UNITED ST AT ES OF AMERI CA DEP AR TMENTOF TRANSPOR TA TI ON FEDERAL

A VI AT IO N ADMINISTRA TI ON WA SHI NGT ON, DC

Regulatory

Docket No. _______________

IN THE MA

TTER OF THE PETITION FOR EXEMPTI ON OF: CHRI ST OPHER A. MERGENTHALER

FOR AN EXEMPTION SEEKING R ELIEF FROM THE REQUIREMENTS OF TI TLE 14 OF THE CODE OF FEDERAL REGULA

TI ONS SECTI ONS 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERA TI ON OF THE DJ I PHANT OM 3 UNMANNED AI RCRAFTSYSTEM PURSUANTTO SECTION 333 OF THE F AA MODERNIZA

TI ON AND REFORM ACTOF 2012 (PUBLIC LA

W 1 12

- 95)

Submitted on June 30 , 2015

CHRI ST OPHER MERGENTHALER 1952 HERI TA GE GROVE CI R.

UNIT 1227 TA LLAHASSEE , FL 32304 (847)

- 772

- 4153

TA BLE OF CONTENTS PageGLOSSAR Y OF ABBREVIA

TI ONS.................................................................................................................3

SUMMAR

Y.

.............................. .............................................................................................. 4

IN TRODUCTION AND INTERESTS OF PETITIONER......................................................4

BACKGROUND............................................... ......................................................................5

BASI S FOR PETITION........................................................................................................... 5

NAME AND ADDRESS OF PETITIONER................................................................6

THE SPECI FI C SECTIONS OF 14 C.F .R. FROM WHI CH CHRI ST OPHER MERGENTHALER SEEKS EXEMPTION..........................................................7

THE EXTENT OF RELIEF CHRI ST OPHER MERGENTHALER SEEKS AND THE REASON CHRI STOPHER MERGENTHALER SEEKS THE RELIEF.........................9

THE REASONS WHY

GRANTING CHRIST OPHER MERGENTHALER’S REQUEST WOUL D BE IN THE PUBLIC INTEREST

........................................... ..................1 1

THE REASONS WHY

GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL

Y A FFECTSAFETY

..............................................................................13

CONCLUSION................................................................ .......................................................19GLOSSAR Y OF ABBREVIA

TI ONS

AGL Above Ground Level AOI Area of Interest AT C Air T

raf fic Control AT O Air T

raf fic Organization AV Aerial Ve hicle CFR Code of Federal Regulations COA Certificate of Authorization FA A Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LO L Lo ss of Link NAS National Airspace S ys tem NOT AM Notice to Airman PI C Pilot In Command Section 333 F

AA Modernization and Reform Act of 2012 (FMRA) SO Safety

Observer SOP Standar d Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Vi sual Flight Rules VLOS Vi sual L ine of Site VMC Vi sual Meteorological Conditions VTOL Ve rtical T akeof f and Landing DJI UA

V manufactur er ESC Electronic speed control FPV First Person V iew LI

- PO Li thium Poly mer battery RCV Radio Controlled vehicle**SUMMAR Y**  Christopher Mergenthaler, operating under the company title, Delta Aerial Imaging, LLC. seeks exemption from the requirements of 14 C.F .R §§ 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the F AA Modernization and Re form Act of 2012 (FMRA). This exemption will permit Chris Mergenthaler to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography for Marketing, film sets, real estate photography , commercials, specia l events, wedding cinematograph y, marine photography

, roofing inspection, and landscape imaging over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF**  **T HE PETITIONER** 
My name is Christopher Mergenthaler, and I am a Aerial RCV enthusi ast with over 8 y ears of exper ience operating various ty pes of Aerial RCV’ s as well as 1 y ear operating quadcopter UAS’ s

. Christopher Mergenthaler also provides customers high qualit y photograph y for a wide range of applications. Chris Mergenthaler is cons idered an advanced level RCV pilot who has even taught beginners how to pilot RCV’ s. The objective of Delta Aerial Imaging LLC is to provide superior aerial imaging for a wide range of industries and events while promoting safe UAS operations and promoti ng public knowledge of UAS’ s as well as providing a high level of knowledge about UAS’ s.**BACKGROUND**

