19 Country Fair Lane

St. Louis, Missouri, 63141

United States of America

Phone: (314) 484

- 6360

July 20, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

PAL and Associates LLC ( PAL ), h ereby applies for an exemption seeking relief from the requirements of

title 14 of the code of federal regulations sections 61.113(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 operation of DJI Phantom 2

Vision +, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ Unmanned Aircraft

Systems (UAS) pursuant to section 333 of the Federal Aviation Administration Modernization and Reform

Act of 2012 (public law 11295).

PAL and Associates L LC respectfully requests a waiver on the 45 day comment period, as this application is

identical in description to other Section 333 Exemptions that have already been granted.

This exemption would permit commercial operations by PAL and Associates LLC to u se the D JI

Phantom 2 Vision+

, DJI Phantom 3 Professional , DJI Inspire 1, and the DJI Spreading Wings S1000+ to

conduct aerial photography

, videography, agricultural assessment of crops and data collection, training and

education, inspections and assessmen ts of structures

.

The name and address of the applicant are:

PAL and Associates LLC

Damon Lercel, President

19 Country Fair Lane

St. Louis, MO 63141

Phone: (314) 484

- 6360

Email: damon@palandassociates.com

Respectfully,

Damon Lercel, Ph.D.TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

................................ ................................ .......................... 3

SUMMARY

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

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

BACKGROUND

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

BASIS FOR PETITION

................................ ................................ ................................ ................ 5

CONCLUSION

................................ ................................ ................................ ........................... 27

Page 2 of 33

### GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regu lations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Comman d

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

Page 3 of 33

### SUMMARY

PAL and Associates LL C seeks exemption from the requirements of 14 C.F.R 61.113(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 System pursuant to Section 333 of the FAA

Modernization an d Reform Act of 2012 (FMRA).

This exemption will permit PAL and Associates LLC to operate an Unmanned Aircraft System

(UAS) for the commercial purpose of conducting aerial photography, videography, agricultural

assessment of crops and data collection, tr aining and education, inspections and assessments of

structures for civil operations within the United States of America.



### INTRODUCTION AND INTERESTS OF THE PETITIONER

PAL and Associates LLC (PAL) is a recognized international leader in aviation safety rese arch

, training, education, and services, with headquarters in St. Louis, Missouri. Combined, the PAL

team has over 80 years of aviation experience, and holds a number of FAA and other

professional certificates, which includes pilot certificates (private, instrument, commercial, and

airline transport pilot)

, airframe and powerplant technician certificates, Federal Radio

Communications Commission’s General Radiotelephone Operators License s, and numerous

unmanned aircraft system training certificates.



### BACK GROUND

PAL and Associates LLC seek an exemption to operate DJI UAS systems for compensation or

hire within the NAS. The DJI Phantom 2 Vision +, DJI Phantom 3 Professional, DJI Inspire 1,

and DJI Spreading Wings S1000+ are vertical takeoff and landing (VTOL ) Unmanned Aircraft

(UA). These UAS’s use a Ground Control Station (GCS), displayed on an electronic tablet or

smartphone. The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2

pounds 11 ounces, a length of 16 inches width of 16 inches, h eight of 8 inches, and a maximum

speed of approximately 29 knots. The DJI Phantom 3 Professional has a maximum gross weight

of approximately 2 pounds 1 3 ounces, a length of 16 inches width of 16 inches, height of 8

inches, and a maximum speed of approximat ely 31 knots. The DJI Inspire 1 has a maximum

gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8

inches, and a maximum speed of approximately 42 knots. The DJI Spreading Wings S 1000 + has

a maximum gross weigh t of 24 pounds 4 ounces, is approximately 42 inches in diameter, and has

a maximum speed of approximately 30 knots. The DJI Phantom 2 Vision+, DJI Phantom 3

Professional , and DJI Inspire 1 are equipped with four main rotors , which are driven by Lithium

Pol ymer battery powered electric motors. The DJI Spreading Wings S1000+ is equipped with

eight main rotors, which are driven by Lithium Polymer battery powered electric motors.

Page 4 of 33The DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S 10 00 UAS that will be operated by PAL and Associates LLC 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, Identification and Registration

Marking.



### BASIS FOR PETITION

Petitioner, PAL and Associates LLC , pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the

Administrator to commercially operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1 , and DJI Spreading Wings S 10 00 UAS's in the National Airspace System (NAS),

and fo r an exemption from the requirements of 14 C.F.R §§ 61.113(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 th e

unmanned aircraft and its operation, PAL and Associates LLC operation of DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00 UAS's

meets the conditions of FMRA Section 333 and therefore, will not require an air worthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, PAL and Associates LLC requests relief from Sections 91.405(a), 91.407(a)(1),

9 1.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

main tenance that only apply to aircraft with an airworthiness certificate.

PAL and Associates LLC submit that the requested relief is proper since an equivalent level of

safety will be ensured. PAL and Associates LLC will use experienced personnel or technicia ns to

perform maintenance, alterations, or preventive maintenance on the UAS's using the methods,

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance and

Flight Log s , and DJI Phantom 2 Vision+ , DJI Phantom 3 Professio nal, DJI Inspire 1

, and DJI

Spreading Wings S 10 00 Instruction Manual). Furthermore, PAL and Associates LLC will

document and maintain all maintenance records for the DJI Phantom 2 Vision+, DJI Phantom 3

Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00 UAS's.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by PAL and Associates LLC to the extent

necessary to allow a Pilot in Command (PIC) holding a priv ate 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 safely operate the DJI Phantom 2

Vision+, DJI Phantom 3 Profession al, DJI Inspire 1, and DJI Spreading Wings S 10 00 UAS's in a

Page 5 of 33manner consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.

