### 1

Docket Management System

U.S. Dept. of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam,

Pursuant to §333 of the FAA Modernization and Reform Act of 20 12 (the “ Reform Act ” ) and 14 C.P.R. Part

11, Consumers Union of United States, Inc.

, dba Consumer Reports (“ Consumer Reports ”)

, a New York not

- for

profit organization

, desires to operat e a Small Unmanned Aircraft System (sUAS ) for the pur pose of conducting

testing of vehicles at Consumer Reports ’ automobile test facility located in Colchester, C onnecticut . The use

will fu r ther Consumer Reports’ charitable purpose by supporting our product testing operations , helping to

communicate that in formation to the public, and provid ing consumers with a unique perspective on how

Consumer Reports tests its vehicles

. The sUAS would be used in a pre

– planned and controlled are a, located on

327 acres in rural Connecticut, more than six miles from any airport and removed from any air traffic patterns.

We hereby apply for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial

operation of its sU AS for a media purpose

, so long as such operations are con d ucted within and under

the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as

required by §333.

As de s c ri b e d more f

u l l y below, the requested exemption would permit the operation of a sm a ll, unmanned

and r e l ativ e ly inexpensive multirotor aircra ft under controlled conditions in airspace that 1) is contained

, 2) is predetermined

, 3) is on private property with limited public access and 4) has o n

- s ite safety personnel

controlling access

.

The name and address of the applicant is Consumers Union of United States, Inc. , dba Consumer Reports

, :

Attn: Heath Grayson

, 101 Truman Avenue, Yonkers, NY 10703 ( telephone: (914) 378

- 2000 ; e mail:

heath.grayson@consumer.org) . We resp ectfully request a grant of an exemption of the following sections of

Title 14 of the Code of Federal Regulations (and any other relevant provi sions) :

• 14CPR 21;

• 14 CPR 91, et seq.;

• 14 CFR 45.23 (b);

• 14 CPR 61.113 (a) & ( b );

• 14 CPR 407 (a)(l);

• 1 4 CPR 409 (a)(2);

• 14 CFR417(a) & (b).

• 14 CPR 61.113 (a) & ( b );

• 14 CPR 407 (a)(l);

• 1 4 CPR 409 (a)(2); and

• 14 CFR417 (a)&(b).

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Consumer Reports also respectfully requests an Ex e mption from Sec t i on 333 of the FAA Reform Act and Part 11 of

the Federal Aviation R eg u latio n s from:

• 14 CPR 45.23(b);

• 14 CPR Part 21;

• 14 CPR 61.113 (a) & (b);

• 9 1

. 7(a);

• 9 1.9 (b) (2 ) ;

• 91.103(b);

• 91.109;

• 91.119;

• 9 1.1 2 1 ;

• 9l.l5l(a);

• 9 l

. 203(a) & (b);

• 91.405 (a);

• 91.407 (a) (1);

• 91.409 (a) (2);

• 9 1.4 1 7(a)&(b) ; and

any other relevant provisions

.

I. The Extent o f R e l i e f Consumer Reports Seeks and the Reas on I t S e e k s Su c h R e l i e f

Consumer Reports submits this application in acco r d ance w i th the Reform Act, 112 P.L. 95 §§331

- 334,

seeking relief from any c u r r ently applicab l e feder a l aviat i on regulations p e rtaining to UASs (un

- ma nned

aircraft systems) a nd opera ti ng to prevent Consumer Reports’ co n t emplated photographic and other flight

operations within the U.S. national airspace system.

The R e f o rm A ct in §332 provides f o r such integration of civil UASs in t o our national airspace system as it

i s in the publ i c's in t e r e s t to do so. Consumer Reports’ light w e ight U A S meet the d e finition of "small

unmanned aircraft" as set forth in §331 and combined with C o n s u m e r R e p o r t s ’ educational purpose and

not

- for profit mission and the limited intended use of the UAS solely for media purposes

, Consumer Reports’

light duty U

A S is an i d e a l r ecipi e n t of exe m ption by the in t en t of the Reform Act.

C o ns i d erati o n s for r e lief include a combination of the sUAS ’s physical characteristics

, safety features, and

safe practices identi fi ed in §333:

sUAS w eigh t

,

sUAS ov e r a ll siz e,

sUAS speed over g r o un d

,

sUAS flight zone ch a racter i st i cs,

Non

- operation near airports (civilian or military),

Tightly controlled operation in populated areas and

O perat i on of the U AS by VLOS.

Specific c o nsideration is outline d below.

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A. 14 C.F.R. Part 2 1

, Su b part H: A irworthin e ss Certificates

.

14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airwo rthiness Certificates, establishes the procedural

r equir e ments for the issuance of airworthiness certificates as requi r ed by FAR §91.203 (a) (1). Given

the size and limited operating area associated with the s U AS

, an exemption from Part 21 Subpart H meets

the r equirements of an equivalent le v e l of safety under Part 11 and §333 of t h e Reform Ac t

. The

Federal Aviation Act ( 49 U .S.C

. §4470 1 (f)) and §333 of the Reform Act both authorize the FAA to exempt

aircraft from the requirement for an air worthiness certific a t e, upon consideration of the size, weight,

speed, operational cap a bility, and proximity to airports and populated areas of the particular s U AS.

In all cases, an analysis of these criteria demonstrates that the U AS operated without an airworthiness

ce r tificat e

, in t h e restricted environment and under the cond iti ons proposed will be at least as safe, or

safer, than a conventiona l aircraft (fixed wing or rotorcraft) operatin g with an airworthiness certificate

without the restrictions and conditions proposed.

The sUAS to be operated by Consumer Reports is less than 7 l b s . with maximal payload

consisting of cameras and/or other video devices

, carries no persons, carries no explosive or

flammabl e materials including any combustible fuels, and operates exclusively within a private area.

Unlike other civil aircraft, op e rat i ons under this exemption will be tightly controlled and closely

monitored by both the operator and a technician, wh o assists in matters related to maintaining the

sUAS and also monitors for safety concerns

. T hese enhancements provide a greater degree of safety

to the public and property owners than conventional aircraft operations conducted with airworthiness

certificates issue d under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria

demonstrates that there i s no intrinsic credi b l e threat to national sec u r ity posed by the UAS, due to its

size, speed of operation, l ocation of operation, lack of intrinsic ex p l osive materials or flammable liquid

fuels, and inability to carry a substantial ext e rn a l load.

B. 14 C. F

.R. §4 5

. 2 3 ( b ). Ma r ki n g of the Aircraft

.

The regulation requires: When marks include only the Roman capital l ett e r "N" and the registration

number is displayed on limited, restricted or light

- sport category aircraft or experim e ntal or provisionally

certificated aircraft, the operator must also display o n that aircraft near each e ntrance to the cabin, cockpit,

or pilot stat ion, in l etters not less than 2 inches nor more than 6 inches high, the words "limited ”,

"restricted ”, "light

- sport ”

, "experimental ” or "provisional "

, as applicable.

Even though the s UA S will have no airworthiness certificate, a n exemption may b e needed as the

s U A S will have no entrance to the cabin, cockpit or pilot station on which the word "limited ”,

"restricted ”, "light

- sport ”, "experimental ”, or "provisional "

, as applicable, can be placed. Given the size

of the sUA S

, two

- in ch lettering will be impossible. The word "limited ”, "restricted ”, "light

- sport ”,

"experimental ”, or "provisional "

, as applicable, will be placed on the frame in compliance with §45.29

(f) at a size suitable for the available space.

The e quivalent level of safety will be provided by having the s U AS marked on its fuselage as required

by §45.29 ( f) where individuals working with the sUA S will see the identification of the UAS as "limited ”,

"restricted ”, "light

- sport ”, "experimental ”, or "provisional "

, as applicable. The FAA has issued the

following exemptions to this regulation : Exemptions Nos. 10700, 8738, 10167 and 10167A.

C. 1 4 C.F

. R

. § 6 1

. 1 1 3 (a) & ( b ): P r i v a t e Pilot Privi l eges a nd Li m i tatio n s: Pilot i n C omm a nd

.

§61.113 (a) and (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a

pilot or passengers, t h e proposed operati o n s can a c h i eve the equivalent l evel of safety of cu r r e n t o p e r ations

by not requiring a commercial p i l o t ' s l i cense to operate this sUAS. Unlike a conventiona l aircraft that carries

the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of operation

is controlled and restricted, and a ll flights are planned and coordinat ed in advanc e

. The risks associated

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with the operation of the sUAS are so diminished from the level of risk associated with commercial

operations contemplated by Part 61 and exceeds the present level of safety achieved by 14 C.F.R. §61.113

(a) & (b).

D. 14 C

. P

.R. §91

. 7(a ) : C i vil ai r c r a ft airworthi n es s

.

The regulat i o n requires that no pers o n may operate a civil aircraft unless it is an airworthy condition.

As there w ill be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and t he

requirements contained in the maintenance m a n u a l and use of safety check lists prior to each flight

, an

equivalent l e vel of safety will be provided.

E. 1 4 C.P

. R. § 91.9 ( b ) (2): C i v il Aircraft Flight M a nu a l in the Ai r c raft

.

§9 1.9 (b) (2) p rovides: No person may op e r a t e a U.S

. - registe r ed civil aircraft

... (2) For wh i ch a n Airpl a n e or

R o t orcraft F light Man u a l is not r e q u i r e d by §21.5 of th i s chapter, u n l ess th e r e i s availa b l e i n t h e aircraft a

current app r o

ved air p lane or Rotorcraft Flight Manu a l

, approved material, markings, and p lacards, or any

combination thereof.

The sUAS, given i ts size and configuration

, has no ability to carry a physical flight manual on the aircraft. The

equivalent level of safety wil l be maintained by keeping the flight manual at the ground control point where

the crew flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to

this regulation: Exemption Nos. 8607, 873 7

, 8738, 929 9

, 9299A, 9 565, 9565B, 10167, 10167A, 0602, 32827

and 10700.

F. 14 C

. F

. R. § 91.1 0 3: P r e flight a c tion

.

This regulation requires that certain actions are taken before flight to insure the safety of flight. Because

FAA approved rotorcraft f light manuals will n o t be provided for the aircraft

, an exemption will be needed.

A ll actions required to insure safety shall be taken before the flight, including reviewing weathe r

, flight

battery requi r ements, landing and takeoff dista nces and aircraft performance data before initiation of

flight.

G. 1 4 C.F

. R

. § 9 1

. 1 1 9: M i n i mum safe a l t i t u d es

.

§91.119 establishes safe a l titu d es for operation of civil aircraft. §91.119 (d) a1lows helicopters to be operated

at less than the minimums prescribed, provided the person operating the helicopter c o mpl i es with any route

or altitudes prescribed for helicopters by the FAA. As this exempti o n is for a sUAS that closely mimi c s the

behavior of a h elicopter, and t h e e xemption requ est s a uthority to operate at altitudes up to 400 AG L

, an

ex e mption may be needed to a l l ow such operations. A s s e t forth h e r e in, the UAS will never operate at higher

than a height of 200 A GL or beyond unaided visual l i ne of sight, whi c h ev e r i s closer. It will however be

operated in a re s tr i cted , private area wh e re buildings and people will not be exposed to operations with o ut

appropriate t raining and safety precautions

.

The e q ui val e nt l e v e l of safet y w ill be ac h i eved given the s i ze, weight, speed of the UAS as w e ll as the location

where it i s op e r ated. No flight op e r ation will be taken without the permission of t h e property owner in t he

case of private property o r l oc a l officials i n the case of publ i c p r op e r t y o r private property with public in t e r ests.

Compared to flight operati ons with aircraft o r rotorcraft w e i gh i n g far more than the 6.47 lbs. of the sUAS

proposed herein and the l a c k of flammable fuel, any risk associated w ith these operations is far l ess than

those presently presented with conventi o n al aircraft op erating at or below 500 AGL. In a dd i tion, the lo w

altitude operations of the sUAS w ill e n sure separation between these small U A S operations and the operations

of convention a l aircraft that must comply with §91.119.

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H. 1 4 C.F

. R. §

9 1. 1 2 1 A l t i m e t e r Set t

i n gs

.

§91.121 requires ea c h person operating an aircraft to m a in t a i n cru i si n g altitude by r e f

er e nce to an altimeter

that is set "

.. . to the elev a tion of the departure airport or an ap p r o p r i ate a lti m eter setting available before

d epar t u r e "

. As the sUAS may not have a barome t ric altimeter, but i n s t ead a GPS altitude read out, an

exemption m a y be n e e d ed. An equiv ale nt level of saf e ty wi l l b e achieved by the operator, confirming the

altitude of t h e lau n c h si t

e s hown o n the GPS altitude indicator b ef o r e flight.

I. 1 4 C.F.R. § 9 1 .1 5 1 (a): F u e l R e q u ire m e n t s f

o r F l i ght in V F R C o nd i ti o n s

.

§ 9 1. 1 5 1 (a) prohibits an ind i v i dual f rom beginning “ (a)

... a flight in an airplane under VFR conditions

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at leas t 30

minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the sU AS provides

approximat e l y 1 8 minutes of powered flight in hover mode wit hout payload. Consumer Reports’ sUAS will not

be able to meet the 30 minute res e rve r equ i r e m ent in 14 CFR §91.151. Operating the s mall UAS, in a

tightly controlled , private area where o n l y a u t h o r i z e d p e r s o n n e l will be a l l owed, with less than 30

minutes of reserve power, does not engend e r the type of risks t hat Secti o n 91.15l(a) was intended to

allevia t e giv e n the s i z e and s p eed of the s mall UAS. Consumer Reports believes that a n e q uivalent level of

safety can be achiev e d by limiting flights to » 10 minutes o r 25% of battery power whichever happens first.

This restriction would be more than adequate to return the s U A S to its planned landing zone from a nywhere in

its limi t ed operating are a

. Similar ex e mptio n s have been granted to other operations, including Exe m ptions

2689F, 5745, 10673, and 10808.

J. 14 C.P.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Reg i stration

.

Subsection (a) provides in pertinent part t hat :

“ (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it

... [a] n appropriate and current airworthiness certificat e. ”

Subsection (b) provides : “No person may operate a ci v il aircraf t unless the airworthiness certificate

required by paragraph (a) of this section or a speci a l flight authorizat i on issued under §91.715 is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. ”

The sUAS fully loaded weigh s no mo r e than 6.7 lbs. and is operated without an o n board pilot. As

such, there is no ability or place to carry certification and registration documents or to display

them on the sUA S

. An equivalent level of safety w i ll be achieved by keeping these documents

a t the ground control point where the y are immediately accessible

, to the extent they are

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A

representat ive sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A,

9797, 979 7 A, 9816A, and 10700.

K. 14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance I n spec t io n s

.

These regulations require that an aircraft operator or owner "shall have that aircraft i nspected 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

chapte r

.. . ;· and ot hers shall inspect o r maintain the aircraft in compliance with Part 43. Given

that th is section and Part 43 apply o n ly to aircraft with an airwort h i n ess certificate, these

sections will not apply to the applicant. Maintenance will be accomplished by the operator

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pursuant to the flight manual. An equivalent level of safety will be achieved because th is sm a ll

UAS is very limited in size and will carry a small payload and operate only in restricted areas for

limited periods of time. If mechanica l issues a r i se the UAS can land immediately and will be

operating from no higher than 2 00 feet AGL. The operator will ensure that the UAS is in working

order prior to initiating flight, perform required maintenance, and keep a log of any maintenance

p erformed. Moreove r

, the operator is the person most familiar with the aircraft and best suited to

maintain the aircraft in an airworthy condition to provide the equiv a lent level of safety.

An exemption granted to Consumer Reports wo u ld permit its operat ion of a lightweight,

unmanned, remotely controlled, sUAS in a tightly controlled environment with limited airspace.

Further, Consumer Reports conducts its operations in compliance with protocols described herein

or as otherwise established by the FAA.

II. Commercial and Pu b l ic Benefits

A. Furtherance of the Public Interest

.

We believe that granting this exemption request furthers the pu b l ic interest by providing

Consu mer Rep orts, w hich is a Ne w York n ot

- for

- profit organiza tion

, with a

safe

, efficient and innovative means to educate consumer s so that they are empowered to

make informed purchasing decisions. Consumer Reports a ccept s no advertising, buy s all of

i ts test samples and accept s no corporate donations. The success of our mission depends on

the value of our content, the quality of our testing results, and the impact of our reporting and

advocacy efforts in helping consumers. Granting this exemption furthers o ur charitable

purpose of educat ing consumer s

. Drone capability will augment our organization’s testing

methodolo gies

, provid e consumers with unique information , perspective and messaging to

find products that meet their needs and facilitate their purchasing decisions, and educate

consumers about how we test automobiles

.

In addition, use of the s UAS to collect data by photographic, videographi c and other means will enable us to

identify potential technical problems and safety issues to consumers, as well as influence manufacturers to

take appropriate remedial measures.

By movi n g these functions onto a sUAS

- based aircraft, the po t e n tial f o r l o ss of life or pro p erty i s diminished

due to t h e greater co n t r o l in a smaller and s a f e r aircraft that holds no p e r s o n s

. Second, t h ere are n o reactive

or combu st ible materials on board the s U A S and thus the po t e ntial for fire or explosions i s greatly diminished.

Third, the s mall siz e and extreme maneuverability of Consumer Reports’ s UAS will allow the operator to avoid

hazards and operate the sUAS a t or above current safety leve l s.

B. The costs and benefits of your proposed action t o society in general and specific groups within

society

.

The re would be no adverse impact to society, financial a n d otherwise

. I n d eed, allowing the collection of

information through the sUAS would have positive societal effect by augmenting Consumer Reports’ product

testing methodologies and furthering Consumer Reports’ mission of empowering consumers to make informed

purchasin g decisions.

C. T h e effect of an ex e mption f or Consumer Reports on the qual i ty of the natural and social

env ir o n ments

.

Utilizing a

n sUAS minimizes the r eq u irement for conv e nt i onal a i r c raft. This elim i na t es the need for an onboard

pi l ot, time consumi n g adherence to regulations s urrounding book k eeping and s ubmi s s ion of fl i ght pat h s to

l ocal civilia n or military airports, and detrim e ntal effects to the environm e nt caused by operating a

c o mbustible fuel ba s e d, l a r ge sc a l e aircraft, with r es t r i c tions o n the proximity to the targ e t for remote sensing.

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III. F l ig h t Capabilities and Characterist i cs of Consumer Reports’ UAS

Pursuant to 112 P.L. 95 §333 (a), c o ncerns for public safety a re mitigated by t h e overall capabili t

ies and

c haracteristics of t he sUA S

. Consumer Reports’ UA S s util i ze four ( 4 ) counte r

- r o tati n g propellers paired

oppos i t e ly to each other for balance, c o nt r o l and stability. T h e dimensions of the sUAS i s 438x451x301 mm

allowing for stab l e flight and l an d i n g

. The sUAS ha s a maxim um unit + payload mass of 2 9 3 5 g

, including

cinematic/photographic or other equipment. The sUAS’s specifications are set forth in more detail in

Exhibit A attached hereto.

Consumer Reports’ sUAS is designed to primarily hover in p l ace to cap t u r e photograph ic data a nd then

operate at less than 22 m /s maximum speed to the next point of interest. They a r e c a p able of vertical and horizontal

operatio n s but, in pr a ctice, is opera t e d o nly within the operator’s unai d ed VLOS

Consumer Reports’ sUAS utilize s LiPo battery based power sources , - decreasing safety risks from more easily

combustible, fuel base d, power sources. Flight times generally last between eight (8) to ten ( 1 0) minutes

allowing the staff to work with small flight areas per phase. The maximum flight time without payload is 1 8

minutes ; however practical safe operation l imits this to 10 minutes to give am p l e time to control the sUAS

to a safe landing zone. Consumer Reports further restricts f l i ght time by not operating its sUASs with less

than twenty five percent battery capacity.

The sU AS’s specifications are set forth in more detail in Exhibit A attached hereto.

IV. Reasons Why an Exemption to Consumer Reports Will Not Adversely Affect Safety Standards

.

Consumer Reports maintains that opera t ion of its sUAS will not "create a hazard to us ers of the national

airspace system or the public." as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight of

Consumer Reports’ sUAS

, combined with their operation in cordoned off and well

- controlled areas, Consumer

Reports ’ sUAS falls within Congress' contemplated safety zone. Consumer Reports ’ sUAS has an established

safety record bolstered by multi

- point preflight checklist, awareness of their surr o undings and intimate

knowle d ge of the behavior of the sUAS platform in many weat her conditions. This safety record and

imp l emented operationa l practices demonstrate an awareness of public safety.

Consumer Reports ’ operations routinely provide a level of safety at least equal to exi sting rules, and in nearly

every instance, exceeds e xisting rules.

Consumer Reports maintains a l evel of insurance intended to rectify accident a l damage or injury

.

Consumer Reports will not operate its UAS on or near airports and will only be operated on private grounds in

a contained area at Consumer Reports ’ automotive test track

. Consumer Reports determines the areas needed

to fulfill its goals and only operates its UAS in these flight zones and only in compliance with well

- regarded

safety protocols set forth initially by the RC UAS trade and hobby groups and recently codified by relevant

FARs.

Consumer Reports implemented the f o ll o wing practices to ensure safe oper a tion of i t s UASs:

 Work with o n

- s ite personnel to plan the flight goals,

 Work with on

- site personnel to r e s trict access by non

- ess e ntial p ersons,

 Operation by unaided VLOS operation only,

 Operation in phases 10 minutes in length,

 Oper a tion to minimal 25% bat tery powe r

,

### 8

 Operation of d e v i ce to 2 00ft at max i mum

,

 Experienced o n

- s i te safety p e rs o nn e l,

 Preform a site check day(s) before flig ht to identify potential issues and

 Track relevant local weather and safety alerts,

Consumer Reports has exper i ence in si m ilar fields and h a s adapted this exp e r i ence in it s use of the

UAS to increase safety.

S u m m a r y

Pursuant to 14 C.F

. R

. Part 1 1

, the following summary i s provided for publication in the Federal Register,

sh o uld it be d etermined that publicat i on is needed:

Consumer Reports ( a pplica n t ) se e ks a n exemption from the f o l l o w i n g ru l es: 14 C.F.R

. § 2 1, s ubpart H; 14

C.F.R 45.23(b); 14 C.P

. R

. §§61.113( a) and (b); 91.7 (a); 91.9 (b) (2); 9 1. 1 03(b); 9 1. 1 09; 91.119; 91.121;

91.1 5l(a); 91.203(a) & ( b); 91.405 ( a); 91.407 (a) (l); 9 1

. 409 (a) (2); 91.409 (a) ( 2) and 91.417 (a) & (b)

to operate commerciall y a small unmanned v e hicle ( 7 lbs. or less) in elevated photograph op e r a t i ons.

App r oval of exemp tions allowing commercial operat i ons of th e UAS w ill e nha n ce safety by reducing risk

associated with conventional aircraft op e r a t i ons and other means of elevated product testing and

photography involving persons. The public benefit s e rved by approval of t h i s petition is providing

testing methodologies, ratings information and visual presentations to help consumers make informed

purchase decisions and c ompel manufacturers to address and remediate discovered technical and safety

issues

. A sUAS weighing f e w er than 7 l b s . and powered by se a l ed batteries elimina t es virtually all

associated risk inherent in operating c o n v e n tional aircraft in close proximi ty to b uildings or persons or

otherwise elevating persons to a position t h ey would be able t o collect nee d e d da t a.

The o p erati o n of s m a ll UASs, w e ighting less than 7 lbs. conducted in the strict conditions outlined above, will

provide an e q uiva l e nt l e v e l of safety supporting the grant of the exemptions re q u e s ted herein, including

exempting the ap p lic a nt from the requ i remen t s of Part 2 1 and allowing c o mmerci a l operations.

As identified and described herein, Consu mers Reports is an experienced, well regarded media company that has been

in business since 1936.

The FAA has been given the authority to issue Consumer Reports t he exemption to pursuant to the Federal Aviation Act,

85 P.L. 726 (1958), and as such, we humbly seek your consideration and approval of this petition.

Sincerely,

Heath Grayson

Associate General Counsel

Exhibit A: s

UAS Specifications

Exhibit B: I nsurance C ertificate

### 9 sU AS Specifications

Aircraft Model

Inspire 1 T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

- 10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Power Spectral Density

9.06mW/MHz

Gimbal Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

### 10 Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch:

- 90° to +30°

Pan: ±320°

Mechanical Range

Pitch:

- 125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100

- 3200 (video)

100

- 1600 (photo)

Electronic Shutter Speed

8s

- 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti

- distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time

- lapse

Video Recording Modes

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

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

### 11 Video: MP4/MOV (MPEG

- 4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS

- 1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unob structed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini

- HDMI

Power Supply

Built

- in battery

Charging

DJI charger

Dual User Capability

Host

- and

- Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

- 10° to 40° C

Storage Temperature Range

Less than 3 months:

- 20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0

- 40° C

Battery

6000 mAh LiPo 2S

Charger Model

A14

- 100P1A

Voltage

26.3 V

Rated Power

100 W

Battery (Standard) Name

Intelligent Flight Battery

Model

### 12 TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

- 10° to 40° C

Storage Temperature Range

Less than 3 months:

- 20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional) Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

- 10° to 40° C

Storage Temperature Range

Less than 3 months:

- 20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

18 0 W

Vision Positioning Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5

- 500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

### 13 Operating Range

0

- 250 cm

DJI GO App Mobile Device System Requirements

iOS 8.0 or later, Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air

Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2,

iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, an d iPad mini 3 Wi

- Fi + Cellular.

This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

* Compatible with Samsung tabs 705c, Samsung S6, Samsung S5, Samsung

NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend

Mate7, Nubia Z7 mini, SON Y Z3 EXPERIA, MI 3, MI PAD

*Support for additional Android devices available as testing and

development continues.

### 14