New Heights Aerial

**Phot~graphy** LLC 12619 Second Branch Ro d Chesterfield, VA 23838 April21 , 2015
U.S. Dept. ofTranspo;tttion, Docket Operations West Building Ground

**~loor,** Room Wl2-140 1200 New Jersey Avenfe, SE Washington, DC 20590 Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regull tions Dear Sir or Madam: Pmsuant to Section

**33 oftbe**  FAA Modemization and Reform Act of2012 (the "Reform Act") and 14 "-i
.F
.R
. Part 11 , New



### Hei~ts Aerial Photography LLC (CAY) seeks an exemption fr;oederal Aviation Regul tions ("FARs") detailed below for the following described U anned Aerial System c · led in this application the CA V System, which includes Phantom 2 Vision+ , uad-copter Unmanned Aircraft (UAS) and ground station-baser equipment and crew. New Heights Aerial Photography LLC wishes to serve our community by providing professional photograph and videography servi9es for various markets detailed in the following paragraphs. The requested exemptio wou ld support an appliEtion for a commercial Certificate of Authorization to use the above CAY system to c nduct aerial photography, videography and cinematography to nhance real estate, insur ce, specia l event, and land development industries. We plan to serve centra ' Virginia and surrounding areas . The UA, powered by ba h eries , is smaller, lighter requires no fuel , and more maneuverable than



### lar~

**·** aircraft rwming on cot bustible fuel , it operates at lower altitudes with no people on board and will therebr reduce current risk levels and thereby enhance safety and d. · ish the likelihood of de4th or serious bodily injury. With a small payload and maxitpum flight time of only 25 minutes with maximum air speed of 30 knots , this is offers little or no risk to national security. Low-level oblique phot sand video from severa angles are far more eff ective than ground-based imagery fi r displaying the charact ristics of large, complex properties with several buildings a d large trees . Full-sized helicopters have proven more costly than many potential clie ts have been able to af£ rd. The benefits ofreduced cost andimproved quality ofpresentation from the UA 

# wlu be valuable to and benefit many buyers and sellers ofreal property . Additionally, we reques that we be allowed to

**u~e** our system to benefit first responders nearby who might requ· e assistance, including fire fighters, the police, the sheriff , et al. , while remaining subjec to all limitations cited · tlus application as we do so The CAV System woul be as follows: THE PHANTOM 2 VI ION+ UNMANNED CRAFT (UA): • A lightweight (rna imum gross weight of potmds), electric motors powered by

batteries and oper ted with four rotors in t e fonn of a quad-copter that takes off and lands vertica ly, manufactured by 

# dJI, PHANTOM 2 VISION+, 3-axel camera stabilization system ; • An on-board flight computer with GPS na, .gation and location ability that

receives signals for flight contro s from a ground-based transmitter /control er; • An on-board tele1 etry system that

**deliver**

**~** flight data from the on-board flight

computer to the o -board radio transmitter including alti tude AGL , horizontal

**a~d** vertical speed compass direction of 1ight and direction back to its lalmch stte ; • A 5.8GHz on-boar radio transmitter that rsmits live video from the on-board

camera plus all tJ>e flight data from the telemetry system described above ; Frequency 2462MHz THE GROUND

**STA ION-BASED**  PART OF I THE SYSTEM: • A Pilot in Command (PIC) in operational control of a ilight operation from

beginning to end and who controls the UA

**~hile** 

### in the air; • A lOOmw,

**2.4G~** radio transmitter /controller operated by the PIC to control the UA while in flight ; • A radio receiver r ceiving live video and flight data from the on-board

camera and comp ter projects it all together onto a screen for the PIC to view during flight; • A Visual

**Observ~** (VO) is a person wh provides a second pair of eyes to

visually track the J A while in flight. The CA V System will 

### be operated 

### in tl1e field

**w~th** both a PIC and a VO in accordance with FAA Policy N 8900
.22 1 Section 14



## "Operationa~ Requirements for UAS" and with the following Restrictions: 

## I (a) No flight will be !made witl1 a UA Gross

**~ight** exceeding 55 pow1ds ; (b) All operations

**~I!St** occur 

### in FAA Class airspace at no more than 400 ft. AGL, at an airspeed of n more ilian 25 knots and o further than 3/4 NM from the PIC ; (c) All operations st utilize a visual obsent l er (VO)
. The VO and PIC must be able to communicate by voice at all times during a flight operation; (d) Operations will e restricted to flights