PAL and Associates LLC seeks r elief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S 10 00 UAS's do not require an airworthiness certificate in accordance with 14

C.F.R. p a rt 21, Subpart H. As such, PAL and Associates LLC submits that they will ensure that

the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S 10 00 UAS's are in an airworthy condition, prior to every flight, by determin ing that the

UAS's are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI

Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, DJI Spreading Wings S 10 00

Instruction Manual), and that the aircraft are in a condition for safe flight.

PAL and Associates LLC also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1, and DJI Spreading Wings S 10 00 UAs will not have a typical barometric altimeter

onboard. However, altitude information of the DJI Phantom 2 Vision+, DJI Phantom 3

Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00 UA S will be provided to the PIC

via Global Positioning System (GPS) equipment and ra dio communications telemetry data link,

which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with PAL and Associates LLC ’s operation of the DJI Phantom 2 Vision+

, DJI Phantom 3 Professional, D JI Inspire 1

, and DJI Spreading Wings S 10 00 UAS's within visual

line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section

91.121.

Additionally, PAL and Associates LLC seek an exemption from the requirements of Section

91. 151(b), entitled Fuel requirements for flight in VFR conditions. PAL and Associates LLC

submits that safety will not be affected by operation of the DJI Phantom Vision+ , DJI Phantom 3

Professional, DJI Inspire 1

, and DJI Spreading Wings S 10 00 UAS’s during daylight hours in

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fly for a total duration of approximately 14.5 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. 11.81, PAL and Associates LLC provide the following information

in support of its petition for exemption:

A. Name and Address of the Petitioner.

The name and address of the Petitioner and poin t of contact is:

PAL and Associates LLC

19 Country Fair Lane

St. Louis, MO 63141

Page 6 of 33Attention Damon Lercel, President

Phone: (314) 484

- 6360

Email: damon@palandassociates.com

B. The Specific Sections of 14 C.F.R. From Which PAL and Associates LLC Seeks

Exemption.

PAL and Associates LLC Seeks Exemption from the Requirements of Section 61.113(a)

and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) pres cribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC)

of an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation or hire, act a s PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if

—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or pro perty for compensation or hire.

2. P AL and Associates LLC Seeks Exemption From The Requirements 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 airworthy condition.

3. PAL and Associates LLC Seeks Exemption From The Requirements 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 altitude or flight level

of that aircraft, as the case may be, by reference to an altimeter that is set, when

operating

--

(1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) 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) the case of an aircraft not equipped with a radio, the elevation of the

departur e airport or an appropriate altimeter setting available before

departure.

Page 7 of 334. PAL and Associates LLC Seeks Exemption From The Requirements Of

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions

, subsection (b), states th e following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to

the first point of intended landing and, assuming normal cruising speed, to fly afte r

that for at least 20 minutes.

PAL and Associates LLC Seeks Exemption From The Requirement 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 tha t aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this section,

have discrepancies repaired as prescribed in part 43 of this chapter[.]

PAL and Associates LLC Seeks E xemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration

, subsection (a)(1), states the following:

(a) N o person may operate any aircraft that has undergone m aintenance,

preventive maintenance, rebuilding, or alteration unless

--

(1) It has been approved for return to service by a person authorized under part 43.7

of this chapter [ .]

PAL and Associates LLC Seeks Exemption from the Requirements 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 by a person authorized by part 43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with

part 21 of this chapter.

PAL and Associates LLC Seeks Exemption from the Requirements of Sections

91.417(a) and 91.417(b).

Page 8 of 33Section 91.417, entitled Maintenance re cords

, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 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 o f 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 applia nce of an aircraft. The records must

include

-- (i) 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 to 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 appliance.

(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 by the inspec tion program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or safety

directive number and revision date

. If the AD or safety directive involves

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major

alteration to the airframe and currently installed engines, rotors, pr opellers,

and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) 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 year after the work

is performed.

(2) 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.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

thi s chapter shall be retained until the defects are repaired and the aircraft is

Page 9 of 33approved for return to service.

C. The Extent Of Relief PAL and Associates LLC Seeks And The Reason PAL and

Associates LLC Seeks The Relief.

1. Extent of Relief PAL and Associates LL C Seeks And the Reason PAL and

Associates LLC Seeks Relief from Section 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command

, is requested to the extent necessary to allow a PIC holdi ng a private pilot or higher

level certificate, as well as a current and valid airman medical certificate, and who has met

certain flight hour and currency requirements, to conduct the proposed UAS flight operations for

compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if: (1) The flight is only incidental to that business or employment; and

(2) the aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, PAL and Associates LLC submits that an equivalent level of

safety will be maintained because no PIC will be allowed to oper ate the DJI Phantom 2 Vision+

UAS, DJI Phantom 3 Professional UAS

, DJI Inspire 1 UAS, or DJI Spreading Wings S 10 00

UAS unless that PIC has met certain flight hour and currency requirements, demonstrating that

the PIC is able to safely operate the DJI Phanto m 2 Vision+, DJI Phantom 3 Professiona l, DJI

Inspire 1, or DJI Spreading Wings S 10 00 UAS in a manner consistent with the operations

specifications as described in this exemption, including evasive and emergency maneuvers, as

well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, PAL and Associates LLC submits that all flights of the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00 UAS's, conducted by the

PIC pursuant to the grant of this Petition: (1) will be incidental to PAL and Associates LLC's

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief PAL and Associates LLC Seeks And The Reason PAL and

Associates LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft air worthiness

, is requested to the extent

required to allow PAL and Associates LLC to determine that the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00 UAS's are in airworthy

condition prior to every flight by ensuring that the UAS is in compliance with the operating

documents (i.e., the PAL and Associates LLC Flight Operations Log, Monthly Maintenance Log,

DJI Phantom 2 Vision+ , DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings

Page 10 of 33S 10 00 Instructio n Manual).

PAL and Associates LLC seeks the requested relief because the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00 UAS's do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21

, Subpart H. Therefore, PAL and

Associates LLC will ensure that the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1

, and DJI Spreading Wings S 10 00 UAS's are in airworthy condition based upon its

compliance with the operating documents (i.e

., Monthly Maintenance Log, and DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00, Instruction

Manual) prior to every flight, and further, determine that the aircraft are in condition for safe

flight, as stated in the conditions and limitations below.

3. Extent Of Relief PAL and Associates LLC Seeks And The Reason PAL and

Associates LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operati ons

of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S 10 00 UAS's, which utilize a barometric pressure sensor, GPS equipment, and a radio

communications telemetry data link to downlink altitude information fro m the UA to the PIC at

the ground control station (GCS). Since the FAA requires that any altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), PAL and Associates LLC seeks the requested re lief because the DJI Phantom 2 Vision+,

DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00 UA’s altimeter may

be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude,

before each flight.

Con sidering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the DJI

Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S10 00

UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically

ensures that a ground level pressure setting w ill be established prior to each flight, and provides

the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief PAL and Associates LLC Seeks And The Reason PAL and

Associates LLC Seeks Relief From Section 91.151(b).

R elief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision+,

DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S 10 0 0 UAs during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total

duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising

Page 11 of 33speed, to fly after that for at least 4.5 minu tes. PAL and Associates LLC seeks the requested

relief because without an exemption from Section 91.151(b), the flight time duration of the

battery powered DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S1000+ UAs will severely constrain the practicality of any aerial video or still

photo flight operations that PAL and Associates LLC proposes to conduct pursuant to this

Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's, the DJI

Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

operating documents, and PAL and Associates LLC proposed operatin g limitations, ensure that

PAL and Associates LLC will safely operate the battery powered DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAs during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough

battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent of Relief PAL and Associat es LLC Seeks And the Reason PAL and

Associates LLC Seeks Relief from 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 apply to

aircraft wit h an airworthiness certificate, PAL and Associates LLC requests relief from these

Sections because the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S 10 00 UAS's do not require airworthiness certificates. As set f orth more fully

below, the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S 10 00 UAS's meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, PAL and Associates LLC will use FAA certified Airframe

and Powerplant technicians to perform maintenance, alterations, or preventive maintenance on

the UAS's using the methods, techniques, and practices prescribed in the UAS operating

documents (i.e., the PAL and Associates LLC Flight Operation Logs, Monthly Maintenance

Log s

, and the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S 10 00, Instruction Manual). Furthermore, PAL and Associates LLC will

document and maintain all maintenance r ecords for the DJI Phantom 2 Vision+, DJI Phantom 3

Professional, DJI Inspire 1, and DJI Spreading Wings S 10 00, UAS's.

D. The Reasons Why Granting PAL and Associates LLC Request Would Be In the

Public Interest; That Is, How It Would Benefit The Public As A Wh ole.

Granting the present Petition will further the public interest by allowing PAL and Associates

LLC to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, and landscape over certain areas of the United States.

Page 12 of 33Additionally, use of the DJI Phantom 2 Vision+, DJI Phantom Professional, DJI Inspire 1, and

DJI Spreading Wings S1000+

, UAS's will decrease congestion of the NAS, reduce pollution, and

provide significant benefits to the economy. Notably, the benefits of PAL and Associates LLC’s

proposed operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1,

and DJI Spreading Wings S1000+

, UAS's will be realized without implicating any privacy issues.

1. The Public Will Benefit Fro m Decreased Congestion Of The NAS.

The DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S1000+ , UAs are battery powered and serve as a safe, efficient, and economical

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, or DJI Spreading Wings

S1000+

, UAS wou ld reduce the amount of manned aircraft in the NAS, reduce noise and air

pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

ar ound airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAs do

not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting

aerial video and photography 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 From The S afety And Efficiency Of The DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings

S1000+ UAS's.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1, and DJI Spreading Wings S1000+ UAS's, instead of manned aircraft, will greatly

benefit the public by drastically reducing the levels of air and noise pollution generated during

traditional aerial video and still photography flight operations. By using battery power and

elec tric motors, the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S1000+ UAS's produce no air pollution, and is the most viable environmentally

conscious alternative to the cabin class, six cylinder internal combust ion engine aircraft that are

typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons

per hour of leaded aviation fuel. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1, and DJI Spreading Wings S100 0+ UAs, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric

motors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision+, DJI Phantom 3 P rofessional, DJI Inspire 1, and DJI

Spreading Wings S1000+ UAS's to perform aerial acquisitions, the substantial risk to life and

Page 13 of 33property in the air and on the ground, which is usually associated with traditional manned aircraft

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of

flight crew members located onboard the aircraft, the DJI Phantom 2 Vision+, DJI Phantom 3

Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAs are a fraction of the weight

an d size and do not utilize any fuel, which is typical of manned aircraft conducting similar

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a

length of 34 feet, and a fuel capacity of 180 gallons). The DJI UAs have less physical potential

for collateral damage to life and property on the ground, and in the air, compared to the traditional

manned aircraft.

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJ I Inspire 1, and DJI Spreading Wings

S1000+ UAS's Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's are also an economical alternative to

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom

2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's

will allow United States based companies, like PAL and Associate s LLC, to remain competitive

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded

aviation fuels, U.S. owned and operated com panies must adopt new and alternative technology in

order to remain competitive. Operating the battery powered DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's is one such

technology that not only allows companies greater operational flexibility compared to manned

aircraft, but provides such flexibility without the high operational cost of a traditional manned

aircraft.

By operating the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, an d DJI

Spreading Wings S1000+ UAS's, companies such as PAL and Associates LLC, can remain

competitive and profitable, and therefore, provide greater job stability to employees and

contractors, which will ultimately contribute to growth of the U.S. economy. I mproved financial

performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's, provides a

stable workforce that increases consumer spending

, improves tax revenues

, and allows

companies to invest in research and development in order to remain competitive both in the

United States and abroad.

4. T here Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

PAL and Associates LLC’s proposed operation of the DJI Phantom 2 Vision+, DJI Phantom 3

Page 14 of 33Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's will not implicate any

privacy issues. Specifically, the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1, and DJI Spreading Wings S1000+ UAS's will be operated only in compliance with

operating documents (i.e. Monthly Maintenance Log, and the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

, Instruction Manual)

which requires property owner involvement as well as local law enforcement notification, and in

accordance with the Federal Aviation Regulations, including the minimum altitude requirements

of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or

How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which PAL and Associates LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+, DJI Phanto m 3 Professional, DJI

Inspire 1, and DJI Spreading Wings S1000+ UAs Meet The Conditions Of

The FAA 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, PAL and Associates LLC’s operation of the DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's

meet the regulation and conditions of FMRA Section 333, and will not require an airw orthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the N AS or the

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

(a) In General. n otwithstanding any other requirement of this subtitle, and not later

than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may operate

safely in the national airspace system before completion of the plan and

rulemaking required by section 332 of this Act or the guidance required by

s ection 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems. In making the determination under

subsection (a), the Secretary shall determine, at a minimum :

(1) which types of unmanned aircraft systems, if any, as a result of their size,

weight, speed, ope rational capability, proximity to airports and populated

areas, and operation within visual line of sight do not create a hazard to

users of the national airspace system or the public or pose a threat to

national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United

Page 15 of 33States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

(c) Requ irements for Safe Operation. If the Secretary determines under this section

that certain unmanned aircraft systems may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe

operation of such aircraft system s in the national airspace system.

In seeking this exemption, PAL and Associates LLC submits that the DJI Phantom 2 Vision+,

DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's can operate

safely in the NAS pursuant to FMRA Sect ion 333, as demonstrated by: (a) the characteristics of

the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S1000+ UAS's; (b) the pilot certification requirement ; and (c) the specific operating

limitations.

a) The Spec ifications Of The DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's Demonstrate Its Safe

Characteristics.

The DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S100 0+ UAS's do not create a hazard to users of the NAS or the public, or otherwise pose

a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 2 Vision+, DJI Phantom 3

Professi onal, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's.

The technical specifications of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1, and DJI Spreading Wings S1000+ UAS's are set forth by the DJI Phantom 2 Vision+,

DJI Phantom 3 Pr ofessional, DJI Inspire 1, and DJI Spreading Wings S1000+ Specifications and

Data Sheet, attached hereto as Exhibit A, B

, C , and D

.

ii. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1,

and DJI Spreading Wings S1000+ UAS's Autonomous Flight A nd

Navigation Modes Enable The UAS's To Remain Within A Defined

Operational Area.

The DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S1000+ UAS's may be operated in both manual and fully autonomous flight modes. A

complete description of the flight and navigational modes of the DJI Phantom 2 Vision+, DJI

Inspire 1+, and DJI Spreading Wings S1000+

, UAS's is provided at pages 25

- 35 of the DJI

Phantom 2 Vision+ , pages 11

- 14 and 39

- 47 of the DJI Phantom 3 Professional, pages 12

- 16 and

45

- 50 of the DJI Inspire 1, and page 23

- 38 of the A2 Flight Control System (which is the control

system on the DJI Spreading Wings S1000+) User Manuals, attached hereto as Exhibit D, E

, F

,

and G

.

Page 16 of 33iii. The DJI Phantom 2 Vision+, DJI Inspire 1+, a nd DJI Spreading Wings

S1000+ , UAS's Are Designed For Automatic Return To Home Point Or

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1, and D JI Spreading Wings S1000+

, UAs will remain stationary, in flight, for 3 seconds

or more. If, after 3 seconds, the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire

1, and DJI Spreading Wings S1000+

, UAs do not reacquire control link data from the GCS, the

UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e.,

failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

iv. The DJI Phantom 2 Vision+, DJI Inspire 1+, and DJI Spreading Wing s

S1000+ , GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 Vision+, DJI

Inspire 1+, and DJI Spreading Wings S1000+

, GCS and flight control software is provided in the

DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings

S1000+ User Manual s

- attached hereto as Exhibits C, D, E , and F.

b) Flight Operations Of DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI

Inspire 1, and DJI Spreading Wings S1000+ UAS's Are Limited To The Line Of

Sight Of A Certificated Pilot in Command With A Safety Observer.

PAL and Associates LLC will only utilize certificated pilots who possess a current and valid

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

, UAS's. Additionally, a

safety observer will assist all pilots during flight time.

c) Flights Of DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1,

and DJI Sprea ding Wings S1000+ UAS's Will Be Conducted Pursuant To

Specific Operating Limitations.

In seeking this exemption, PAL and Associates LLC proposes to commercially operate DJI

Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Win gs

S1000+

, UAS's for the special purpose of conducting aerial video and photography over areas of

United States that do not pose any safety discrepancies to civilians, pursuant to the 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 UAS's weighing less than 55

pounds maximum gross weight: DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1, and DJI Spreading Wings S1000+

, Unmanned Aircraft Systems.

Proposed operations of any other aircraft will require a new petition or a petition to

amend this grant.

Page 17 of 332. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and ph otography.

3. The UAs may not be flown by any at an indicated airspeed exceeding 5 0 knots.

4. The UA 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

s pecial request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL.

5. The UAs 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 o ther than

corrective lenses, as specified on the PIC’s FAA issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC must be able to communicate verbally at all times. Electronic 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 SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with s eeing and

avoiding other air traffic 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 request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations

contained in the grant of exempt ion take precedence and must be followed. Otherwise,

the operator 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 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

determines that any update or revis ion would affect the basis upon which the FAA

granted the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions

arise regarding updates or revisions to th e operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for

safe flight. 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. The Ground

Control Station must be included in the preflight inspection. All maintenance and

Page 18 of 33alterations must be properly documented in the aircraft rec ords.

11. 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. The PIC who conducts the functional test flight mus t make an

entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

13. The operator must fol low the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating document s. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished, and

the signature of the authorized person returning the U AS to service.

15. Each UAS's 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 corrective action

taken against discrepancies discovered between inspections.

17. The PIC 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 unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to sa fely 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 from persons, vessels,

vehicles and structures. PIC qualification flight hour s must be logged in a manner

consistent with 14 C.F.R. 61.51(b). Flights for the purposes of training the operator’s

PICs are permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, proficiency, and

experience

- building flights, all persons not essential for flight operations are considered

non

- participants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 C.F.R. 91. 119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. All

operations must be conducted under visual meteorological conditions (VMC). If flight

at night is required, a special request will be made at the FAA office closest to propos ed

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted

Page 19 of 33on a current FAA published aeronautical chart unless a letter of agreement w ith that

airport’s management is obtained, and the operation is conducted in accordance with a

NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.

21. The UA 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 PIC. If

the UA loses communications or loses its GPS signal, it must return to a pre

determined location w ithin the planned operating area and land or be recovered in

accordance with the operating documents.

22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

23. The PIC 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.

24. The operator must obtain an Air Traffic Organ ization (ATO) issued Certificate of

Waiver 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

(NOTAM) 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 requirements

in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements.

25. All aircraft operated in accordance with the exemption 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.

26. Before conducti ng operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC)

or other appropriate government oversight agency requirements.

27. The documents required fewer than 14 C.F.R. 91. 9 and 91.203 must be available to the

PIC 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.

28. The UA must remain clear and yield t he right of way to all manned aviation operations

and activities at all times.

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

a. Flight operations must be conducted at least 500 feet from all

nonparticipating persons (persons other than the PIC, SO, operator trainees

Page 20 of 33or essential persons), vessels, vehicles, and structures unless: Barriers or

structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator m ust

ensure that 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

and/or;

b. The aircraft is operated n ear vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission 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, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do

not present an undue hazard to those persons per 91.119(a).

30. All operations shall be conducted over private or controlled access property with

permission from the land owner/co ntroller or authorized representative. Permission

from land owner/controller or authorized representative will be obtained for each

flight to be conducted.

31. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be

reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents

must be reported to the National Transportation Safety Board (NTSB) per

instructions contained on the NTSB Web si te: www.ntsb.gov

.

2. Reasons Why an Exemption from the Requirements of Section 61.113(a) and (b)

Would Not Adversely Affect Safety.

PAL and Associates LLC submits that the equivalent level of safety established by Secti on

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom

2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

, UAS's

unless that PIC has demonstrated, by meeting minimum flight hour a nd currency requirements,

that the PIC is able to safely operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1, or DJI Spreading Wings S1000+

, UAS in a manner consistent with the exemption,

including evasive and emergency maneuvers a nd maintaining appropriate distances from people,

vessels, vehicles and structures.

Considering PAL and Associates LLC’s proposed area of operations, and the operating

limitations set forth above ; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062 ); and the

airmanship skills necessary to safely operate the DJI Phantom 2 Vision+, DJI Phantom 3

Professional, DJI Inspire 1, or DJI Spreading Wings S1000+ UAS, PAL and Associates LLC

Page 21 of 33submits that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for PAL and Associates LLC’s specific

proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11158, 11159, 11160, 11161).

PAL and Associates LLC will not allow any PIC to operate the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, or DJI Spreading Wings S1000+ UAS u nless that PIC has

demonstrated, by meeting minimum flight hour requirements or the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, or DJI Spreading Wings S1000+

, UAS training and

currency requirements, that the PIC is able to safely oper ate the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, or DJI Spreading Wings S1000+

, UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, v ehicles and structures. Specifically, the PIC 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 m ake and model of UAS to be used for operations under the exemption). In

addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the

preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prio r documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of safety

during PAL and Associates LLC’s proposed operations. The Administrator has held that prior

documented flight experience tha t was obtained in compliance with applicable regulations would

ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for

the purpose of motion picture filming (or similar operations), the P IC must have

accumulated and logged, 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. 11062, the

PIC 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 FAA considers these minimum hour

requirements to be inclusive rathe r 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 landi ngs in the preceding

90 days (for currency purposes). The FAA finds that at a minimum, the flight hour

Page 22 of 33requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct the petitioner’s proposed

operations. The FAA also finds that prior documented flight experience that was

obtained in compliance with applicable regulations would satisfy this requirement.

Training, proficiency, and experience building flights can also be conducted under

the grant of exemption to accomplish the required flight time. During training,

proficiency, and experience building flights the PIC is required to operate the UA

with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No.

11138 at page 15.

Accord ingly, PAL and Associates LLC will ensure safe operations by not allowing any PIC to

operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, or DJI Spreading

Wings S1000+

, UAS unless that PIC has demonstrated, by meeting minimum fligh t hour and

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+, DJI

Inspire 1+, or DJI Spreading Wings S1000+

, UAS in a manner consistent with the exemption,

including evasive and emergency maneuvers and maintaining appr opriate distances from people,

vessels, vehicles and structures.