Unmanned Aircraft Sy stems: DJIPhantom 3 UAS Chris Mergenthaler seeks an exemption to operate the DJ I sy stem for compensation or hire within the NAS. The DJ I Phantom 3 is a vertical takeof f and landing (VT OL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sy stems. The DJ I Phantom 3 has a maximum gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJ I Phantom 3 UAS is equipped with four main rotors; driven by a Lithium Poly mer battery powered electric moto r

. The DJ I Phantom 3 UAS that will be operated b y Chris Mergenthaler will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F .R Part 47, Aircraft Registration, and marked in accordance with 14 C.F .R. Part 45, Id entification and Registration Markings.

**BASIS FOR PETITION**

Petitioner, Christopher Mergenthaler, pursuant to the provisions of the Federal Av iation Regulations (14 C.F .R. § 1 1.61) and the F AA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft S ys tems, hereb y petitions the Administrator to commercially operate the DJ I Phantom 3 UAS in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F .R §§ 61.1 13(a) & (b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Chris Mergenthaler ’s operatio n of DJ I Phantom 3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Accordingly

, Chris Mergenthaler requests relief from Sections 91.405(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate. Chris Mergenthaler submits that the requested relief is proper since an equivalent level of safet y will be ensured. Chris Mergenthaler will use experienced personnel or technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 Manual). Furthermore, Chris Mergenthaler will document and maintain all maintenance records for the DJ I Phantom 3

. Relief from certain requirements of Section 61.1 13(a) and (b), entitled Private pilot pr ivileges and limitations: Pilot in command, is requested b y Chris Mergenthaler to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated , by meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the DJ I Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from peopl e, vessels, vehicles and structures.Chris Mergenthaler seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because

the DJ I Phantom 3 UAS do es not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H

. As su ch, Chris Mergenthaler submits that he will ensure that the DJ I Phantom 3 UAS is in an airworth y condition, prior to every flight, b y determining that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJIPhantom 3 Instruction Manual), and that the aircraft is in a condition for safe flight. Chris Mergenthaler also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJIPhantom 3 UAS will not have a t ypical barome tric altimeter onboard. However, altitude information of the DJ I Phantom 3 UAS will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA S to the GCS for active monito ring of the flight path. This altitude information, combined with Chris Mergenthaler ’ s operation of the DJ I Phantom UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally

, Chri s Mergenthaler seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Chris Mergenthaler submits that safety will not be af fected b y operation of the DJ I Phantom 3 UAS during daylight hours i n visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

In accordance with 14 C.F .R. § 1 1.81, Chris Mergenthaler provides the following information in support of its petition for exemption:

**A. Name And**  **Addr ess Of**  **The Petitioner**

**.** The name and address of the Petitioner and point o f contact is: CHRI ST OPHER MERGENTHALER 1952 HERI TA GE GROVE CI R. UNIT 1227 TA LLAHASSEE,FL

32304 (847)

- 772

- 4153 Email: cam13g@m y. fsu.edu**A . The Specific Sections Of 14 C.F**  **.R . Fr**  **om Which**  **Chris Mergenthaler Seeks Exemption** 

**. 1.**  **Chris Mergenthaler Seeks Exemption Fr**  **om The Requir ements Of Section 61.1**  **13(a) And (b).**  Section 61.1 13, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or propert y for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may

, fo r compensation or hire, act as PIC of an aircraft in connection with an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employment; and (2) The aircraft does not carry passengers or propert y for compensation or hire.