## o~er private property with the pennission of the property owner; (e) The PIC must ha e accmnulated and logg d , in a manner consistent witll 14 CFR § 61.51 (b) , a mini urn of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least en hours logged as a U pilot w i th a similar UA type ;(f) All required pen ·ts will be obtained fro1 state and local government prior to operation ; (g) The CAV Syste will not be operated ov r densely populated areas; (h) TheCA V Syste will not be operated at 

### ir shows ; (i) The CA V Syste will not be operated ovf any open-air assembly of people ; G) The CA V Syste will not be operated ov r heavily trafficked roads; (k) The CA V Syste will not be operated wi in 5 NM of an airport or heliport; (1) The CAV Syster will not be operated ov r prope1ties smaller than two acres in size ; (m) Operations will b 1 restricted to day only d weather conditions equivalent to VFR ; (n) The PIC will bri f the VO and property wner about the operation and risk before the first flight at eacl new location ; (o) No flight may b made without a Pre-Fii ht Inspection by the PTC before each operation to ascertain that t e UA is 

### in a conditions e for flight. (see Appendix A) The PIC and YO will eet the requirements o lined in FAA Policy N 8900.227 Section 

### 16 personnel Qualificatio s . Additionally, the PIC and VO will perform maintenance on the system and will compl te a course ofmaintena ce instruction as part oftheir initial training. qualified flight crew a strict operation under he guidelines established in 8900.227 , and under all of the Restric ions (a) through ( o) lis ed above, the FAA can have full confidence that the operation will ave an equivalent or gr ater level of safety than manned aircraft performing the same m ssion How this Request Will enefit the Public As Granting this exemptio request furthers the p lie interest. First, Congress has already pronounced that it is in the public's interest to i tegrate commercially flown UASs into the national airspace syste , hence the passing of e Reform Act. Second, New Heights Aerial Photography conducts esearch into safe UAS fperations every time it flies its UAS
. Flight data, visual inspections recorded observations nd flight analyses are compiled to further enhance current safety rotocols. Allowing us lo g more flight time directly relates to our research and our abili to further enhance curr nt safety measures. Third, the public has an interest in reducing the dange r and emission as ociated with current aerial cinematic capture methods , namely, full s·z e helicopters. Our U is battery powered and creates no emissions. In the unlikely event o r UA crashes there is n fuel to ignite and explode. The impact of our lightweight UA is negl"gible when compared t a full size helicopter, notwithstanding the statistically noteworthy safety record of full si helicopters used in motion picture captur e. The public ' s interest is furthered by minimizin ecological and crash impacts by permitting photo and motion pictu e capture through our I ghtweight UA. Progression of the arts nd sciences has been 

### f ndamental to our society since its inclusion in the United States Cons itution. Indeed, Congre s mandated the integration ofUASs into our national airspace syste , in part, to achieve**pr~gression** in this noteworthy, and inevitable, field. Permitting New eights Aerial**Photogr~ahy** LLC to immediately fly within the United States furthers these go Is. Whether it is the a algam of scientific discoveries applicable to feature film making (in luding those drawing pon architecture , physics , engineering and cultural inclusiveness) o advancements in pub icly usable technologies or advancements in equipment available to aw enforcement perso:_rel 

### I first responders that does not cost millions of dollars , gra ting this exemption re uest substantially furthers the public ' s interest in ways known and c ently unknown.

### Granting this request w'll also allow small busi ess owners and home owners to be able to afford high quality aeri I images and video tha1they would otherwise have no access to due to several factors, cost teing the largest. Attached are

### supportin~documents from them nufacture of the Phantom 2 Vision+. All attached documents ha e been studied and will be periodically reviewed by our PIC.

• DJI Phantom V sion 2+ Users Manual • DJI Phantom V sion 2+ Quick Start Gu de • DJI Phantom V sion 2+ Pilot Training uide • Smart Flight B ery Safety Guidelines 

### Our Virginia State Cor oration Commission L C paperwork is also attached for your review. (SCC ID: S548 301) The Contact Informati n for the applicants is fi , llows: New Heights Aerial Ph tography LLC 12619 Second Branch oad Chesterfield, VA 2383 804-476-8505 Dante Robinson OOdrobOO (@.gmail
.com Natasha Nash Tashagop@aol.com

The Title 14 Code of ederal Regulations fro which the exemptions are requested and listed below. Beside each re ation number is the p ge of the attached Addendum upon which each may be found together ith our proposed equiva ent level of safety fol' each regulation:

- 14 CFR Part 21
.. .. .. . .. . .. .. .. .. .. ... .. .. .. .. ... . .. .. .. Addendum Page 4

- 14 CFR 45.23(b)
....... ........ . ..... . .. . .. . .......... Addendum Page 4

- 14 CFR 6l.I 13(a); 61.113(b);
.... .. .. .... .. .... . . ... Addendum Page 4

- 14 CFR 91.7(a); 91.9 )(2); 91.103(b)
............ Addendum Page 4

- 14 CFR 91.109 ; 91.1 9; 91.121..
................. . Addendum Page 3

- 14 CFR 91.15 1 (a); 91.203(a) & 

### (b)
............... Addendum Page 4

- 14 CFR Subpart E (9 .405(a) ; 91.407(a)(l)
.... .. Addendum Page 4

- 14 CFR Subpart E (9 .409(a)(2); 91.417(a) & 

### (b)) Addendum Page 4 -FAA Policy 8900 .227 Paragraph 16(c)(4) and ' aragraph 16(e)(l)
... Addendum Page 4 We are prepared to mo ify or amend any part o this request to satisfy the need for an equivalent level of safe
. Please contact us at y time ifyou require additional information or clarification. We loo forward to working wit your office.

### S incerely and respectf lly,

Dante Robinson

Natasha Nash

### ADDENDUM EXEMPTI N REQUESTS AND ErUIVALENT LEVEL OF SAFETY New Heights Aerial

**Ph tograph** 
**y** 

### LLC , requests 

# F exemption from the followin g r egulations as well as any additional r gulations that may tec,cally apply to the operation ofthe CA V System: 14 CFR Part 2 1 , Subpartt H: Airworthiness Certificates 21
. 191 Experimental cerificates
. Experimental certificat e are issued for the folloring purposes: (a) 

### Research and devel pmcnt. Testing new airjcraft de sign concepts , new aircraft equipment, new aircraft installation , new aircraft operating techniques, or new uses for aircraft
. (b) 

### Showing complia nc with r e

gulations
. Conducting flight tests and other operations to show compliance with the · orthiness regulations including fli ghts to s how compliance for issuance of type and supplemental e certificates, fli g hts t3 substantiate major design changes, and fli ghts to show compliance with e function and

**reliabili~** 

### requirements of the regulation s. Sect ion 45.23(b)

**presc~**

**·** 

### es that when marks inclfde only the Roman capital letter "N" and the registrat ion number is d spla yed on limited,

**res~ cted**  

### or li ght-sport category aircraft or experimental or provisionally certific ted aircraft, the operator must also display on that aircraft near each entrance to the cabin, c ckpit, or pilot station , in etters not less than 2 inche s nor more than 6 inche s high, the words "limit j " "restricted, " "ligh t
- spo , ""experimental, " or "pr ovis ional, " as applicable.
Sect ion 61.113(a) and 

## (lp) prescribes that- (a) no person who holds a private pilo certificate may act as a pilot in command of an aircraft that is carrying Jpassengers or property or compensation or hire ; nor may that person, for compensati on or hire , a t as pilot 

### in command o an aircraft. (b) a private pil t may , for compensatio [ or hire, act as pilot in command of an aircraft in connection with any bu iness or employment if: (1) The ight is only incident a

l t l that business or employment; and (2) The aircraft does not carry

**~asse**

**ge s**  

### or property for compensation or hire
. [ Secti on 91
.7(a) prescrib s t hat no person may operate a civil aircraft w1less it is in an airworthy condition .



# ~ Section 91.7 (b) prescri es that the pilot in com and of a civil aircraft is responsible for determining whether th t aircraft is in condition or safe flight and that the PIC shall discontinue the flight when un airwort 4 1 mechanica l , electrical , or structural conditi ons occur. Section 91.9(b)(2) pro bits operat ion ofU.S
.-rebstered civil aircraft unless there is available in Addendum Page 4 of 10the aircraft a current apJ roved Airplane or



# Rotor **raft** Flight Manual , approved manual material , markings, and placards, l or any combination thereof. Section 91.1 03 (b) presfribes that a pilot shall 

### fi r any flight, become familiar with runway lengths at airports ofintended use, and takeoff a d landing distance information
. Section 91.1 09( a) pres ribes, in pe1tinent prut, t 1at no person may opera te a civil aircraft
. (except a manned free balloon) th tis being used for flight instruction unless that aircraft has fully functioning dual control
. Section 91
. 119 prescribys that, except when necessary for takeoff or landing, no person may operate an aircraft belo'f the following altitudes: (a) Anywhere
. An

**~titude** allowing, if a po er unit fails , an emergency landing without undue hazard to perso s or property on the surface. (b) Over congested areas. Over any conges l ed area of a city, town, or settlement, or over any open air assem ly of persons , an altitud of 1,000 feet above the highest obstacle within a horizontal radiu of 2,000 feet ofthe a:i.rc 

### · aft
. (c) Over other than congested areas . An alti ude of 500 feet above the surface, except over open water or sparse! populated areas. In tho e cases , the aircraft may not be operated closer than 500 feet to atly r rson, ves sel , vehicle, 0 structure . (d) Helicopters, po ered parachutes , and weight-shift-control aircraft. If the operation IS conducted with ut hazard to persons or roperty on the surface- (1) A

**helicopte**

**~** may be operated at less

**~an** the minimums prescribed in paragraph (b) or (c) of this section, provided rch person operating the helicopter complies with any routes altitudes specifically p

1 scribed for helicopters by the FAA; and (2) A powered arachute or weight-shiijt-control aircraft may be operated at less than the minimu s prescribed in paragrarlh (c) of tlus section. Section 91
. 121 require , in pertinent part, eacl J person operating atl aircraft to maintain cruising altitude by reference to an altimeter that is set ivailable within 100 NM of the aircraft "
... to the elevation ofthe departure airport or an approprij e altimeter setting available before departure." Section 91.151 (a) prescribes that no person

**rna ~**  begin a flight in an airplane tmder VFR conditions unless (const'dering wind and

**forecas**

**~** weather conditions) there is enough fuel to fly to the first point ofintend d landing and, assuming normal cruising speed, ( l) during the day, to fly 

### after that 

### for al least 30
. irtutes [emphasis adder Section 91.203(a) pro · its , in pertinent part, an person from operating a civil aircraft unless it has within it (1) an app opriate and current airw ' rthiness certificate ; and (2) an effective U
.S
. registration certifi ate issued to its owner o , for operation within the United States, the Addendum Page 5 of 10second copy of the Airc aft registration Applica on as provi ded for in § 4 7.3 1 (c). Section 91.203(b) presc ibes , in pertinent part, tl t no person may operate a civil aircraft unless the airworthiness certificate or a special flight**autho~·zation** issued under § 91.715 is displayed at the cabin or cockpit entranc so that it is legible top ssengers or crew. At a maximum gross w ight of 5.3 pow1ds , the A is too small to carry documentation , does not have an entrance, and is not capable of carrying assengers or crew. To obtain an equiva lent level of safety and meet the inte t of 91
.203 , we propose at documents deemed appropriate for this aircraft by the FAA will be co-l cated with the crew at t e ground control station and available for inspection upon request. Section 91.405(a) reqt · es, 

### in pertinent part, that an aircraft operator or owner shall havetl1at aircraft inspected as prescribed subpart E of the same art and shall , between required inspections, except as provided in paragrap (c) oftl1e same section, have discrepancies repaired as prescribed in part 43 ofthe chapter. Section 91.407(a)(l) pr hibits , in pertinent part, y person from operating an aircraft thathas undergone maintenance preventive**maintenan~c ,**  rebuilding, or alteration unless it has been approved for return to s rvice by a person autho ·zed under § 43.7 ofthe same chapter. Section 91.409(a)(2) pr scribes , in pertinent p that no person may operate an aircraft tmless, within the preceding 12 calendar months , it has td an inspection for the issuance of an airworthiness ce1tificat in accordance with part ( ofthis chapter. Section 91.417(a) and ) prescribes , in pertinen1 part, that- (a) Each registe ed owner or operator sh 11 keep the following records for the periods specified in par graph (b) ofthis section (1) Rec rds ofthe maintenance, reventive maintenance, and alteration and records of the 1 0-hour, annual, progres ive, and other required or approved inspections, as ate, for each aircraft (inc uding the airframe) and each engine , propeller, rotor, d appliance of an aircra
. The records must includei) A descript ion (or re renee to data acceptable to the dministrator) ofthe wo k perfonned; and ii) The date of completi n ofthe work performed; and iii) The signature, and ,ertificate number of the person approving the
· craft for return to se ing information: i) The total time in se · ce of the airframe, each engine, each Addendum Page 6 of 10f ropeller, and each rotor.