3. Reasons Why an Exemption from the Requirements of Section 91.7(a) Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because p rior to

every flight, PAL and Associates LLC will ensure that the DJI Phantom 2 Vision+, DJI Inspire

1+, and DJI Spreading Wings S1000+

, UAS is in an airworthy condition based upon the UAS’s

compliance with its operating documents and as stated in the cond itions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why an Exemption from the Requirements of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Sect ion 91.121 will be maintained because the

altitude information of the DJI Phantom 2 Vision+, DJI Inspire 1+, and DJI Spreading Wings

S1000+

, UAs will be provided to the PIC via GPS equipment and a radio communications

telemetry data link, which downlinks f rom the UA to the GCS for active monitoring of the

flight path and altitude. This altitude information, combined with PAL and Associates LLC

operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S 10 00, U As within visual line of sight, at or below 500 feet AGL, will

ensure a level of safety equivalent to Section 91.121. The altitude information will be

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude

Page 23 of 33initiati on point is automatically established by the UAS's at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

1064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

5. Reasons Why an Exemption from the Requirements of Section 91.151(b) Would

Not Adversely Affect Safety.

A grant of this exemption would e nsure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 Vision+,

DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

, UAS's; (2) the

limitatio ns on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, PAL and Associates LLC will ensure that it will safely operate the

battery powered DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S1000+ , UAs during daylight hours in VFR conditions, with enough battery

power to fly for a total duration of 13.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4. 5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

, UAS's; the limitations

on the proposed flight operations; and the location of the proposed operations, will ensure an

equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be

ensured as the DJI Phantom 2 Vision+, D JI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S1000+

, UAS's provide audible and visual warnings to the PIC at the GCS

when the UAs experiences low battery voltage, the first warning occurring at approximately 30%

remaining battery power

, and again at approximately 10% remaining battery power. At the

critically low battery level, the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire

1, and DJI Spreading Wings S1000+

, UAS's will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and operating limitations of the

UAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, to those presen ted herein (e.g. Exemption Nos.

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080).

Page 24 of 336. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversel y

Affect Safety.

In seeking this exemption, PAL and Associates LLC submits that the equivalent level of safety

with regard to the regulatory maintenance and alteration requirements established by Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because PAL and

Associates LLC will use trained technicians to perform maintenance, alterations, or preventive

maintenance on the UAS's using the methods, techniques, and practices prescribed in the

operating documents (i.e., t he PAL and Associates Flight Operations Log, Monthly Maintenance

Log, and DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S1000+

, Instruction Manual). Furthermore, PAL and Associates LLC will document and

maintain all maintenance records for the DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's.

Since the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading

Wings S1000+

, UAS's will b e inspected as prescribed by the operating documents, PAL and

Associates LLC will maintain the equivalent level of safety established by Sections 91.405(a),

91.409(a)(1), and 91.409(a)(2).

Likewise, the exemption sought will not adversely affect safety be cause PAL and Associates

LLC will use trained technicians to perform maintenance, alterations or preventive maintenance

on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would m aintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+ UAS's

will be performed by trained technicians. Maintenance will be documented and maintained

utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA

concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish

that safety is not adversely affected when the technical characteristics and operating limitations

of the UAS are considered.

In consideration of PAL and Associates LLC’s proposed operating limitations, the operating

documents, and the technical aspects of the DJI Phantom 2 Vision+, DJI Phantom Professional,

DJI Inspire 1, and DJI Spreading Wings S1000+

, UAS's, PAL and Associates LLC submits that

safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a),

91.407(a)(1) and (a)( 2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted

relief specific to UAS in circumstances similar, in all material respects, to those presented herein

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153).

Page 25 of 337. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, PAL and Associates LLC requests that the FAA

prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

, UAS's, which contain

such safety standards that the Administrator fi nds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(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).

Such special cond itions will permit safe operation of the UAs for the limited purpose of

conducting aerial video and photography over certain areas of the United States for compensation

or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS wil l create

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification in

accordance with any requirements that must be establish ed for the safe operation of the UAS in

the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 21.16, for

operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S1000 +UAS's, since the airworthiness regulations of 14 C.F.R. Part 21 do not

contain adequate or appropriate safety standards, due to the novel or unusual design features of

the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not

contain adequate or appropriate safety standards for an aircraft, aircraft engine, or

propeller because of a novel or unusual design feature of the aircraft, aircraft

engine or propelle r, he prescribes special conditions and amendments thereto for

the product. The special conditions are issued in accordance with Part 11 of this

chapter and contain such safety standards for the aircraft, aircraft engine or

propeller as the FAA finds neces sary to establish a level of safety equivalent to

that established in the regulations.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe

special conditions for PAL and Associates LLC intended operation of the DJI Phantom 2

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spreading Wings S1000+

, UAS's,

which contain such safety standards that the Administrator finds necessary to establish a level of

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections

61.113(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).

Page 26 of 33A Summary That Can Be Published in the Federal Register, stating: The Rules from Which

PAL and Associa tes LLC Seeks Exemption:

PAL and Associates LLC seeks exemption from the requirements of 14 C.F.R Sections

61.113(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).

A Brief Description Of The Nature Of T he Exemption PAL and Associates LLC Seeks:

This exemption will permit PAL and Associates LLC to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

Any A dditional Information, Views, Or Arguments Available to Support PAL and

Associates LLC’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA)

Section 333, which directs the Secretary of Transportation to determine if certain UAS may

operate safely in the NAS. As such, PAL and Associates LLC’s request for exemption may be

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, PAL and Associates LLC will operate the DJI Phantom 2 Vision+,

DJI Phantom 3 Professional, DJI Inspire 1, and DJI Spre ading Wings S1000+

, UAS's safely in the

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to

national security.



### CONCLUSION

As set forth herein, PAL and Associates LLC seeks an exemption pursuant to 14 C.F.R. 11. 61

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit

safe operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S1000+ UAS's commercially, without an airworthiness certificate, for the

limited purpose of conducting aerial video and photography over certain areas of the United

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act o f 2012, while also advancing the interests

of the public, by allowing PAL and Associates LLC to safely, efficiently, and economically

operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and DJI

Spreading Wings S1000+ UAS's commerci ally within the NAS.

Page 27 of 33WHEREFORE

, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, PAL and Associates LLC respectfully

requests that the Administrator grant this Petition for an exemption fr om the requirements of 14

C.F.R Sections 61.113(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 PAL and Associates LLC to operate the DJI Phantom 2

Vision+, DJI Phantom 3 Professional, D JI Inspire 1, and DJI Spreading Wings S1000+ UAS's

commercially for the purpose of conducting aerial video and photography over certain areas of

the United States.

Respectfully submitted :

July 23, 2015

Damon Lercel , Ph.D.

President

PAL and Associa tes LLC

19 Country Fair Lane

St. Louis, MO 63141

Appendices :

A. DJI Phantom 2 Vision+ Specifications Data Sheet

B. DJI Phantom 3 Professional Specification Data Sheet

C. DJI Inspire 1 Specification Data Sheet

D. DJI Spreading Wings S1000 Specification Data Sheet

Page 28 of 3319 Country Fair Lane

St. Louis, Missouri, 63141

United States of America

Phone: (314) 484

- 6360

APP ENDIX A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

PAL and Associates LLC only utilize safe and reliable UAS's. DJI is an industry leader in small UAS

production. DJI UAS's are loaded with ground breaking software enabling the user to set parameters wh ich

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 predetermined and set distance. In addition, DJI

software provides real

- time alti tude and location information to the PIC via the linked monitor (smart

phone/tablet devices)

.

1. DJI Phantom 2 Vision+

1.1. Aircraft

1.1.1. Supported Battery

– DJI 5200mAH LiPo Battery

1.1.2. Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.3. Hover Accuracy (Ready t o Fly)

– Vertical: .8m; Horizontal: 2.5m

1.1.4. Max Yaw Angular Velocity

- 200 0 /s

1.1.5. Max Tilt Angel

- 35 0

1.1.6. Max Ascent Speed

– 6m/s

1.1.7. Max Descent Speed

– 2m/s

1.1.8. Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.2. Gimbal

1.2.1. Working Current

– Static: 750mA; Dynamic: 900mA

1.2.2. Control Accur acy

- ±0.03 0

1.2.3. Controllable Range

– Pitch:

- 90 0

- 0 0

1.2.4. Maximum Angular Speed

– Pitch: 90 0 /s

1.3. Camera

1.3.1. Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

1.3.2. Sensor Size

– 1/2.3”

1.3.3. Effective Pixels

– 14M

1.3.4. Resolution

– 4384x3288

1.3.5. HD Video Recording

– 1080p30 & 720p

1.3.6. Re cording Field of View

- 110 0 /85 0

1.4. Transmitter

1.4.1. Operating Frequency

– 5.728GHz

– 5.85GHz

1.4.2. Communication Distance (unobstructed)

– FCC Compliance: 800m

1.4.3. Receiver Sensitivity (1%PER)

- - 93dBm

1.4.4. Transmitter Power

– FCC Compliance: 100mW

1.4.5. Working Voltage

– 120mA@3.7V

1.5. Range Extender

1.5.1. Operating Frequency

– 2412

- 2462MHz

1.5.2. Communication Distance (unobstructed)

– 500

- 700m

1.5.3. Transmitter Power

– 20dBm

1.5.4. Power Consumption

– 2WAPPENDIX B

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

PAL and Associates LLC only utilize safe and reliable UAS's. DJI is an industry leader in small UAS

production. DJI UAS's are loaded with ground breaking software enabling the user to set parameters which

will not allow flight into controlled airspace. Paramet ers can also be set to limit flight to no higher than a

predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI

software provides real

- time altitude and location information to the PIC via the linked mon itor (smart

phone/tablet devices).

2. DJI Phantom 3 Professional

2.1. Aircraft

2.1.1. Weight (including battery and propellers) 1280 g

2.1.2. Diagonal size (including propellers) 590 mm

2.1.3. Battery Capacity: 4480 mAh, Voltage: 15.2 V

2.1.4. Battery Type: LiPo 4S, Net Weight: 365 g

2.1.5. Max Fl ight Time Approximately 23 minutes

2.1.6. Max Ascent Speed 5 m/s

2.1.7. Max Descent Speed 3 m/s

2.1.8. Hover Accuracy : Vertical: +/

- 0.1 m

, Horizont al: +/

- 1.5 m

2.1.9. Max Speed 16 m/s (ATTI mode, no wind)

2.1.10. Max Altitude Above Sea Level 6000 m

2.1.11. Operating Temperature

- 0°C to 40°C

2.2. Camer a

2.2.1. Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

2.2.2. Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

2.2.3. ISO Range 100

- 3200 (video) 100

- 1600 (photo)

2.2.4. Shutter Speed 8s

- 1/8000s

2.2.5. Image Max Size 4000 x 3000

2.2.6. Video Recording Modes: UHD: 4096x2160p 24/25, 3840x2160p 24/25/30, FHD:

1920x1080p 24/25/30/48/50/60, HD: 1280x 720p 24/25/30/48/50/60

2.2.7. Supported SD Card Types: Micro SD

2.2.8. Operating Temperature 0°C to 40°C

2.3. Gimbal

2.3.1. Controllable Range Pitch

- 90° to +30°

2.3.2. Stabilization 3

- axis (pitch, roll, yaw)

2.4. Transmitter

2.4.1. Operating Frequency 2.400 GHz

- 2.483 GHz

2.4.2. Max Distance 2000m (outdo ors and unobstructed)

2.4.3. Operating Temperature 0°C

- 40°C

2.4.4. Receiver Sensitivity (1%PER)

- 101 dBm ±2 dBm

2.4.5. Transmitter Power (EIRP): FCC: 20 dBm, CE: 16 dBm

2.4.6. Battery 6000 mAh LiPo 2S

2.4.7. Working Voltage 1.2 A @7.4 V

Page 30 of 33APPENDIX C

DJI Inspire 1+, TECHNICAL SPECIFICATIONS

PAL and Associates LLC only utilize safe and reliable UAS's. DJI is an industry leader in small UAS

production. DJI UAS's are loaded with ground breaking software enabling the user to set parameters which

will not allow flight into controlled airspace. Pa rameters can also be set to limit flight to no higher than a

predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI

software provides real

- time altitude and location information to the PIC via the linke d monitor (smart

phone/tablet devices)