**2. Christopher** 

**Mergenthaler Seeks Exemption Fr**  **om T**  **he Requir ements Of Section**  **91.7(a).** Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworth y condition

. **3. Christopher** 

**Mergenthaler Seeks Exemption Fr**  **om T**  **he Requir ements Of Section**  **91.121.** Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising al titude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set,
when operating

-- Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of th e aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

**4. Christopher** 

**Mergenthaler Seeks Exemption Fr**  **om T**  **he Requir ements Of Section**  **91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b) , states the following: (b ) No person may begin a flight in a r otor craft under VFR conditions unless (considering wind and for ecast weather conditions) ther e is enough fuel to fly to the first point of intended landi ng and, assuming normal cruising speed, to fly after that for at least 20 minutes.**5. Christopher Mergenthaler**  **Seeks Exemption Fr om** **T he Requir**  **ement Of Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepanc ies repaired as prescribed in part 43 of this chapter[.]
**6. Christopher**

**Mergenthaler Seeks Exemption Fr**  **om T**  **he Requir ements Of Section**  **91.4 07(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]
**7. Christopher**

**Mergenthaler Seeks Exemption Fr**  **om T**  **he Requir ements Of Sections**  **91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Inspections, subsection (a), states the following: (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 b y a person authorized by § 43. 7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. **8. Christopher**

**Mergenthaler Seeks Exemption Fr**  **om T**  **he Requir ements Of Sections**  **91.417(a) And 91.417(b).**  Section 91.417 , entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.41 1 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

1. Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must includ e
-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return t o service.

2. Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor

.(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and applian ce. ( iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and re vision date. If the AD or safet y directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currently installed en gines, rotors, propellers, and appliances.

3. The owner or operator shall retain the following records for the periods prescribed: (i ) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 y ear after the work is performed. (ii ) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (iii ) A list of defects furnished to a registered owner or operator under § 43.1 1 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

**B**

**. The Extent Of Relief**  **Christopher Mergenthaler**  **Seeks And**  **T he Reason**  **Christopher Mergenthaler**  **Seeks The Relief.**  **1. Extent Of Relief Christopher**  **Mergenthaler Seeks**  **And The Reason**  **Christopher Mergenthaler**  **Seeks Relief Fr om** **Section 61.1 13(a)**  **And (b).** Relief from Section 61.1 13(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current a nd valid airman medical certificate, and who has met certain flight

- hour and curren cy requ irements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.1 13(a) and (b) state that a private pilot may , for compensation or hire, act as PIC of an airc raft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more full y below, Christopher Merge nthaler submits that an equivalent level of safety

will be maintained because no PI C will be allowed to operate the DJ I Phantom 3 UAS unless that PI C has met certain flight

- h our and currency requirements, demonstrating that the PIC i s able to safel y operat e th e DJ I Phantom 3 UAS in a manner consistent with the operations specifications a s described in this exemption, including evasive and emergency maneuvers, as well as maintain ing appropriate distances from people, vessels, vehicles and structures. Furthe r more, Christopher Mergenthaler submits that all flights of the DJ I P hantom 3 UAS , conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental toChristopher Mergenthaler ' s business; and (2) will not carry passengers or propert y for compensation or hire.

**2. Extent Of Relief**  **Christopher Mergenthaler**  **Seeks And**  **The Reason Christopher**  **Mergenthaler Seeks Relief Fr**  **om Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airw orthiness, is requested to the extent required t o allow Christopher Mergenthaler to determine that the DJI Phantom 3 UAS is in airworthy

condition prior to every

flight by ensuring that the UAS is in compliance with the operating do cuments (i.e., Christopher Mergenthaler ’s Aerial Operations Manual, Monthly Maintenance Log, and DJIPhantom 3 Instruction Manual , Pre

- Flight Checklist ). Christopher Mergenthaler seeks the requested relief because the DJ I Phantom 3 UAS do es not require an airworthiness certificate in acco rdance with 14 C.F .R. Part 21, Subpart H. Therefore, Christopher Mergenthaler will ensure that the DJ I Phantom 3 UAS is in airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 Instruction Manual) prior to every flight, and further, determine that the aircra ft is in condition for safe flight, as stated in the conditions and limitations below

. **3. Extent Of Relief Christopher**  **Mergenthaler Seeks**  **And The Reason**  **Christopher Mergenthaler**  **Seeks Relief Fr**  **om Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 UAS , which utilizes a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the F AA requires that an y altitude information concerning UAS operations be reporte d to air traffic control (A

TC) in feet above groun d level (AGL), Christopher Mergenthaler seek s the requested relief because the DJ I Phantom 3 UA S ’s altimeter may be set o n the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable con ditions and limitations stated below

. As more full y set forth herein, an equivalent level of safet y will be maintained since the DJ I Phantom 3 UAS is equipped with a baro metric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude informat ion of the UA on the heads

- up d isplay

of the GCS.

**4. Extent Of Relief**  **Christopher Mergenthaler**  **Seeks And**  **The Reason Christopher**  **Mergenthaler Seeks Relief Fr**  **om Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to al low flights of the battery powered D JI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Christopher Mergenthaler seeks the requested relief because without an exe mption from Section 91.151(b), the flight time duration of the battery powered DJ I Phantom 3 UAS w ill severel y constrain the pract icality of any aerial video or still photo flight operations that Christopher Mergenthaler proposes to conduct pursuant to this Petition. Significantly

, as set forth below, the technical specifi cations of the DJ I Phantom 3 UAS , the DJ I Phantom 3 UAS’ s ope rating d ocuments, and proposed operating limitations, ensure that Christopher Mergenthaler will safel y operate the battery powered DJ I Phantom3 UAS during daylight hours in visual meteorological conditions (VMC), under visual

flight ru les (VFR), with enou gh battery power to fly for a total duration of 15 .5 minutes to the first point of intended landing an d, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

**5. Extent Of Relief**  **Christopher Mergenthaler**  **Seeks And**  **The Reason Christopher**  **Mergenthaler Seeks Relief Fr**  **om Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),**  **And 91.417(a) & (b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certifi cate, Christopher Mergenthaler requests relief from these Sections because the DJ I Phantom 3 UAS does not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certif icate. Accordingly

, Christopher Mergenthaler will use trained techn icians to perform maintenance, alterations, or pr eventive maintenance on the UAS usin g the methods, techniques, and practices prescribed in the UAS operating docume nts (i.e., Christopher Mergenthaler Aerial Operations Manu al, Monthly Maintenance Log, D JIPhantom 3 Instruction Manual , Pre

Flight Checklist ). Furthermore, Christopher Mergenthaler will document and maintain all maintenance records for the DJ I Phantom 3 U AS

. **C. The Reasons**  **Why Granting Christopher**  **Mergenthaler ’s**  **Request W ould Be In**  **The Public Inter**  **est; That Is, How It**  **Wo uld Benefit**  **The Public As**  **A Whole.** 

Granting the present Petition will further the publi c interest b y allowing Christopher Mergenthaler to safely

, efficiently

, and economically

perform a erial video and photography of construction sites, real estate, and landscape , boats, and events over certain areas of the United States. Additionally

, use of the DJIPhantom 3 UAS will decrease congestion of the NAS, reduce pollution, crashes and accidents cau sed by pilot error and provide significant benefits to the eco nom y. Notably , the benefits of Christopher Mergenthaler ’s proposed operation of the DJ I Phantom 3 UAS will b e realized without implicating any privacy issues. **1. The Public Will Benefit Fr om** **Decr eased Congestion Of**  **The NAS.**

The DJ I Phantom 3 UAS is battery powered and serves as a safe, ef ficient, and economical alternative to the manned aircraft tradition ally utilized to obtain aerial imagery

. By reducing the amount of manned aircraft needed to perform aeri al acquisitions, an exemption allowing the use of a DJIPhantom 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the sa fet y of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJ I Phantom 3 do es not require an airport to takeof f or land. Likewise,
a reduction of manned aircraft conducting aerial video and photog raph y missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The Public Will Benefit Fr om**  **The Safety And Efficiency Of**  **The DJI Pha**  **ntom 3 UAS**

**.** Conducting aerial acquisitions with the DJIPhantom 3 UAS , instead of manned aircraft, will greatly benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By using battery

power and electric motors, the DJ IPhantom 3 UAS produces no air pollution, and is the most viable environmentally conscious a lternative to the cabin class, six cylinder internal combustion engine aircraft that are ty

picall y utilized for aerial video and photography , while burning approximately

20

- 30 gallons per hour of lead ed aviation fuel. The DJ I Phantom 3 UAS , while reducing the carbon footprint of aerial acquisitions, also elimin ates noise pollution, as the UAS is propelled by battery powered electric motors, rather than an internal combustion engine.
By using the DJ I Phantom 3 UAS to pe rform aerial acquisi tions, the substantial risk to life and propert y in the air and on the groun d, which is usually associated with traditional manned aircraft flight operations, will be subst antially reduced or completel y eliminated. Aside from the lack of flight crew member s located onboard the aircraft, the DJ I Phantom 3 (weighing approximately 2 pounds 14 ounces at its maximum gross weight, with a length of 16 inches, and a width of 16 inc hes , and with no fuel on board), has less ph ysical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty

pic all y conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacit y of 180 gall ons).
**3. Performing Aerial**  **Vi deo and Photography Operations**  **Wi th**  **The DJI Phantom**  **3 UAS**  **Wi ll Benefit**  **The Economy**

**.** In addition to being safe and efficient, the DJ I Phantom 3 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJIPhantom 3 UAS will allow United States based companies, like Delta Aerial Imaging LL C , to remain competitive and contribute to growth of the U.S. economy . Specifically

, with the rising cost of aviat ion fuel an d the Environmental Protection Agency (“EP A”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology

i n order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operational flexibility

co mpared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJ I Phantom 3 U AS, companies such as Delta Aerial Imaging LLC , can remain competitive and profitable, and therefore, provide greater job stability

to employ ees and contractors, which will ultimately co ntribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJ I Phantom 3 UAS , provides a stable wor kforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remai n competitive both in the United States and abroad. **4. Ther**  **e Are No Privacy Issues.**  Similar to the manned aerial acquisition flight operations that have been conducted for decades, Christopher Mergenthaler ’s proposed operation of the DJ I Phantom 3 UAS will not implicate any privacy issues. Specifically

, the DJIPhantom 3 UAS will be operated only in compliance with oper ating documents (i.e., Christopher Mergenthaler Aerial Operations Manua l, Monthly Maintenance L og, DJIPhantom 3 and Instruction Manual , Pre

- Flight Checklist ) which requires propert y owne r involvement as well as local law enforcement notification, and in accordance with the Federal Av iation Regulations, including the minimum altituderequirements of 14 C.F .R. § 91.1 19.

**E. The Reasons**  **Why Granting The Exemption W ould N**  **ot Adversely**  **Affect Safety , Or**  **How The Exemption W** 

**ould Pr ovide**  **A Level Of Safety**  **A t Least Equal**  **To That Pr**  **ovided By**  **The Rule Fr**  **om Which**  **Christopher Mergenthaler**  **Seeks Exemption.**

**1. Reasons Why The DJI Phantom 3**  **UAS Mee**  **t s**  **The Conditions Of The F**  **AA Modernization and Reform**  **Act of 2012 (FMRA) Section 333.** In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Christopher Mergenthaler ’s operation of the DJIPhantom 3 UAS meet s the conditions of FMRA Section 333, and w ill not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Section 333 provides authority

for a UAS to operate without airworthiness certificati on and sets forth requirements for considering whether a UAS will create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security . Specificall y, FMRA

Section 333 states the following, in part: (a) In General.

- - Notwithstanding an y other requirement of this subtitle, and not later than 180 day s after the date of enactment of this Act, the Sec retary of T ransportation shall determine if certain unmanned aircraft s ys tems may operate safel y in the nationa l airspace s ys tem before completion of the plan and rulemaking required by section 332 of this Act or the guidance required b y section 334 of this Act. (b) Assessment of Unmanned Aircraft Sy stems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

— (1) which t ypes of unmanned aircraft s ys tems, if any , as a result of their size, weight, speed, operational capability , proximity

to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the n ational airspace sy stem or the public or pose a threat to national security ; and whether a certifi cate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required fo r the operation of unmanned aircraft s ys tems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft s ys tems may operate safel y in the national a irspace s ys tem, the Secretary

shall establish requirements for the safe operation o f such aircraft s ys tems in the national airspace s ys tem. In seeking this exemption, Christopher Mergenthaler submits that the DJ I Phantom 3 UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specificatio ns Of The DJI Phantom 3 UAS Demonstrates**  **Its Safe Characteristics** 

**.** The DJ I Phantom 3 UAS do es not create a haz ard to users of the NAS or the public, or otherwise pose a threat to national security considerin g its size, weight, speed, and operational capabilit y. **i. Te**  **chnical Specifications Of The DJI Phantom 3**  **UAS**

**.** The technical specifications of the DJ I Phantom 3 UAS is set forth by the DJIPhantom 3 Specifications and Data Sheet, att ached hereto as Exhibit A

. **ii. The DJI Phantom 3**  **UAS’ Autonomous Flight**  **And Navigation Modes**  **Enable The UAS**  **To Remain Within**  **A De**  **fined Operational Ar**  **ea.** The DJ I Phantom 3 UAS may be ope rated in both manual and full yautonomous flight modes. A complete description of the flight and navigational modes of the DJ I Phantom 3 UAS is provided at pages 25

- 35 of the DJ I Phantom 3 User Manual, attached hereto as Exhibit B

. **iii. The DJI Phantom 3**  **UAS is Designed For Automatic**  **Return To**  **Home Point Or**  **Hover In**  **The Event Of Loss Of**  **The Contr ol Link Or**  **Navigation.** When the Control L ink is lost, the DJIPhantom 3 UAS will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Phantom 3 UAS do es not reacquire control link data from the GCS, the UAS will assume that the Control L ink is lost and the UAS will return to the home position (i.e., failsafe mode ) via GPS, and will descend to the takeof f position and shutdown. A complete description of the Failsafe Functions of the DJ I Phantom 3 UAS are set forth at pages 27 through 29 of the DJ I Phantom User Manual, attached hereto as Exhibit B

. **iv**

**. The DJI Phantom 3**  **GCS And Its Operation.**  A complete description of the operation and specifications of the D JI Phantom 3 GCS and flight control software is provided at pages 32 through 43 of the DJ I Phantom 3 User Manual . DJ I Phantom 3 User Manual is atta ched hereto as Exhibit B. **b. Flight Operations Of DJI P hantom 3 UAS is**  **Limited To**  **The Line Of Sight**  **Of A**  **Certificated Pilot in Command With**  **A Safety Observer** 

**.** Christopher Mergenthaler will only utilize certificated pilots who possess a current and valid airman medical certif icate to act as a pilot in command (PIC) of the DJ I Phantom 3 UAS

. Additionally , a safet y observer will assist all pilots during flight time. **c. Flights Of DJI Phantom 3 UAS**  **Wi ll Be Conducted**  **Pursuant To**  **Specific Operating Limitations.**  In seeking this e xemption, Christopher Mergenthaler proposes to commerciall y operate the DJIPhantom 3 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to th e following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maxi mum gross weight: DJ I Phantom 3 Unmanned Aircraft Sy stem. Proposed operations of any other aircraft will require a new petiti on or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography

. 3. The UAS may

not be flown at an indicated airspeed exceeding 20 knots.

4. The UA S must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by A TC

. All altitudes reported to AT C must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision un aided by an y device other than corrective lenses, as specified on the PIC’ s F AA

- issued ai rman medical certificate.6. The use of first person view (FPV) b y the PI C or safet y observe r (SO) is not permitted.

7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VLOS capability . The SO and PI C must be able to communicate verbally at all times. Electronic messagi ng or texting is not permitted during flight operations. The PIC must be designated before the fli ght and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traf fic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made availab le to the Administrator upon re quest. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the oper ating documents, the conditions and limitations contained in the grant o f exempt ion take precedence and must be followed. Otherwise , the operator must follow the procedures as outlined in its operatin g documents. The ope rator may update or revise its operating documents. It is the operator ’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determin es that any update or revisi on would aff ect the basis upon which the F AA granted the exe mption, then the operator must petition for amendment to its grant of exemption. The F AA’s U AS Integration Of fice (AFS

- 80) may

be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condit ion f

or safe flight. If the inspection reveals a condition that af fects the safe op eration of the UAS, the aircraft is prohibited from operati ng until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance an d alterations must be properl y documented in the aircraft records.

11

. An y UAS that has undergone maintenance or a lterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional tes t flight must make an entry in the a ircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered i n the relevant sections of the oper ati ng documents. 13. The operator must follow the UAS manu facturer ’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.14. The operator must carry out its maintenance, i nspections, and record keepin g requirements, in accordance with the operating documents. Mainten ance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accompli shed,
and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the correc tive action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may not permit any PIC to operate unles s the PI C meets the operator ’s qualification criteria and demonstrates the ability to safe ly operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances f

rom persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F .R. § 61.51(b). Flights for the purposes of training the operator ’s PI Cs are permitted under the terms of the exempti on. However, training operation s may onl y be conducted during dedicated training sessions. During training, proficiency , and experience

buildin g flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F .R. § 91.1 19. 19. UAS operations may

not be conducted during night, as defined in 14 C.F .R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the F AA of fi ce closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA S may

not operate within 5 nautical miles of an airport reference point as denoted on a current F

AA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, and the operation is conduc ted in accordance with a NOT

AM as required b y the operator ’s COA. The letter of agreement wi th the airport management must be made available to the Administrator upon request.
21. The UA S may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C.

22. If the UA S loses communications or loses its GPS si gnal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PI C must abort the flight in the event of unpredict ed obstacles or emergencies in accordance with the operating documents.24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery

power remaining. 25. The operator must obtain an Air T raf fic Organizati on (A

TO) issued Certificate of Wa iver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA

will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requ irements in the AT O issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemptio n must be identified by serial number, registered in accordance with 14 C.F .R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F .R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency s pectrum used for operation and control of the UA

must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F .R. 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UA

must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated b y the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PI C, SO, operator trainees or essential persons),
ves sels, vehicles, and structures unless: a. Barriers or structures are present that suf ficiently protect nonparticipating persons from the UA

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, ve h icles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C ha s made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.1 19(a).

32. All operations shall be conducted over private or c ontrolled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.33. An y incident, accident, or flight operation that transg resses the lateral or vertical boundaries of the operational area as defined b y t he applicab le COA must be reported to the FA A's UAS Integration Office (AFS

- 80) within 24 hours. Acc idents must be reported to the National Tr ansportation Safety Board (NTSB) per instructions c onta ined on the NTSB W eb site: www .ntsb.gov

. **2. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Section 6 1.1**  **13(a) And**  **(b) W ould**  **Not Adversely**  **Affect Safety**

**.** Christopher Mergenthaler submits that the equivalent level of saf et y established by Section 61.1 13(a) and (b) will be maintained because no PI C will be allowed to operate the DJI Phantom 3 UAS unless that PI C has de monstrated, by meeting minimum flight

- hour and currency

requirements, that the PI C is able to sa fel y operate the DJ I Phantom 3 UAS in a manner consistent with the ex emption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Christopher Mergenthaler ’s proposed area of operations, and the operating li mitations set forth

- above; the parallel nature of privat e pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11 062); and the airmanship skills necessary to safely operate the DJ I Phantom 3 UAS , Christophe r Mergenthaler submits that the additional manned airmanship experience of a
comme rciall y certificated pilot would not correlate to the airmanship skills necessary for Christopher Mergenthaler ’s specific proposed flight operations. The F AA has previously granted relief from Section 61.1 13(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those present ed herein (e.g. Exemption Nos. 11 062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 1 11 09, 1 111 0, 1 111 2, 111 36, 1 11 38, 1 11 50, 111 53, 1 11 56, 1 11 58, 1 11 59, 1 11 60, 1 11 61). Christopher Mergenthaler will not allow an y P IC to operate the DJ I Phantom 3 UAS unless that PI C has demonstrated, b y meeting min imum flight

- hour requirements and the DJIPhantom 3 UAS training and currency

requireme nts, that the PI C is able to safel y operate the DJ I Phantom 3 UAS in a manner consistent with this exemption, including evasive a nd emergency
maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures. Specifically

, the PI C must have accumulated and logged, in a manner consistent with 14 C.F .R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operat ions under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 1 1062, 1 11 38, and 1 11 53, prior documented flight experience that wa s obtained in compliance with applicable regulations will ensure an equivalent level of safet y during Christopher Mergenthaler ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 1 1062, the F AA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and log ged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 1 1062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FA A considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may

be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 d ay s(for currency purposes). The F

AA finds that at a minimum, the flighthour requirements in Exemption No. 1 1062 are appropriate to practice and build proficiency in the skills necessary to safel y conduct the petitioner ’s proposed operations. The F AA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. T raining, proficiency

, and experience

- building flights can also be conducted under the grant of exemption to accomplis h the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA

with appropriate distances in acc ordance with 14 C.F .R 91.1 19. Exemption No. 1 11 38 at page 15. Accordingly

, Christopher Mergenthaler will ensure safe operati ons by not allowing any PIC to operate the DJIPhantom 3 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJI Phantom 3 UAS in a manner consistent with th e exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

**CONCLUSION** Christopher Mergenthaler seeks an exemption pursuant to 14 C.F .R. § 1 1.61 and Section 333 of the F

AA Modernization and Reform Act of 2012 (F MRA), which will permit safe operation of the DJ I Phantom 3 UAS commerci ally , without an airworthiness certificate, for the limited purpose of conducting aerial vide o and p hotography over certain areas of the United States. By granting this Petition, the F AA A dmini strator will be fulfilling the Congressional mandate of the F AA Modernization and Reform Act of 2012, while also advancing the interests of the public, b y allowing Christopher Mergenthaler to safely , ef ficiently , and economically

operate the DJIPhantom 3 UAS commerciall y within the NAS. Therefore , in accordance with the Federal Av iation Regulations and the F AA Modernization and Reform Act of 2012, Section 333, Chri stopher Mergenthaler respectfull y requests that the Administrator grant this Petition for an exempti on from the requirements of 14 C.F .R Sections 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91. 405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b), and permit Delta Aerial Imaging to operate the DJ I P hantom 3 UAS commerciall y for the purpose of conductin g aerial video and photograph y over certain areas of the United States. Dated: June 30 , 2015 Submitted by Christopher Mergenthaler**APPENDIX**

**– A**  DJIPHANT OM 3 TECHNI CAL SPECIFICA

TI ONS Christopher Mergenthaler only utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a prede termined and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices)

1.1 DJIPhantom 3 1.2 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 6000AH LiPo Battery

1.1.1.2 W eight (Battery

& Propellers Included)

– 2lbs 1 1.810oz (1242g) 1.1.1.3 Hover Accuracy

(Ready to Fl y)

– Ve rtical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Ve locit y - 200/s 1.1.1.5 Max Ti lt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOTRECOMMENDED) 1.1.2 Gimbal 1.1.2.1 W orking Current

– Static: 750mA; Dy namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 1.1.2.3 Controllable Range

– Pitch:

- 90

- 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90/s 1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32F

- 104F (0C

- 40C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Ef fective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD V

ideo Recording

– 10 80p30 & 720p 4.1.3.6 Recording Field of V iew

- 11 0/85

**APPENDIX**

**- B**  **D JI P**  **H ANT**  **O M 3**  **U S**  **E R**  **MA N**  **UA L** 
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