### August 17, 2015

Exemption No. 12480 Regulatory Docket No. FAA

− 2015

− 0998

Mr. Charles Ayers 6680 Mossy Glen Dr ive Fort Myers, FL 33908

Dear Mr. Ayers :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By one letter posted to the public docket on April 14 and one da ted June 21, 2015 , you petitioned the Federal Aviation Administration (FAA) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography, inspections and surveys

.
See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

.
The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal R egister because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+

.

### 2

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA fi nds that relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decis ion

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater propo rtions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you pre sent; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Charles Ayers is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417 (a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Conditions and Limitations

In this grant of exemption, Mr. Charles Ayers is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision+ when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this e xemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no mor e than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than

co rrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and con duct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Adm inistrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.

### 4

Otherwise, the o perator must follow the procedures as outlined in its operating documents. The operator 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 Administrat or or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the b asis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating docum ents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- fl ight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be

### 5

operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 1 4 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight ope rations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must b e conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facili ty Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet hori zontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must ab ort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and t o operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial

num ber, registered in accordance with 14 CFR part 47, and have identification

### 6

(N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcem ent official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure tha t nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipa ting persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the prop erty owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vert ical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions containe d on the NTSB Web site: www.ntsb.gov

.
If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

### 7

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities t o the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times fo r all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted a nd the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

U nless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded.

Sincerely, / s/ John S. Duncan Director, Flight Standards Service

Enclosures

### My	name	is	Charles	Ayers	and	I	would	like	to	petition	for	an	exemption	under

Section	333.	I	would	like	to	use	a	multi

- roter	quadcopter	aerial	drone	(DJI	Phantom Vision+)	for	commercial	purposes.	The	quadcopter is	fitted	with	a	camera	that	will capture	imag es	for	real

- estate, marketing and	roof	inspections .	It	will	be	flown within	FAA	guidelines	for	use. The	P hantom	2	Vision	+	quadcopter uses	wireless	communication	with	the controller	transmitter	operating	in	the	5.8Ghz	frequency	band.	It	is	compliant	with
CE (300m) and	FCC (500m) regulations	and	effective	ranges.	If	it	flies	beyond	the effective	range	it	will	enter	and	failsafe	mode	and return	home. Max	height	and	radius	have	been	set	in	the	unit’s	software	as	well	as	no

- fly	zones and	restricted

- altitude	areas.	The	software	alerts	the	operator	when	near	these areas	and	issues	a	warning	when	flying	near	the	zone.	If	it	enters	a	no

- fly	zon e	it automatically	lands.	If	trying	to	take

- off	in	a	prohibited	area	the	motors	will	not

start. The	quadcopter	will	be	flown	in	residential	areas	and	on	personal	property	as permitted	by	the	land	or	home	owner.	Safety	procedures	will	be	in	effect	includin g	a maximum	height	of	200	feet	for	flight and	a	maximum	speed	of	under	10m/s .	In addition,	propeller	guards	will	be	used	when	flying	in	proximity	to	people. The	unit will	be	in	direct	line	of	sight	of	the	operator	at	all	times.	It	will	also	be	flown	in	win ds under	15mph	to	minimize	risk	of	crashing.
Pre

- flight	safety	check	includes	examining	battery,	propellers,	calibrating	the compass	and	the	unit’s	shell	for	damage	and	that	the	self

- tightening	propellers	are secured.	The	quadcopter	will	not	be	flown	in	in clement	weather	including	heavy wind	and	rain.	Obstacles	such	as	trees,	powerlines	and buildings	will	also	be avoided.	Regular	maintenance	will	be	performed	as	required	for	the	motors	and internal	circuitry.	Propellers	will	be	changed	for	new	ones	if	chipp ed	or	damaged	in

any	way. Screws	on	the	unit’s	shell	will	be	inspected	frequently	for	signs	of loosening. The	weight	of	the	craft	is	1160g	which	is	well	below	the	maximum	weighted payload	of	1350g.	Max	speed	is	15m/s. My	proposed	speed	will	be	much	lower than this	as	I’m	only	concerned	with	capturing	images	of	homes	and	property. The operating	frequency	of	the	controller’s	wireless	range	extender	is	2412MHz

2462MHz	and	the	open	area	communication	distance	is	300m. I,	Charles	Ayers,	will	be	the	only	operat or	using	the	quadcopter	under	this exemption and	am	directly	responsible	for	the	proposed	operation

. I	have	become completely	versed	in	operating	this	device	from	several	months	of	personal	use.June 21, 2015

Char l es Ayers 6680 Mossy Glen Dr. Fort Myers, FL 33908 Cell 407-416-6781 Email: cayers13@gmail.com

U.S. Department of Transportation Docket Management System
1200 New Jersey Ave., SE Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012 Attachments: 1) Phantom 2 Vision+ User Manual V1.04 2) Phantom 2 Vision P lus Quick Start Guide 3) Phantom 2 Vision Pilot Train ing Guide 4) Phantom 2 Vision Release Notes

References: 1) FAA E xemption No

. 11138, R egulatory Docket No. FAA20140481 in the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYI NG CAM INC

Dear FAA,
In accordance with the FAA's 

### Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012 , I, C h a rl es Ayers, reque st exemption from the following sections of Ti tle 14, Code of Federal Regulations§§



### 61.113(a). 61.113(b). 91.119(c). 91.121. 91.151(a). 91.40S(a). 91

. 407(a)(1). 91.409 (a)(1). 91.409(a)(2). 91.417(a) & 

### (b).

In order to operate sma ll unmann ed aircraft systems (UAS) commercially i n airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aeria l photography, structural in spections of bridges, pipelines, we ll and ce ll towers, rea l estate marketing and surveys and other flight operat i ons that could

### 91.405(a). 91.407(a)(1). 91.409 (a)(1) & 

### (2). 91.417(a) & 

### (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, Charles Ayers, propose to inspect and ensure that the UAS is in a conditio n for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the

r equirements for maintenance, inspection, and recordkeeping, were sufficient to

ensure that safety wou l d not be adversely affected

.