## ii) The current status



## o~ life-limited parts of each airframe, engine, ropeller, rotor, and appliance. iii) The time since last f l verhaul of all items installed on the aircraft hich are required to be verhauled on a specified time basis
. iv) The current inspecti n status of the aircraft, including the time ince the last inspect ion required by the inspection program under hich the aircraft and its appliances are maintained. v) The current status of applicable airworthiness directives (AD) and safety directives includillf, for each, the method of compliance, the AD or



### afety directive number nd revision date
. Ifthe AD or safety directive involves recurring action the time and date when the next action is required.
vi) Copies of the forms rescribed by§ 43 .9( d) oftl1i s chapter for each ajor alteration to tl1e · rame and currently installed engines , rotors, ropellers , and appliance
. (b) The owner r operator shall retain th j following records for the periods prescribed: 

### (1) The f ecords specified in parlraph (a)(l) of this section shall be retained until the wor is repeated or s uperse ed by other work or for 1 year after the work is perform d. (2) The 1 ecords specified in par graph (a)(2) of this section shall be retained and transfe1 ed with the aircraft at tht time the aircraft is sold. (3) A



### 1~ **t** of defects furnished tor re gis tered owner ot' operator under § 43.11 ofthis chapter shall be Jtained until the defects are repaired and the aircraft s approved for return to ervice. Co ncluding, the Phanto n 2 Vision+ aircraft (U ) will not carry persons or propetty, w ill not carry fuel , and will



## onl~y under strict operatiohal requirements. Combined with the UA's lightweight, being cons cted primarily of carbJn fiber and plastic, we propose that the UA will be at least as safe, 

### ifno safer, than a conventionally certificated aircraft performing the same lTilSStOn
. Ifan aiiworthiness cet tcate is not appropriate for tllis application, then we request an exemption of 14 CFR Part 21, Sub art H, and the requiremlnt for an airwortl1iness certificate in general , citing the equivalent level of afety. The UA is battery oper ted and the maximum d ation of flight from a single battery charge is 25 minutes witl1 a 20% res rve. Since the aircraft w 11 never fly more than 3/4 NM from the Addendum Page 7 of 10point of intended landint a full battery charge at law1ch will ensure that we meet the reserve energy requ irement oftl}.is paragraph. We reques an exemption to the word "fuel" and ask for an equivalent interpretatiod with the word "energy". 

### It is our intention that th PIC perform maintena ce and inspection of the aircraft and "be authorized to approve t e aircraft for return to sef ice ." As provided in the Pre-Flight Checklist in Appendix A, the PIC wi 

### 1ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct etailed inspections aftc every two hours of flight. Maintenance performed by the PIC is limited to

**~epa iring**  small cracks, replacing a propeller, checking electrical

**co~ections** and updating sortare and firmware for the on-board computer . All other maintenance will be performed by the manfacturer or designated repair facility
. The PIC wi ll document work performed in accordance wi h 9 1.417. We feel that due to the size , construction, and simpli ity ofthe aircraft, the P can ensure an equivalent level of safety. The UA maximwn

**gros**
**~** weight is 3.0 pounds and the PIC is not on board. Both the PIC and the YO are required to be in YLbS. Given the unlikely efent that both the PIC and YO become medically incapacitated while the Jircraft is 

### in flight , the U will retwn autonomously to the s ite of launching and land without crew · tervention. Therefore , requiring the PIC and YO to meet the same medical requirements as a commercial pilot carrying passenger in a lar ge aircraft is an necessary burden. The UA will always fly

**~elow** 400 feet AGL and will not need to maintain cmising altitudes in order to prevent conflict with other aircraft. An bove Ground Level altimeter measurement above takeoff point is trrsmitted via radio from A on-board computer to display screen held by the PIC, providing a f onstant updated AGL readout. We propose that the miq.imum medical requirements for the PIC and YO be vision corrected to 20/20 and a valid , state issued driver's license. T 1e 20/20 vision requirement will ensure that the PIC and YO can see an avoid air traffic; a licen ed driver is medically qualified to operate a much larger vehicle. UAS Operating Parame ers The petitioner states th he will abide by the fol owing additional operating conditions w1der tllis exemption : I • operate his UAS below 300 feet and witliin a radius distance of 1000 feet from the controller to both aid in direct line of



## sig~t visual observation ; 1 • operate the U A I for 

### 15 minutes per

**flig~t**

**;** land hi s UAS rior to the manufacturer' s recommended minimum level of battery power; • operate his UA only within visual line

**f** sight (YLOS); • use the UAS' gJ , bal positioning system ( PS) flight safety feature whereby it hovers and then slowly lands ifcommunication ith the remote control pilot is lost; conduct all ope ations under his own pe ' Onal and flight safety protocols ( including posting a wan g sign reading: "Attenti n Aerial Photography in Progress- Remain Addendum Page 8 of 10Back 150 feet" contained in the operafng documents and will actively analyze flight data and other sources of information to constantly update and enhance his safety protocols ; • contact respecti e airports if operations ill be within 5 miles to advise them ofhis estimated flight time, flight duration, ele ation of flight and otl1er pertinent information; • always obtain I necessary permissions rior to operation; and • have procedure 

### in place to abort flights the event of safety breaches or potential danger.

Addendum Page 9 of 10

### APPENDIX A- F IGHT MANUAL
(a) No flight will be · de with a UA Gross we ght exceeding 55 pounds; (b) All operations mu t occur in FAA Class airspace at no more than 400' AGL, at an airspeed of no mor than 25 knots and no**ft~her** than 3/4 NM from the PIC ; (c) All**oper~tions** mu t utilize a_ visual o_bserv**~** (YO)
.**Th~** YO and PIC must be able to commumcate verb
. lly at all ttmes dunn g a · tght operatiOn ; (d) Operations will b restricted to flights ov r private property with the permission ofthe property owner; (e) The PIC must hav accumulated and logge , in a manner consistent with 14 CFR 

### § 61.51 

### (b) , a minimum of 100 fl ght cycles and 25 hours ftotal time as a UA rotorcraft pilot and at least ten hours logged as a A pilot with a similar U type ; (f) All required permi swill be obtained from tate and local government prior to operation ; (g) The CAY System ill not be operated over densely populated areas; (h) The CAY System 

### ill not be operated at a· shows ; (i) The CAY System 

### ill not be operated over any open-air assembly ofpeople; G) The CAY System ill not be operated over heavi ly trafficked roads ; (k) The CA V System 

### '11 not be operated witl · 5 NM of an airport or heliport; (1) The CAY System ill not be operated over properties smaller than two acres in size; (m) Operations will b restricted to day only**~f.** weather conditions equivalent to YFR; (n) The PIC will brie the YO and property o ner about the operation and risk before the first fli ght at each ew location ; (o) No flight may be ade without a success ul Pre-Flight Inspection by the PIC before each operation to ascert in that the U A is in a c ndition safe for flight.
(1) Use voltmeter to d tennine that UA batte is fully charged in order to prevent unexpected premature descent ; (2) Check all wiring co ections are tight; (3) Check all propeller are undamaged and no racks exist in any structural members of the UA ; (5) Turn on radio con oiler, check for adequat voltage , set it to connect to the UA, move all control switches to orward or down positio and throttle control stick full back position ; (6) Connect UA main attery , check for radio c ntact with UA's radio receiver ; (7) At a location differ nt from previous flight, e -set GPS and compass to CtUTent location; (8) Tum on transmitter gimbal and camera. 

### TO REGAIN CONT



### 1. 

### 2. Throttle = 50°/ 3. Mode = 

### A TTl 4. Failsafe= OFF Mode= G 

### IOCONTACT If radio contact is n , t restored, the UA will**a~tomatically** 

### c ntinue at SOft. above its last eleva ion before losing contact toward its t keoff point , t h en descend and l and t ere autonomously

Addendum Page 10 of 10