3. DJI Inspire 1+,

3.1. Aircraft

3.1.1. Model

– T600

3.1.2. Weight (Battery Included)

– 6lbs 7.5291oz (2935g)

3.1.3. Hovering Accuracy (GPS Mode)

– Vertical: 0.5m ; Horizontal: 2.5m

3.1.4. Max Angular Velocity

– Pitch: 300 0 /s ; Yaw: 150 0 /s

3.1.5. Max Tilt Angle

- 35 0

3.1.6. Max Ascent Speed

– 5m/s

3.1.7. Max Descent Speed

– 4m/s

3.1.8. Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED)

3.1.9. Max Flight Altitude

– 4500m

3.1.10. Max Wind Resistance

– 10m/s

3.1.11. Max Flight Time

– Approximately 18 minutes

3.1.12. Motor Model

– DJI 3510

3.1.13. Propeller Model

– DJI 1345

3.1.14. Operating Temperature Range

– 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

3.1.15. Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

3.2. Gimbal

3.2.1. Model

– ZENMUSE X3

3.2.2. Output Power (with camera)

– Static: 9W ; In Motion: 11W

3.2.3. Operating Current

– Static: 750mA ; In Motion: 900mA

3.2.4. Angular Vibration Range

- ±0.03 0

3.2.5. Mounting

– Detachable

3.2.6. Controllable Range

– Pitch:

- 90 0 to +30 0 ; Pan: ±320 0

3.2.7. Mechanical Range

– Pitch:

- 125 0 to 45 0 ; Pan: ±330 0

3.2.8. Max Controllable Speed

– Pitch: 120 0 /s ; Pan: 180 0 /s

3.3. Camera

3.3.1. Name

– X3

3.3.2. Model

– FC350

3.3.3. Total Pixels

– 12.76M

3.3.4. Effective Pixels

– 12.4M

3.3.5. Image Max Size

– 4000x3000

3.3.6. ISO Range

– 100

- 3200

3.3.7. Field of View

- 94 0

3.3.8. CMOS

– Sony EXMOR 1/2.3”

3.3.9. HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30 ; FHD:

1920x1080p24/25/30/48/50/60 ; HD: 1280x720p24/25/30/48/50/60

3.3.10. Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

3.4. Transmitter

3.4.1. Name

– C1

3.4.2. Operating Frequency

– 5.728

- 5.850GHz ; 2.400

- 2.483GHz

3.4.3. Communicating Distance (unobstructed)

– 2000m

3.4.4. Output Power

– 9W

3.4.5. Operating Temperature Range

- 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

3.4.6. Battery

– 600mAh LiPo 2 S

Page 31 of 33APPENDIX D

DJI SPREADING WINGS S 10 00+ TECHNICAL SPECIFICATIONS

PAL and Associates LLC only utilize safe and reliable UAS's. DJI is an industry leader in small UAS

production. DJI UAS's are loaded with ground breaking software enabling the user to set pa rameters 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 predetermined and set distance. In addition, DJI

software provides real

- time altitude and location information to the PIC via the linked monitor (smart

phone/tablet devices)

4. DJI Spreading Wings S 10 00 +

4.1. Aircraft

4.1.1. Supported Battery

– LiPo (6S,10000mAh~20000mAh,15C(Min))

4.1.2. Weight (Battery & Propellers Included)

– 24 bs , 4 oz (1 1k g )

4.1.3. Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

4.1.4. Max Yaw Angular Velocity

- 200 0 /s

4.1.5. Max Tilt Angel

- 35 0

4.1.6. Max Ascent Speed

– 6m/s

4.1.7. Max Descent Speed

– 2m/s

4.1.8. Max Flight Speed

– 18m/s (NOT RECOMMENDED)

4.2. Gimbal

4.2.1. Working Current

– Static: 750mA; Dynam ic: 900mA

4.2.2. Control Accuracy

- ±0.03 0

4.2.3. Controllable Range

– Pitch:

- 90 0

- 0 0

4.2.4. Maximum Angular Speed

– Pitch: 90 0 /s

4.3. Camera

4.3.1. Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

4.3.2. Sensor Size

– 1/2.4”

4.3.3. Effective Pixels

– 16M

4.3.4. Resolution

– 4384x3288

4.3.5. HD Video Record ing

– 1080p30 & 720p

4.3.6. Recording Field of View

- 110 0 /85 0

4.4. Transmitter

4.4.1. Operating Frequency

– 5.728GHz

– 5.85GHz

4.4.2. Communication Distance (unobstructed)

– FCC Compliance: 800m

4.4.3. Receiver Sensitivity (1%PER)

- - 93dBm

Page 32 of 33EXHIBITS

PLEASE CLICK ON THE WEB LINKS BELOW TO ACCESS THE LATEST USER MANUALS

EXHIBIT A: DJI PHANTOM 2 VISION+ USE R MANUAL

http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_en.pd f

EXHIBIT B: DJI PHANTOM 3 PROFESSIONAL USER MANUAL

http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional _User_Manual_v1.2_en.pdf

EXHIBIT C: DJI INSPIRE 1 USER MANUAL

h ttp://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

EXHIBIT C: DJI SPREADING WINGS S1000+ USER MANUAL

http://download.dji

- innovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

A2 FLIGHT CONTROL SYSTEM USER MANUAL (USED ON THE S1000+)

http://download.dji

- innovations.com/downloads/a2/en/A2_Quick_Start_Guide_v1.22_en.pdf

Page 33 of 33