### The UAS The DJI Phantom 2 vis ion plus is a highly successful consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of l ess than 44 ounces (1242g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electr i c motors with a distance between motors of less than 14 inches (350mm) It utilizes an internal inertial measuring unit (IM U ) with int egrated barometric sensor augmented with globa l positioning system (GPS) to mainta in its geospatial orientation and position. 

### It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery l eve l, GPS signal strength, altitude (AGL), distance from PIC,

camera imagery, and control camera angle. 

### It has fail safe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life lim its flight times to approximately 25 minutes. The o nboard flight controller will

warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 10 minutes. More information is available in attachment 

### 1.

Risk mitigation I, Charles Ayers, have reviewed FAA exemptions reference's 13 

### Conditions and Limitations section and believe that the procedures specified therein are reasonable and will be utilized in orde r to manage and mitigate risk and ensure public safety.

A preflight checklist will be developed and employed to ensure that the UAS's airworthiness will be verified before laun ch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components.I

, Charl es Aye r s, state th at op e r at i o n w ill not occ ur w ithin 5 m i l es of a n airport o r a n y unauthor i ze d space.



### "The UA may not operate in Class B, C, or D airspace without written approval from the FAA

. The UA may not operate within 5 nautical miles of the geographic cente r o f a non towe r ed airport as denoted on a current FAA pub li shed aeronautical chart unless a letter of agreement with that airport ' s man a gement is obtained, and the ope r ation is conducted in accordance with a NOTAM as r e quired by the operator ' s COA. The letter of agre e ment with the airport management must be made ava il able to the Administrator upon request. "

Publ i c i nterest Use of the UAS in lieu of a ma n ned aircraft would enhance safety and reduce the

env i ro n mental impact as compared to similar operations conducted with manned ai r c r aft of greater propo rti o n s, ca r rying a crew and fl am ma bl e fuel.

In rega r ds to performing i nspections of bridges, towers, and natura l gas pipelines the UAS will mi n imize the r isk to pe r sons attempting to climb these structu r es and photograph prob l em areas. It will prov i de a way for companies to have their eng i neers review p h otographs and provide add i tional safety to the general public in regards to towers failing o r natural gas p i pel in es having structural issues. Many of t h e natura l gas pipelines i n our area travel in areas that are hard to reach by ve hi cle o r foot and if an a r ea is suspected of having pro bl e m s the U AS can reach it t o make an assess m e n t eas i er and safer.

I

, Cha r les Ayers, wi ll also m ake the UAS and myself available to l ocal

vo lu nteer organizations (for no charge) such as fire departments, local law

e n forcement, etc., to perfo r m search and rescue operations, or other similar events as d irected by authorities

.

I n a ddition the use of the U AS in order to facilitate commerce cou l d lead to

eco n o m ic growt h

. Operat i o ns for t h is petitio n w ill e n a bl e serv i ce for p r operty

ow n ers or their designees seek in g a n enhanced pe r spect i ve for cha r acte r is t ics,

ame n ities, and benefits of t h eir desired photog r ap hi c subjects that ca n not be disp l ayed th r ough ground l evel photography. Aerial p h otography is a valuab l emarketing tool that can lead to inc r eased commerce and enhance my persona l photography. A v i sual observer will be utilized at all times that the UAS is performing duties for compensation

.

My own research shows an u pward demand for these services t h at cu r rently exists in the real estate market, surveying and other markets are just beginning to realize the need for such services

.

Flight data including UAS flight time, Control Unit operation time, in c i dent, and details wi ll be recorded for each flight and made avai l ab l e to the FAA at any time needed. Any deviations from normal operations will also be r ecorded and made available
to FAA

.

Conclusion I, Charles Ayers, am requesting this exemption for the purposes of ae ri al photog r aphy of real estate, bridge in spections, land surveying, tower inspections, and other flight ope ra t i ons

. The reason for such a ge n eral and broad based request is that I, Charles Ayers, wish to utilize a bus i ness strategy in order to capitalize on opportunities as they may arise in the future without the long t u rnaround time associated with additional exempt i ons. My business model is based on the idea of offering small UAS services to individuals o r compan i es who w ish to employ these services as a safe, effective, and l egal option to enhance their business or prevent st r uctu r a l disasters that may influence the general public or individuals.be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by, Charles Ayers, are drawn from references 13.



### 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms "congested areas" and "densely populated". I, Charles Ayers, request waiver for this condition to allow reasonable and responsible operations with safety as my main concern in

areas of subdivisions and neighborhoods if required.



### 91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.



### 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate

a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable.