## June 23, 2015

Exemption No. 11862

Regulatory Docket No. FAA

– 20 15

– 0891

Mr. Kendrick Smith

1946 Twin Creeks Court

Napa, CA 94559

Dear Mr. Smith :

This letter is to inform you that we have granted your request for exemption. It transmits our

decision, explains its basis, and gives you the conditions and limitations of the exemption,

including the date it ends.

By letter dated March 30, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Raven Aerial Imaging ( hereinafter petitioner or operator ) for an exemption . The

petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct market

research, aerial surveys, mapping, data collection and inspections that consist of still

photographs, video, thermal imaging and other data taken by onboard sensors

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exempti on

.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because the requested exemption would not set a precedent, and any

delay in acting on this petition would be detrimental to the petition er

. The FAA received one

individual comment in opposition to the petition and one in support from the petitioner . In

granting this exemption, the FAA has determined that the proposed operations can safely be

conducted under the conditions and limitations of this exemption. As with exemptions issued

to Aeryon Lab, Astraeus Aerial, Clayco, Inc., and VDOS Global, LLC, failure to comply with

the document’s conditions and limitations is grounds for immediate suspension or rescission

of the exemption.

## 2

Airwort hiness Certification

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

.

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

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited

operating area associated with the aircraft and its operation, the Secretary of Transportation

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

finds that relief from 14 CFR part 21

, C ertification procedures for products and parts,

Subpart H

— Airworthiness Certificates , and any associated noise certification and testing

requirements of part 36, is not necessary.

The Basis for Our Decision

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



## . The FAA has issued grants of

exemption in circumstances similar in all material respects to those presented in your petition.

In Grants of Exemption No s

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

11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No.

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned

aircraft (UA) with the specifications described by the p etitioner and carrying no passengers or

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled

by this exemption is in the publi c interest.

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

—

 They are similar in all material respects to relief previously requested in Grant of

Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for grant ing Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest.

T herefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701,

delegated to me by the Administrator, Raven Aerial Imaging is granted an exemption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c),

1 

### Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA.

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF

analysis, etc.), chemical measurement ( particulate measurement, etc.), or any other gathering of data by

instruments aboard the UA.

## 3

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limi tations listed below.

Conditions and Limitations

In this grant of exemption, Raven Aerial Imaging is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

Vision+ when weighing less than 55 pounds including payload. Proposed operations

of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder ma y use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at

airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human v ision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within

the visual line of sigh t (VLOS) of the PIC and VO at all times. The VO may be used

to satisfy the VLOS requirement as long as the PIC always maintains VLOS

capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not per mitted during flight operations. The PIC

must be designated before the flight and cannot transfer his or her designation for the

duration of the flight. The PIC must ensure that the VO can perform the duties

required of the VO.

7. This exemption and all do cuments needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in this grant of

exemption, are hereinafter referred to as the operating documents. The operating

## 4

documents must be accessible during UAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and

limitations in this exemption and the procedures outlined in the operating documents,

the conditions and limitations herein take precedenc e 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 or any law enforcement official upon request. The

operator must also present updated and revised documents if it petitions for extension

or amendment to this grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted this exemption, then

the operator must petition for an amendment to its grant of exemption. The FA A’s

UAS Integration Office (AFS− 80) may be contacted if questions arise regarding

up dates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation

or flight characteristics, e.g.

, replacement of a flight critical component, must undergo

a functional test flight prior to conducting further operations under this exemption.

Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to not pose an u ndue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is

in a condition for safe operation.

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

- flight inspection and determine the

UAS is in a condition for safe flight. The pre

- flight inspection must account for all

potential discrepancies, e.g.

, inoperable components, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

proh ibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal

## 5

government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged i n a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

(traini ng, proficiency, and experience

- building) and determining the PIC’s ability to

safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption. However,

training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for

flight operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

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

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in th e current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter of agreement with the airport management must be made available

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

pre

- determined location within the pr ivate or controlled

- acces s property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least five minutes or with the reserve

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be cond ucte d in accordance with an ATO

- issued COA. The

## 6

exemption holder may apply for a new or amended COA if it intends to conduct

operations that cannot be conducted under the terms of the attached COA

.

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

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

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

be as large as practicable.

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

official upon request.

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

activities at all times.

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

26. All Flight opera tions must be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accide nt. The operator must 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 in a manner en suring the safety

of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those ob jects and determined that it does not

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

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

- access property with

permission from the property owner/controller or authorized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight op eration that transgresses the lateral or vertical

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

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be

## 7

reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and

television filming and production, the following a dditional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exempti on must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day

notification may be waived with the concurrence of the FSDO. The plan of activities

must inclu de at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

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

- scene operation of

the UAS;

d. Mak e, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS

operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

## 8

This exemption terminates on June 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

EnclosuresKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

1 March 30, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Reques t U nder Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14

C.F.R. Part 11, Raven Aerial Imaging

, the owner and operator of the DJI Phantom 2 Vision+ a small

Unmanned Aircraft Systems (“sUAS”) seeks an exemption from the Federal Aviation Regulations

(“FARs”) listed below and discussed in Appendix A. Details of Raven Aerial Imagery and the DJI

Phantom 2 Vision+ sUAS and described in Appendix B. Attached as Appendix C is a summary of this

request.

The requested exemption would permit Raven Aerial Imaging commercial operation of DJI Phantom 2

Vision+ ( see details in Appendix B), which weighs under 6 lbs. with imaging payload, to perform

market research, aerial surveys, mapping

, data collection and inspections that consist of still

photographs, video, thermal imaging and other data taken by onboard sensors. The DJI Phantom 2

Vision+ produces high quality imagery and data that can be used independently or in the case of

surveying and modelling, can be combined to produce precision digital point clouds, triangle models,

and contour maps of the surveyed area. Application for this sUAS include inspection of sensitive

infrastructure including oil and gas pipelines and flare stacks, power lines and towers, wind turbines,

and surveying tasks such as precision agriculture, mining, transportation, building inspection wildlife

monitoring and forestry. Use of the DJI Phantom 2 Vision+ for these inspection and surveying

applications reduces the need to operate conventional aircraft, providing data more quickly, accurately,

economically, safely and with reduced environmental impact.

Operations under the exemption will be subject to strict operating requirements and conditions to

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft

and under conditions as may be modified by the FAA as required by Section 333.

While Raven Aerial Imaging is filing this exemption request on its own behalf, it anticipates that its

customers, in the future, will file exemption applications to allow them to operate the DJI Phantom 2

Vision+ in commercial operations at their own facilities, farms, mines, and other sites that require

aerial data for inspections and surveys. Wherever possible, those filings will be substantially similar to

this exemption application.

As described more fully below, the requested exemption would authorize Raven Aerial Imaging toKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

2 perform market research and commercial operations of aerial inspections , thermal imaging, photography,

video and surveys using the DJI Phantom 2 Vision+ 1 which under 6 lbs. is small in size and powered

electrically by battery. The DJI Phantom 2 Vision+ will be operated under controlled conditions at low

altitude (under 400ft. or 200ft. as determined by this exemption) in airspace that is limited in scope, as

described more fully herein; It will have automated control features, as described below. The DJI

Phantom 2 Vis ion+ is designed to be operated by one person but flight operations generally involve two

people: an operator and an observer. The operator is responsible for flying the sUAS, monitoring its

status and flight dynamics while maintaining visual line of sight and keeping the flight within the

specified factory limits (in terms of wind, flight range, battery life, etc. ) to ensure safe operation of the

sUAS itself. The observer is responsible for monitoring the airspace for other aircraft and hazards

and instructing the operator before and during flight as necessary to ensure safe separation/de

- confliction with these aircraft and hazards. The operator also will be an individual who has passed

authorized The DJI Phantom 2 Vision+ training program for the DJI Phantom 2 Vision+

. Finally, the

airspace in which the DJI Phantom 2 Vision+ will operate will be disclosed to and approved, as

needed, by the FAA in advance.

Raven Aerial Imaging respectfully submits that because this small, unmanned aerial system

– the DJI

Phantom 2 Vision+ will be used in lieu of comparatively hazardous operations now conducted with

fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will

achieve at least an equivalent level or greater level of safety. Approval of this exemption would thereby

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities

under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such

aircraft systems in the national airspace system.”

The name and address of the applicant are:

Raven Aerial Imaging

Attn: Kendrick Smith

Ph

. 707

- 333

- 0256

Email: kendrick@ravenaerialimagery.com

Address: 1946 Twin Creeks Ct

Napa, CA 9 4 559 USA



### The primary contact for this application is:

Kendrick Smith;

kendrick@ravenaerialimagery.com ;

707

- 333

- 0256

The regu lations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

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

14 C.F.R. 61.113(a) & (b) ;

14 C.F.R. 61.133(a) ;

14 C.F.R. 91.7(a) ;

14 C.F.R. 91.9(b) (2) & (c) ;

14 C.F.R. 91.103;

14 C.F.R. 91.109(a) ;

14 C.F.R. 91.119;

Formatted: Font: (Default) Arial, 1 ptKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

3 1 DJI Phantom 2 Vision+ customers have been granted flight operation certificate to operate the DJI Phantom 2

Vision+

, Certificates of Waiver or Authorization (COA) in the US for public agency use.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15



### Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

4 14 C.F.R. 91.151(a) ;

14 C.F.R. 91.203(a) & (b) ;

14 C.F.R. 91.405(a) ;

14 C.F.R. 91.407(a) (1) ;

14 C.F.R. 91.409(a) (2) ;

14 C.F.R. 91.417(a).

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public

interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Raven Aerial Imagery submits that grant of this exemption application for use of the DJI Phantom

2 Vision+ in market research, surveying, mapping and inspection operations will advance the

Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of sUASs

into the national airspace system (“NAS”) if it can be accomplished safely. This law directs the

Secretary of Transportation to consider whether certain sUASs may operate safe ly in the NAS

before completion of the rulemaking required under Section 332 of the Reform Act. In making this

determination, the Secretary is required to determine which types of sUASs do not create a

hazard to users of the NAS or the public or pose a threat to national security in light of the

following:

1. The sUAS’s size, weight, speed, and operational capability;

2. Operation of the sUAS in close proximity to airports and populated areas; and

3. Operation of the sUAS within visual line of sight of the operator.

Reform Act § 333(a) (1). If the Secretary determines that such vehicles “may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe operation of

such aircraft in the national airspace system.” Id. §333(c) (emphasis added). 2



### The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness

certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the

Administrator finds the exemption is in the public interest.

49 U.S.C. §44701(f). See also 49 USC §44711(a) ; 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 of the Reform Act; The additional authority in the Federal Aviation Act, as

amended; The strong equivalent level of safety surrounding the proposed operations; And theKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15



### Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

5 significant public benefit, including enhanced safety and cost savings associated with transitioning

to sUASs for aerial surveying, mapping and inspection applications. According ly, th e applicant

respectfully requests that the FAA grant the requested exemption without delay.

Airworthiness of the DJI Phantom 2 Vision+

A critical element of the exemption application involves evidence of the airworthiness of DJI

Phantom 2 Vision+ sUA S including the DJI Phantom 2 Vision+

. Raven Aerial Imagery believes that

it has shown compliance through a history of granted flight operations and successful flights

- including many operations with public agencies. The list of granted applicants includes:

2 Applicant submits that this provision places a duty on the Administrator to not only process applications for

exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein

require modification in order to allow approval, to supply conditions for the safe operation of the sUAS

. 

### Raven

Aerial Imagery welcomes the opportunity to consult with FAA staff in order to address any issues or

concerns that this proposal may raise that they believe may require modification.



### The criteria set forth in the Order specify the substantive showings of the device’s safety and

fitness for operation to ensure that the FAA has sufficient basis to evaluate the aircraft’s safety 3



### . The DJI Phantom 2 Vision+ also has a signifi cant set o f automated features to ensure safe takeoff,

flight and landing in many conditions, further details of operation can be found in Appendix B.



### Mandatory Operating Conditions

Grant of the exemption to Raven Aerial Imagery will be subject to the following mandatory

conditions, which are based upon operating conditions set forth for operation of sUAS by public

entities pursuant to Certificates of Authorization, with additional restrictions:



### 1. All operations to occur in Class G airspace.



### 2. Operations to avoid congested or populated areas, which are depicted in yellow on VFR

charts.



### 3. Operations to be condu cted over private or controlled access property.



### 4. Permission from land owner/controller required before commencing any flight.



### 5. Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).



### 6. Aircraft to remain within Visual Line of Sight (VLOS).

i. VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical

miles (NM).

ii. Cylinder walls may be expanded by observer with ability to control aircraft.



### 7. Operations to occur during daylight hours.

8. Above Ground Level (AGL) altitude to be restricted to 400 feet.

9. All operations conducted in vicinity of airp ort to remain more than 2.5 NM from centerline

azimuth of runw ay centerline measured from runway thresholds.

10. Operator will file a NOTAM for each flight.

11. All required permissions and permits will be obtained from territorial, state, county or cityKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15



### Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

6 jurisdictions, including local law enforcement, fire, or other appropriate governmental

agencies.

12. All operations will include one pilot for flight control and one observer for VLOS

enhancement of surrounding area near the aircraft



### Operator Requirements

Raven Aerial Imagery respectfully proposes that operator requirements should take into account

the characteristics of the particular sUAS. Certain sUASs, such as the DJI Phantom 2 Vision+

are characterized by a high degree of pre-programmed control and various built

- in technical

capabilities that limit the potential for operation outside of the operating co nditions set forth above.

The DJI Phantom 2 Vision+ sUAS also provides many built

- in functional and safety features to

assist the operator in safe and reliable operation. 4

3 

### Raven Aerial Imagery can submit under confidentiality the following documents in support of this exemption

application for the DJI Phantom 2 Vision+

. DJI Phantom 2 Vision+ User Guide (Exhibit 1) which includes Safety

and Preflight Checklists; and 2) Training Manual (Exhibit 2).

4 As of July 2014, 

### Raven Aerial Imagery staff have performed over 100 flights, logging more than 120 hours of

flight time with the DJI Phantom 2 Vision+

. This is a significant amount of flight time collected to understand and

refine skills for the DJI Phantom 2 Vision+



### .

The DJI Phantom 2 Vision+ provides two semi-autonomous flight modes using a point-and-click

map and video interface. The user clicks on a map to direct the DJI Phantom 2 Vision+ to fly to the

point on the map where the operator is pointing, or programmed flight plans may be entered for

a series of waypoints or grid based area. Additional navigation aids including landing zones and

flight areas may be designated to ensure the DJI Phantom 2 Vision+ operates only within user

specified flight parameters. All fl ight operations are GPS controlled making the system easy to

navigate, and the fl ight control system also employs a variety of sensors including sonar,

barometric pressure, temperature, wind speed and others to ensure the high stability and reliability

in challenging weather conditions. At all times during flight operations, the operator can intervene a

programmed flight and take immediate control.

Additional automated safety functions and safety enhancing features of the DJI Phantom 2 Vision+

include the following:



### ● Automated pre-flight system performance checks

● User pre-flight checklist

● Automated condition or fault detection, warnings, and pre-defined responses to a

number of flight and system conditions.

◦ High winds with system and user defined safety thresholds

◦ Low battery with system and user defined safety thresholds

◦ High temperature or other system safety thresholds

◦ Lost link communication



### ● Pre-defined responses include behavior such as attempting to re-establish

radio communication, return to home position and hover, return to home

position and land, or land in current position

● In the case of lost GPS, a manual user flight mode is enabled which allows the

operator to provide manual navigation inputs to assist in landing the vehicle.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15



### Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

7 Given these safety features, Raven Aerial Imagery proposes that operators of the DJI Phantom 2

Vision+ should not be required to hold a commercial or private pilot certification. Instead,

operators should be required to:



### 1. Have successfully completed, at a minimum, FAA private pilot ground instruction and passed

the FAA Private Pilot written examination or FAA recognized equivalents including

commercial or private license and ground school issued from an ICAO recognized country;



### 2. H ave completed DJI Phantom 2 Vision+ authorized training program for operation and

maintenance of the sUAS.

Raven Aerial Imagery notes that the FAA has found that safety factors permitted operation of

sUASs by operators with these qualifications in the case of operation s pursuant to public COAs when

the mandatory operating conditions specified above were present. See Federal Aviation

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at

20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the

requirements for and privileges associated with the grant of airmen ’s certificates. 49 USC §44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to

allow market research and commercial operations of a small unmanned vehicle in surveying,

mapping and inspection operations.

Approval of the exemption allowing commercial operations of the DJI Phantom 2 Vision+ for

surveying, mapping , aerial photography, thermal imagery, data collection and inspection operations

will enhance safe ty by reducing risk. Conventional aerial survey and inspection operations using

manned aircraft involve very heavy aerial vehicles carrying significant quanti ties of combustible

fuels, and a multi-person crew in piloting and observation roles. These operations require

transit to and from the location of the activity, and will at times take place in congested

environments including proximity to physical obstacles and/or presence of the general public.

By contrast the DJI Phantom 2 Vision+ weighs u n d e r 6 lbs. including payloads and uses a

battery for power, is carried to /from the area of activity, removes the need for airborne

pilots/observers, and poses less risk to people and infrastructure on the ground.

Additionally, no national security issue is raised by the grant of the requested exemptions. Given

the size, load carrying capacity, speed at which it operates, and the fact that it carries no

explosives or other dangerous materials, the DJI Phantom 2 Vision+ poses no threat to national

security.

The operation of the DJI Phantom 2 Vision+ for market research, surveying, mapping , thermal

imaging, data collection and inspection operations in accordance with the strict conditions outlined

abo ve, will provide an equivalent level of safety supporting the grant of the exemptions requested

herein, including exempting Raven Aerial Imagery from the requirements of Part 21.

T he DJI Phantom 2 Vision+ satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight, speed, operating capabilities, lack of proximity to airports and populated areas,

operation within visual line of sight, and national security

– and its showing of an equivalent level

of safety as it may relate to the requirement for a pilot’s license, provide more than adequateKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15



### Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

8 justification for the grant of the requested exemptions allowing Raven Aerial Imagery commercial

operation of the DJI Phantom 2 Vision+ in market research, surveying, mapping , thermal imaging,

data collection and inspection operations.

Respectfully yours,

Kendrick F. Smith

Raven Aerial Imagery

1946 Twin Creeks Ct

Napa, CA 94559 USA

kendrick@ravenaerialimagery.com

Temporary Number: NT0048855KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

9 APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Raven Aerial Imagery requests an exemption from the following regulations as well as any additional

regulations that may technically apply to the operation of the DJI Phantom 2 Vision+ :

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a) (1)

Section 91.203(a) (1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart

H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft ( under 6

lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the

certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the

size, weight, speed, operational capability, and proximity to airports and populated areas of the

sUAS involved.

In this case, an analysis of these criteria demonstrates that the DJI Phantom 2 Vision+ operated

without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or

safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The DJI

Phantom 2 Vision+ weighs under 6 lbs. fully loaded. It will not carry a pilot or passenger, will not carry

flammable fuel, and will operate exclusively within an area pre disclosed and in compliance with

conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by

both the operator, pursuant to the conditions set forth above, and by local public safety requirements.

The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt of the

prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that

the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The

DJI Phantom 2 Vision+ provides at least an equivalent, and most likely exceeds level of safety to that

of such operations being conducted with conventional aircraft that would be orders-of-magnitude

larger and would be carrying passengers, cargo and flammable fuel. The automated safety features

including redundant sensor systems as described in Appendix B and throughout this document

highlight the design intentions towards safety and reliability on DJI Phantom 2 Vision+.

14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the

Roman capital letter “N” (denoting United States registration) followed by the registration

number of the aircraft. Each suffix letter used in the marks displayed must also be a

Roman capital letter.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

10 (b) When marks include only the Roman capital letter “N” and the registration number is

displayed on limited, restricted or light sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also dis play on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more

than 6 inches high, the words “limited,” “restricted,” “ light sport ,” “experimental,” or

“provisional,” as applicable.

Regulati on 91.9(c) provides:

No person may operate a U.S. registered civil aircraft unless that aircraft is identified in

accordance with part 45 of this chapter

.

The DJI Phantom 2 Vision+ has no entrance to the cabin, cockpit, or pilot station on which the

markings can be placed. Given the size of the sUAS, two inch lettering will be impossible. Official

marking systems for small UAS have not yet been established for operations inside the NAS. The DJI

Phantom 2 Vision+ is currently marked with a fixed label containing DJI Phantom 2 Vision+ measuring

1.5” x 0.5” as well as a serial number located under the removable camera payload. Raven Aerial

Imagery is prepared to mark the inspection system with the name of the organization and location or

origin and fulfill any other request by the FAA to this topic in accordance to § 45.29(f) where the pilot,

observer, and others working with the sUAS will see the identification of the sUAS.

The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167,

10167A and 10700.



### 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit privat e pilots to non-commercial operations. Unlike a conventional aircraft

that carries a pilot, passengers, and cargo, the DJI Phantom 2 Vision+ in this case is remotely

controlled with no passengers or property of others on board. Section 61.133(a) requires an individual

with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire.

Raven Aerial Imagery respectfully proposes that operator require ments should take into account the

characteristics of the particular s UAS. DJI Phantom 2 Vision+ has a high degree of pre-programmed

control and various built

- in technical capabilities that strictly limit the potential for operation outside of the

operating conditions set forth in the exemption application.

The DJI Phantom 2 Vision+ h as an all

- digital software platform with advanced features previously

restricted to full size unmanned aircraft. Automated features and advanced fly safe controls enable

safe, reliable operation, as well as advanced netw orking capabilities and system extensibility.



### 1. Plan your flight or fly ad hoc: The system can autonomously fly a programmed flight path or fly

in manual mode



### 2. Smart batteries and charger: Flight time and battery minutes are displayed at all times. The

system will return home and land automatically if user configurable limits are reached.

Flight safety is a priority, no matter the operating environment or project. The DJI Phantom 2 Vision+

offers superior safety over manned aircraft by removing the need for people to be onboard in potentially

dangerous situations. With multiple built

- in safety features, the DJI Phantom 2 Vision+ platform leads

other sUAS with respect to safety.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

11 1. Intelligent fault handling: The system automatically detects potential issues

- with configurable

automated response behavior such as a return-home-and-land routine

2. Automatic pre-flight checks: The system self

- calibrates all of its sensors and performs self

- tests

prior to takeoff to check for errors

3. No fly zones: The system has the ability to set up visual no fly zones and installed no fly zones.

4. Self

- monitoring : Monitoring battery levels, in-flight wind speeds, and other system and

environmental conditions are automatically handled by the system

5. Battery co mmunication: Battery minutes and flight time are displayed at all times. The system

will return home and land automatically if user configurable limits are reached.

Additional automated safety functions and s afety enhancing features of the DJI Phantom 2 Vision+

include the following:

1. Auto detection of lost GPS warns the pilot and initiates an immediate landing.

2. Low battery on the DJI Phantom 2 Vision+ triggers a Non

- Fatal Warning alarm to return

home, land and replace the battery

3. Very low battery on the DJI Phantom 2 Vision+ triggers a Fatal Error alarm and initiates an

emergency high speed descent landing.

4. If the DJI Phantom 2 Vision+ detects a lost link to the base station the vehicle will perform its

pre- defined Nonfatal Condition Response

.

Given these safety features, Raven Aerial Imagery proposes that operators of the DJI Phantom 2

Vision+ should not be required to hold a commercial or private pilot certification. Instead, operators

should be required to:



### 1. H ave completed DJI Phantom 2 Vision+ training program for operation of the sUAS.



### 2. Completed Raven Aerial Imagery training and safety program.

Raven Aerial Imagery notes that the FAA has found that safety factors permitted operation of

sUASs by operators with these qualifications in the case of operations pursuant to public COAs

where the mandatory operating conditions specified above are present. See Federal Aviation

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at

20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C §44701(f) to waive

the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing

operation of the DJI Phantom 2 Vision+ without a private pilot’s certificate or a commercial pilot’s

certificate, under the conditions set forth herein.

The risks associated with the operation of the DJI Phantom 2 Vision+ (given its size, speed,

operational capabilities, and lack of combustible fuel) are so diminished from the level of risk

associated with private pilot operations or commercial operations contemplated by Part 61 with

conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUAS as set forth above

meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does

not rise to the level of requiring a commercial pilot t o operate the aircraft under § 61.133(a).14 C.F.R. §

91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

Should the exemption be granted allowing commercial operation of the DJI Phantom 2 Vision+

without an airworthiness certificate, no standard will exist for airworthiness of the DJI Phantom 2KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

12 Vision+

. Given the size of the ai rcraft and the previous COAs issued for DJI Phantom 2 Vision+

equivalent level of safety will be achieved by ensuring compliance with the DJI Phantom 2 Vision+

manuals prior to each flight.

14 C.F.R. § 91.9(b) (2): Civil Aircraft Flig ht Manual in the Aircraft.

The regulation provides:

No person may operate a U.S. registered civil aircraft configuration of the DJI Phantom 2

Vision+ , it has no ability or place to carry such a flight manual on the aircraft, not only

because there is no pilot on board, but because there is no room or capacity to carry

such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual ( see

, e.g.

, User

Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate

access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos.

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10 167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight A ction

This regulation requires each pilot in command to take certain actions before flight to insure the safety

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will

be needed. An equivalent level of safety will be provided as set forth in the DJI Phantom 2 Vision+

User Manual (exhibit 1) under the ‘Getting Ready to Fly’ section. The PIC will take all actions

including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft

performance data before initiation of flight.

14 C.F.R. § 91 .109(a) & 91.319(a) (1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free balloon)

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The DJI Phantom 2 Vision+ is a remotely piloted aircraft and by design, does not have fully functional

dual controls. Flight control is accomplished through the use of a control box that communicates with

the aircraft via radio communications. The flight plan is either manually controlled through

point-and-click touch screen navigation or pre-programmed as way points or an Auto Grid into the

auto pilot before or during flight and only in unusual circumstances will the pilot input control

functions to alter the pre-programmed flight. If instruction is accomplished through a training program,

as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved

exemptions for flight training without fully functional dual controls for a number of aircraft and for flight

instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of

safety will be achieved by the manufacturer providing the training as outlined, for example, in Exhibit

2 and through the use of experienced and qualified pilots familiar with the DJI Phantom 2 Vision+

.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c)

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface,KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

13 except over open water or sparsely populated areas. In those cases, the aircraft may not be

operated closer than 500 feet to a ny person, vessel, vehicle, or structure.

As set forth herein, the DJI Phantom 2 Vision+ will never operate at higher than 400 feet AGL. It will,

however, be operated to avoid congested or populated areas that are depicted in yellow on VFR

sectional charts. Because aerial survey, mapping and inspection work must be accomplished at

relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is

needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which

the DJI Phantom 2 Vision+ is built. Also, no flight will be taken without the permission of the land

owner or those who control the land. Because of the advance notice to the landowner, all affected

individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or

rotorcraft weighing far more than 6 lbs. and carrying flammable fuel, any risk associated with these

operations will be far less than those currently allowed with conventional aircraft operating at or

below 500 feet AGL Indeed, the low altitude operations of the sUAS will maintain separation

between these sUAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “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 least 30 minutes; Or

2. At night, to fly after that for at least 45 minutes.

The DJI Phantom 2 Vision+ batteries provide approximately 50 minutes of powered flight. Without

an exemption from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes

in length. Given the limitations on its proposed operations and the location of those proposed

operations, a longer time frame for flight in daylight VFR conditions is reasonable.

Raven Aerial Imagery believes that an exemption from 14 CFR § 91.151(a) is safe and within the

scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

without compliance with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel does not

engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at

which the sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety.

Additionally, limiting DJI Phantom 2 Vision+ flights to 20 minutes would greatly reduce their utility. In

the unlikely event that the DJI Phantom 2 Vision+ should run out of fuel, it would simply land. Given its

weight and construction material, the risks are less th an contemplated by the current regulation.

Raven Aerial Imagery believes that an equivalent level of safety can be achieved by maintaining 10

minutes of reserve fuel, which, allowing 40 minutes of flight time, would be more than adequate to

return the sUAS to it planned landing zone from anywhere in its operating area.

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and

10808.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

14 14 C.F.R. § 91.203 (a) & (b): Carrying Civ il Aircraft Certification and Registration

This regulation provides as follows:

1.

... No person may operate a civil ai rcraft unless it has

... an appropriate and current

airworthiness certificate.

2. No person may operate a civil aircraft unless the airworthiness certificate required by paragraph

(a) of this section or a special flight authorization issued under §91.715 is displayed at the

cabin or cockpit entrance so that it is legible to passengers or crew.

3. The DJI Phantom 2 Vision+ fully loaded weighs under 6 lbs. As such, there is no ability or

place to carry certification and registration documents or to display them on the sUAS. In

addition, there is no pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point

where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous

exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos.

9565, 9665, 9789, 9789A, 9797, 979 7A, 9816A, and 10700.

14 C.F.R. § 91.405(a) ; 407(a) (1) ; 409(a) (2) ; 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...”

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a) (2) requires

an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires

the owner or operator to keep records showing certain maintenance work that has been accomplished

by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft

for return to service.

The DJI Phantom 2 Vision+ is nearly maintenance free, it performs automatic pre­flight checks and

the failure of any check will prevent take-off. Checks which cannot be done by the system will be

performed by a qualified person prior to each fl ight and at predefined intervals as part of the

Maintenance Schedule in the User Manual (se e Exhibit 1).

Pre flight checklist includes:

1. Visual inspection of the airframe

2. Visual inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, co mmand station, radio repeater station )

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external

payload, will operate only in restricted predetermined areas and is not a complex mechanical devise.

As provided in the attached User Guide (System Maintenance section), the operator of Raven Aerial

Imagery will ensure that the sUAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the

person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy

condition and to ensure an equivalent level of safety.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

15 The DJI Phantom 2 Vision+ Maintenance guidelines ensure an equivalent level of safety to the

maintenance requirements in Part 91. In addition, any component failure detectable by the system will be

reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or

Nonfatal Condition Response.

Appendix B :

The Phantom 2 Vision+ ushers in a new era of aerial cinematography with its brand new and in credibly stable 3

- axis

gimbal, combined with the sharp, powerful DJI

- designed camera, making professional imaging tools easily accessible

to everyone.



## Phantom 2 Vision +

Battery 5200mAh LiPo Formatted: Font: (Default) Times New

Roman, 12 pt, Bold, Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

16 

### Phantom 2 Vision+

Weight 1242g (with battery &

propellers)

Hover Accuracy (Ready

to Fly) Vertical:0.8m

Horizontal:2.5m

Max Yaw Angular

Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent

Speed Ascent: 6m/s

Descent: 3m/s

Max Flight Speed 15m/s(Not Recommended)

Diagonal Length 350mm

Tilting Range of Gimbal Pitch :

- 90°

- 0°

1. Ready to fly

2. 3

- axis camera stabilization

3. Precision flight and stable hovering

4. Radar positioning & return home

5. Onscreen real

- time flight parameters

6. High performance camera

7. Camera tilt control

8. Film straight down

9. Supports Adobe DNG RAW

10. Adobe lens profile support

11. Camera parameter settings



### 12. Album synchronization

TRANSMITTER

1. Operating Frequency:5.728 GHz

– 5.85 GHz

2. Communication Distance ( open area ) : CE: 400m; FCC: 800mKENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

17 3. Receiver Sensitivity ( 1%PER ) :

- 93dBm</td></tr>

4. Transmitter Power: CE: 25mw; FCC: 100mw

5. Working Voltage:80 mA@6V

6. Battery:4 AA Batteries

CAMERA

1. Operating Environment Temperature : 0 °C

- 40 °C

2. Resolution:4384×3288

3. FOV:110°/ 85°

4. Sensor size:1/2.3"

5. HD Recording:1080p30 /720p60

RANGE EXTENDER

The Phantom 2 Vision+ Range Extender is a wireless communication device that operates

within the 2.4 GHz frequency band. It is used to extending the effective range of communication

between a Smartphone and the Phantom 2 Vision+. In an open, unobstructed a rea, the

transmission distance can reach up to 700 meters. This can be reduced by trees, buildings and

other sources of the same frequency. Before every flight, it is suggested that you ensure the

Range Extender is functioning properly; otherwise communica tion issues between the mobile

device and the Phantom 2 Vision+ may occur.

DJI VISI ON APP

System Requirement of Mobile Device: iPhone4s, iPhone5, iPhone5s, iPod Touch4, iPod Touch5;

Phantom 2 Vision+ Before Flight

Once pre

- flight preparation is complete, it is recommended to carry out the tasks in the Phantom Pilot

Training Guide to prepare for more complex flight maneuvers and learn to fly safely. Ensure that all flights

are carried out in a suitable location.

Fli ght Environment Requirements

1. Do not use the aircraft in severe weather conditions. These include wind speed exceeding category

4, snow, rain and smog.

2. Fly in open fields as high buildings or steel structures may affect the accuracy of the onboard

compass.

3. Keep the Phantom away from obstacles, crowds, high voltage power lines, trees or bodies of water

when in flight.

4. Reduce the chance of electromagnetic interference by not flying in areas with high levels of

electromagnetism, including base stations or ra dio transmission towers.

5. The Phantom cannot operate within the polar areas.

6. Do not fly the aircraft within no

- fly zones specified by local laws and regulations.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

18 Preflight Checklist

1. Remote Controller, smart battery, Range Extender and smartphone are ful ly charged.

2. Propellers are mounted correctly.

3. Gimbal clamp has been removed.

4. Damping absorbers are in good condition, not broken or worn.

5. Anti

- drop kits have been mounted correctly.

6. Ca mera lens cap has been removed.

7. Micro

- SD card has been inserted if necessary.

8. Gimbal is functioning as normal.

9. Motors can start and are functioning as normal.

10. DJI VISION App can connect to the camera.

DJI Vision App Usage

The DJI VISION App controls the Phantom 2 Vision+ camera inc luding capture, recording, settings and

pitch angle. It also displays essential flight information including flight parameters and battery.

Calibrating the Compass

IMPORTANT: Make sure to calibrate the compass in every new flight location. The compass is very

sensitive to electromagnetic interference, which can cause abnormal compass data leading to poor flight

performance or even flight failure. Regular calibration is required for optimum performance.

Calibration Procedures

Choose an open space to carry out the following procedures. Watch the Phantom 2 Vision+ quick start

video for more details.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

19 Hints and Tips:

If compass calibration is needed before flight, a prompt will appear on the DJI VISON App’s camera page. It

will disappear aft er successful calibration.

When to Recalibrate

1. When compass data is abnormal, the rear LED flight indicator will blink red and yellow.

2. Flying in different location to last flight.

3. Mechanical structure of the Phantom has changed, i.e. changed mounting position of the compass.

4. Severe drifting occurs in flight, i.e. Phantom does not fly in straight lines.

Starting Motors

A Combination Stick Command (CSC) is used to start the motors instead of simply pushing the stick up.

(Figure 50) Push both sticks to their bottom corners to start the motors. Once the motors have spun up,

release both sticks simultaneously.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

20 Stopping Mo tors

There are two methods to stop the motors.

Method 1: When the Phantom has landed, push the throttle down, then conduct CSC. Motors will stop

immediately. Release both sticks once motors stop.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

21 Method 2: When the aircraft has landed, push the throttl e down and hold. Motors will stop after 3 seconds.KENDRICK SMITH / RAV EN AERIAL IMAGERY

3/30/15

Petition for Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FAR

22 Warning: Do not execute CSC during normal flight. This will stop the motors and cause the aircraft to drop

without control.

References: Conduct the CSC as neatly as you can. Release the sticks once motors start/stop.

Take off / Landing Procedures

1. Place the Phantom 2 Vision+ on open flat ground with battery indicators facing towards you.

2. Power on the Remote Controller and Range Extender, then the Smart Flight Battery.

3. Launch the DJI VISION App and start bind it with your smartphone then enter the camera preview

page.

4. Wait until the Rear LED Flight Indicator blinks green. This means it has initialized and is Ready to

Fly. If it flashes y ellow, it is in Ready to Fly (non

- GPS) mode and will require more careful flight.

Execute the CSC command to start motors.

5. Push the throttle up slowly to take off. Refer to Remote Controller Operation for more details.

6. Shoot photos and videos using the DJI VISION App. Refer to DJI VISION App Usage for more

details.

7. To land, hover over a level surface and gently pull down on the throttle gently to descend.

8. After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or

more until the motors stop.

9. Turn off the smart battery, Range Extender and Remote Controller.

Important:

1. When the Rear LED Flight In dicator blinks yellow rapidly during flight, the aircraft has entered

Failsafe mode. Refer to Failsafe Function (Page 41) for details.

2. A low battery level warning is indicated by the Rear LED Flight Indicator blinking red slowly or

rapidly during flight. Refer to the Low Battery Level Warning Function (Page) for details.

3. View tutorials about flight for more flight information: www.dji.com/phantom2visionplus/training.

Video Suggestions and Tips

1. Work through the check list before each flight.

2. Set the gimbal working mode to Stabilized.

3. Aim to shoot when flying in Ready to Fly only.

4. Always fly in good weather, such as sunny or windless days.

5. Change camera settings to suit you. These include FOV, photo format and exposure compensation.

6. Take flight tests to establish flight routes and scenes.

7. Push the sticks gently to make aircraft movements stable and smooth.

Failsafe Function

The Phantom will enter Failsafe mode when its connection to the Remote Controller is lost. The Flight

Control System will automatically control the aircraft to return to home and land to prevent injury or damage.

Hints and Tips:

Home Point: When the Phantom enters ’Ready to Fly’ from the ‘Ready to Fly status (non

- GPS)’, the GPS

coordinates will be recorded and s et as the home point.KENDRICK SMITH / RAV EN AERIAL IMAGERY

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23 1. When Remote Controller signal is lost, the aircraft will return to the recorded home point coordinates

and land.

2. Home point coordinates are used to calculate the horizontal distance of the aircraft (shown as

“Distance” on the GUI of the DJI VISION App).

3. After successfully record ing the home point, rear LED flight indicators blink fast green.

When will Failsafe Activate?

1. The Remote Controller is powered off.

2. The Phantom has flown out of effective communication range.

3. The signal between the Remote Controller and the Phantom has been blocked.

4. There is interference causing a signal problem with the Remote Controller.

Failsafe Procedure

Initiating the Failsafe mode from different flying statuses will results in different landing processes.

Ready to Fly (non

- GPS)

---- Automatic landing

The Flight Control System will keep the aircraft level during descent and landing. It may be drift duri ng the

descent and landing process.

Ready to Fly

---- Automatic go home and land

The Flight Control System will automatically control the aircraft to fly back to the home point and land.

The below demonstrates the complete Ready to Fly Failsafe landing process.



### Important:

1. To ensure the aircraft successful return to home after Failsafe activation, aim to only fly in Ready to

Fly mode.KENDRICK SMITH / RAV EN AERIAL IMAGERY

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24 2. The Phantom will automatically descend during the Failsafe process if there are less than 6 GPS

satellites detected f or more than 20 seconds.

3. The aircraft cannot avoid obstacles during Failsafe.

Hints and Tips: Quickly flipping the S2 switch of the Remote Controller from top to bottom 5 times or more

will reset the current aircraft position as a new home point. Rear LED flight indicators will blink green rapidly

when successful.

Failsafe on the DJI VISION App

The DJI VISION App will provi de information during Failsafe

Regaining Control During Failsafe Procedures

Low Battery Level Warning Function

The low battery level warning alerts users when the battery is close to depletion during flight. When it

appears, users should promptly fly back and land to avoid accidental damage. The Phantom 2 Vision+ has

two levels of low battery level warning. The def ault battery level warning thresholds are 30% (low battery

level warning) and 15% (critical low battery level warning) respectively.KENDRICK SMITH / RAV EN AERIAL IMAGERY

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25 

### Flight Limits

All unmanned aerial vehicle (UAV) operators should abide by all regulations from such organizations as the

ICAO (International Civil Aviation Organization) and their own national airspace regulations. For safety

reasons, the flight limits function is enabl ed by default to help users use this product safely and legally. The

flight limits function includes height, distance limits and No Fly Zones.

In Ready to Fly mode, height, distance limits and No Fly Zones work together to manage flight. In Ready to

Fly ( non

- GPS) status, only height limits work and flights cannot go higher than 120m.KENDRICK SMITH / RAV EN AERIAL IMAGERY

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26 References : Default parameters in Assistant Software are compliant within the definitions of class G ruled

by ICAO. (Refer to Airspace Classification to get more details). As each country has its own rules, make

sure to configure these parameters to comply w ith these rules before flying.



### Max Height & Radius Limits

Max Height & Radius limits flying height and distance. Configuration can be done in the Phantom 2 Vision+

Assista nt (Figure 57). Once complete, your Phantom will fly in a restricted cylinder (Figure 58).



### Preparing the Remote Controller

The Phantom 2 Vision+ Remote Controller is a wireless communication device using the 5.8GHz frequency

band. Remote Controller and Phantom are paired before delivery. The Remote Controller is set to Mode 2

by default. This can be adjusted in the PHANTOM RC Assistant Software. See Using the PHANTOM RCKENDRICK SMITH / RAV EN AERIAL IMAGERY

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27 Assistant Software for details. You can also adjust the power of your Remote Controller according to

national regulations. Please refer to Compliance Version Configuration

.

Definitions:

Compliance Version: The Phantom 2 Vision+ Remote C ontroller is compliant with CE and FCC (see the

FCC ID) regulations.

Operating Mode: Mode 1 and Mode 2 refer to different channel mappings.

Mode 1: The right stick controls throttle.

Mode 2: The left stick controls throttle.

Hints and Tips:

The Range Extender and Phone Holder are already mounted on the Remote Controller. Twist the Phone

Holder to face outwards and fix it in position for mobile device installation.

Warning: Large smartphones and tablets are not recommended for the Phone Holder as they do not fit.

The Remote Controller

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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28 Power on the Remote Controller

Set S1 and S2 switches to the upper most position and pla ce all sticks in the mid

- point.

Toggle power swi tch to the right to switch on. The Remote Controller will then beep.

If it is set to CE compliance, then there will be one beep while the FCC compliant version will beep twice.

The Power LED will blink green quickly indicating that the solid green. Remote Controller and receiver are

binding. Once binding is completed, the Power LED will change to a steady green. Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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29 Warning:

If the low voltage warning alert sounds

( refer to Remote Controller Power LED Status Information for details), charge batteries as

soon as possible.

For long term storage, be sure to remove the batteries from Remote Controller.

Dispose of batteries properly.

Remote Controller Power LED Status Information Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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30 

### Warning:

The Remote Controller Power LED will blink red and sound an alert when the voltage drops below 3.9V and

automatically power off after 3 seconds. This process will repeat even if you power cycle the Remote Controller.

If this low voltage warning occurs dur ing flight, it will cause the Phantom to enter Failsafe mode which cannot be

interrupted (refer to Failsafe Function for details).

Charging batteries immediately after the low voltage warning (3.9V

- 4.5V) is strongly recommended.

Antenna Orientation

Keep the antennas pointing skyward, perpendicular to the ground for maximum com munication range

during flight. Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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31 Remote Controller Operation Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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32 The Remote Controller default is set to Mode 2 by default.

Move the Stick: The control stick is pushed away from the central position.KENDRICK SMITH / RAV EN AERIAL IMAGERY

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33 Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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34 Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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35 1. Warning:

In ‘Ready to Fly’ mode, the Phantom will hover when all sticks are released.

In ‘Ready to Fly (non

- GPS)’ the Phantom will lock its altitude but will not have

horizontal positioning

.

Linking the Remote Controller and Receiver

A 5.8G receiver is built in to the Phantom 2 Vision+. Its link button and indicator are located on the

underside of the phantom, as shown in Figure 27.

The Remote Controller and the receiver are paired before delivery. Only use this button if you have

rep laced your Remote Controller or receiver. Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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36 

### Linking Procedures:

Power off the Remote Controller, power on the aircraft.

You will see the link indicator blinking red.

Press the link button with a thin object and hold until the link indicator blinks yellow.

Release the link button.

Power on the Remote Controller. Link indicator will switch off,

showing that a link has been successfully established. Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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37 

### Link Indicator

Compliance Version Configuration

As power levels vary between regulators, the Phantom Remote Controller’s

power output can be adjusted by twisting the potentiometer knob (Figure 28) on

the back of the Remote Controller using a flathead screwdriver.

For CE compliance, set the Remote Controller to CE with a full counterclockwise turn.

For FCC compliance, set the Remote Controller to FCC with a full clockwise turn.

Be sure to follow relevant local regulations.

Compliance can be configured using the PHANTOM RC Assistant Software.

Select CE compliance version in Assistant Software to set it, or do the same with

FCC compliance version

. Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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38 Important:

Turn the potentiometer knob gently to avoid damage.

CE compliant devices have an effective communication range of

400 meters in open spaces due to power limitations.

FCC compliant devices have an effective range of 800 meters in open spaces.

Watch your flight distance as the Phantom 2 Vision+ will ente r Failsafe

M o

de (auto

- landing or go home and land) if it flies beyond the relevant range limits.

Always follow local laws and regulations.

Hints and Tips:

1. It is recommended to use a Φ2.4mm flathead screwdriver for adjustments.

2. There is another potentiometer for reserved use.

Preparing the Range Extender

The Phantom 2 Vision+ Range Extender is a wireless communication device that

operates within the 2.4 GHz frequency band. It is used to extending the effective

range of communication between a Smartphone and the Phantom 2 Vision+.

In an open, unobstructed area, the transmission distance can reach up to 700 meters.

This can be reduced by trees, buildings and other sources of the same frequency. Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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39 Before every fli ght, it is suggested that you ensure the Range Extender is functioning

properly; otherwise communication issues between the mobile device and the

Phantom 2 Vision+ may occur.

Each Range Extender has a unique MAC address and network name (SSID), details

of which are printed on the label as ‘Phantom_XXXXXX’. The ‘XXXXXX’ represents

the last 6 letters or numbers of the MAC address for the Range Extender.

This can be renamed in the DJI VISION App.

Introduction



### SYSTEM Indicator

Shows Wi

- Fi status of the Range Extender. Formatted: Font color: Blue

Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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40 

### POWER Indicator

Shows power levels of the Range Extender.

Warning:

If the power indicator is a solid red light, the Ranger Extender may stop

working at any moment. Land and recharge as soon as possible.

Binding Reset Button

When the Binding Reset Button is pressed, it will reset and restart the Range Extender.

You will need to bind it with the Phantom 2 Vision+ again to recreate its Wi

- Fi n etwork.

Failure to do so will cause the DJI VISION App to fail to connect with the camera.

Charging the Range Extender

Charge the Range Extender by connecting the charging port to a power supply device

such as a PC or a USB charger using a Micro

- USB c able. Make sure to charge the

Range Extender completely before using it for the first time. This takes 3~4 hours

depending on USB power output.

Hints and Tips:

Make sure the Range Extender has enough power before each use.

Powering on the Range Extend er Formatted: Font color: Blue

Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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41 Flick the power switch to the ON position.

Wait for approximately 30 seconds. The Wi

- Fi signal indicator will blink green

indicating the Range Extender is communicating properly.

Keep the Range Extender facing the aircraft during flight for the best communication link.

Warning: Power off the Range Extender after every flight to avoid discharging the battery.

Checking the Battery Level

The battery level of the Range Extender can be checked in the camera page of the

DJI VISION App as shown below. When the battery level drops to 20% or lower,

the battery level icon will go red as a charging reminder.

Renaming the Range Extender SSID

Make your Range Extender SSID easier to remember by changing its name. Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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42 1. Tap “Rename SSID of Range Extender” in the Settings page. Enter a new name SSID name (e.g.

Phantom_Tom) in the textbox.

2. Tap Blue Check you will be asked to enter the last six characters of your MAC address on the

Range Extender to confirm the change. The MAC address can be found on the sticker on your

Range Extender. If your MAC address is 60:60:1F:60:41:E7, then enter 6041E7.

3. Tap “OK” to confirm the change. The Range Extender will automatically restart and the App will

return to the settings page. Approx imately 30 seconds later, the new network name can be found in

the Wi

- Fi list of your mobile device. Select and connect the renamed network to use the DJI VISION

App.

Binding the Phantom 2 Vision+ and Range Extender

If the connection between the Phantom 2 Vision+ and the Range Extender fails,

or one of them needs to be repaired or replaced, a camera and

Range Extender binding will need to be performed through the DJI VISION App. Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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43 

### Procedures :

Power on the camera and Range Extender.

Approximately 30 seconds later, press the Binding Reset Button

on the Range Extender with a thin object until the SYSTEM Indicator turns off.

The Range Extender will then restart automatically.

Approximately 30 seconds later, the SYSTEM Indicator will start to blink green,

indicating that the Range Extender is ready for binding.

Enable Wi

- Fi on your mobile device then select “Phantom_XXXXXX”

the (SSID of your Range Extender) from the Wi

- Fi net work list.

Figure 37) Run the DJI VISION App then tap

- > Settings

- > General

- > Binding.

(Figure 38) Select ’Scan QR Code’ to scan the camera QR code on the product

packaging. (Figure 39) Get the camera SSID (E.g. FC200_xxxxxx) and the MAC

address. You can also skip the scan and enter the camera MAC address directly

(Figure 38, Figure 40). The MAC address can be found on the camera label.

Tap the blue check the top right corner. The Range Extender should automatically

restart. Binding is now complete

. Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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44 Formatted: Font color: Blue

Formatted: Font color: BlueKENDRICK SMITH / RAV EN AERIAL IMAGERY

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45 Warning:

DO NOT push the Binding Reset Button of the Range Extender unless you are ready to rebind the Range

Extender and the camera. This will unbind your camera so you must follow the steps above for rebinding.

Important:

If both the Phantom 2 Vision+ and the Range Extender are powered on and working normally, you will be

able to find the SSID on the Wi

- Fi list of your mobile device.KENDRICK SMITH / RAV EN AERIAL IMAGERY

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APPENDIX C

SUMMARY OF RAVEN AERIAL IMAGERY SECTION 333 EXEMPTION REQUEST

Raven Aerial Imagery hereby provides pursuant to Part 11 a summar y of its exemption application to

allow commercial operation of the DJI Phantom 2 Vision+ small unmanned system in market

research, precision aerial survey work, mapping , thermal imaging, photography, video and inspections.

An exemption i s requested from the following regulations:

14 C.F.R. Part 21;

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

14 C.F.R. 61.113(a) & (b) ;

14 C.F.R. 61.133(a) ;

14 C.F.R. 91.7(a) ;

14 C.F.R. 91.9(b) (2) & (c) ;

14 C.F.R. 91.103;

14 C.F.R. 91.109(a) ;

14 C.F.R. 91.119;

14 C.F.R. 91.151(a) ;

14 C.F.R. 91.203(a) & (b) ;

14 C.F.R. 91.405(a) ;

14 C.F.R. 91.407(a) (1) ;

14 C.F.R. 91.409(a) (2) ;

14 C.F.R. 91.417(a).