Electronic Submission

March 3, 2016

U.S. Department of Trans portation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein referred to as FMRA) and 14 CFR Part 11, Mr . Russell Burdge hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of UAS for the acquisition of aeria l data, so long as such operations are conducted within and under the conditions outlined herein or as may be established by

the FAA.

As detailed in this document and the attach ed Appendix of UAS, th e requested exemption would permit the operation of UAS platforms previously approved by the FAA for commercial operations in the United States. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Tr ansportation’s responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) Reform Act.

The name and address of the applicant is:

Mr. Russell Burdge

1568 Meadowbrook Court Niceville, Florida 32578

Tel: 850-585-1431 Email: russburdge@gmail.comRegulations from which the exemption is requested:

14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b ) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CF R 417(a) & (b)

AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants th e FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UAS, from the requiremen t that all civil aircraft must have a current

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of th is section or any sections §44702-44716 of this title if the Administrator finds the exemption in the pub lic interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists th e Secretary in determining whether UAS may operate in the national airspace system without creating a hazard to the user, the public,

or a threat to national secur ity. In making this determinati on, the Secretary must consider:

 The UAS’ size, weight, speed and operational capability;

 Whether the UAS operates within the visu al line of sight of the operator;

 Whether the UAS operates out side of highly populated ar eas and away from close proximity to airports.

Reform Act 333(a). If the Secretary determines that a UAS “may operate safely in the national airspace system, the Secr etary shall establish requirements for the safe operation

of such aircraft in the nationa l airspace system.” Id. 333(c).BACKGROUND ON RUSS ELL BURDGE

Russell Burdge provides 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, a nd contour maps of the survey ed area. Applications for the UAS include, but are not limited to:

 Environmental monitoring

 Real Estate and Construction Inspection

 Inspection, remote sensing and aerial survey of civil infrastructure

 Transportation planning studies

 Forestry and agriculture

Mr. Burdge’s use of the UAS for these inspection and surveyi ng applications reduces the need to operate conventional aircraft, providing data more safely, quickly, accurately, economically, and with reduced impacts to public health and the environment.

Mr. Burdge believes in a risk-based and t echnology agnostic appro ach to operations in

the national airspace. Approval for any operati on should be based on an analysis of

the specific risks associ ated with the fully integrated soluti on, rather than the

individual components.

UAS AND OPERATIONAL DESCRIPTION

Mr. Burdge seeks to commercially ope rate a UAS weighing less than 55 pounds including payload in the Un ited States for the purpose of acquiring aerial data. The Appendix attached to this exemption petition lists the aircraft that Mr. Burdge contemplates operating. In prior, similar exemptions the Secretary has approved every UAS platform included in the Appendix.

As the operator of these aircraft, Mr. Burdge is committed to the following conditions and limitations on its operations. Mr. Burdge understands that failure to comply will be grounds for the immediate suspension or rescission any exemption granted.

1. Operations are limited to the UAS listed in the Appendix when weighing less than 55 pounds including payload.

2. Operations for the purpose of closed-set motion pictur e and television filming are not contemplated.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the aircraft be operated at airspeeds greater than the maximum aircraft operating airspeed reco mmended by the aircraft manufacturer.4. The aircraft will be operated at an altitu de of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC) at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s U.S.

driver’s license.

6. All operations will utilize a visual observer (VO). The ai rcraft will be operated

within the visual line of sight (VLOS) of the PI C and VO at all times.

7. All operating documents needed to operate the UAS and will be accessible during UAS operations and made available to the Administrator upon request. The operator will also present updated and revised documents if it petitions for

extension or amendment.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. re placement of a flight critical component, will undergo a functional test flight prior to conducting further operations.

9. Mr. Burdge is responsible for maintaini ng and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the

UAS is in a conditi on for safe flight.

11. Mr. Burdge will follow the UAS manuf acturer’s maintenance, overhaul, replacement, inspection, and life limit re quirements for the aircraft and aircraft

components.

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

13. The PIC will hold a UAS flight training certificate, in some cases training directly from the aircraft manufacturer, and a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

government.

14. Measure will not permit any PIC to opera te unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated to acquire aerial data, incl uding evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Measure will operate flights for the purposesof training Measure PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC’s ability to safely operate the UAS.

15. UAS operations will not be conducted dur ing night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).

16. The aircraft will not operate within 5 nau tical miles of an airport reference point (ARP) as denoted in the current FAA Ai rport/Facility Dir ectory (AFD) or for airports not denoted with an ARP, the cen ter of the airport symbol as denoted on the current FAA-published aeronautical ch art, unless a letter of agreement with that airport’s management is obtaine d or otherwise permitted by a COA.

17. The aircraft will not be operated less th an 500 feet below or less than 2,000 feet horizontally from a cloud or wh en visibility is less than 3 statute miles from the

PIC.

18. If the UAS loses communications or loses its GPS signal, the aircraft will return to a pre-determined location.

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

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power or fuel for the aircraft to conduct the intended operation a nd to operate after that for at least five minutes or with the reserve power or fu el recommended by the manufacturer if

greater.

21. All operations shall be c onducted in accordance with an ATO-issued COA if the blanket COA does not cover the intended operation.

22. All aircraft operated will 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 will be as large as practicable.

23. Documents used by Mr. Burdge to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be

available to the PIC at the Gr ound Control Station of the UAS any time the aircraft is operating.

24. The aircraft will remain clear and give way to all manned aviation operations and

activities at all times.25. The UAS may be operated by the PIC from a moving device or vehicle; however, specific requests will be ma de via subsequent COA.

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

a. Barriers or structures ar e present that sufficientl y protect nonparticipating persons from the aircraft or debris in the event of an accident; or

b. The owner/controller/operato r of any vessels, vehicles or structures has granted permission for operating closer to t hose objects and the PIC has made an assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

27. The PIC, VO, operator trainees or esse ntial persons will not be considered nonparticipating persons under this exemption.

28. All operations conducted ove r private or controlled -access property will be conducted with the permission from the pr operty owner/controll er or authorized representative. Permission from propert y owner/controller or authorized representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation th at transgresses the lateral or vertical boundaries of the operational area as de fined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the Nati onal Transportation Sa fety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, establishes the pr ocedural requirements for th e issuance of airworthiness certificates as required by FAR §91.203(a)(1). Given the size and limited operating area

associated with the aircraft to be utili zed by Mr. Burdge, an ex emption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act (49 USC §44701(f)) and

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificat e, upon consideration of the size, weight, speed, operational capability and proximity to air ports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airw orthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe , or safer, than a conventional aircraft operating with an airworthiness certificate without the restric tions and conditions proposed.

14 CFR 45.23(b): Marking of the aircraft

This regulation requires that certain experime ntal, provisionally certifie d aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high “limited”, “restricted,” “light-sport,” “experi mental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, 2 inch lettering may be impos sible. Measure will mark the UAS as practicable.

14 CFR 61.113(a) & (b): Private pilot privil eges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current ope rations by requiring the pilot operating the aircraft to have completed a UAS flight-training course. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled. The area of operation is controlled and re stricted, and all flights are planned and c oordinated in

advance. The risks associated with the operation of the UAS are so diminished from the

level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b).14 CFR 91.7(a): Civil ai rcraft airworthiness

The regulation requires that no person may operate a civil aircraft unle ss it is in airworthy

condition. As there will be no airworthiness certificate i ssued for the aircraft Mr. Burdge contemplates operating, should this exemption be granted, no FAA regulatory standard will exist for determining airworthin ess. Given the size of the aircraft and the operational restrictions put on the aircra ft, an equivalent level of safety will be provided.

14 CFR 91.9(b)(2): Civil aircraft flight manual, mark ing and placard requirements

The UAS, given its size and c onfiguration 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 e quivalent level of safety will be maintained by keeping the Operating Ma nuals at the ground cont rol point where the pilot flying the UAS will have immediate access to it.

14 CFR 91.103: Preflight action

This regulation requires each pilot in comma nd take certain actions before flight to ensure the safety of flight. An exemption is needed from this re quirement, as the pilot will take separate preflight actions, includ ing checking for weather conditions, checking flight battery or fuel requi rements, checking takeoff and landing distances, and all other actions in the Operating Manual and safety checklists. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight instruction

Section 91.103 provides that no person may opera te a civil aircraft (except a manned free balloon) that is being used fo r flight instruction unless that aircraft has fully functioning dual controls. By design, UAS do not have fully functional dual controls. Flight control is accomplished through the use of a control box th at communicates with the aircraft via radio communications. The equivale nt level of safety is provid ed by the fact that neither a pilot nor passengers will be carried in the airc raft, the ability to control the UAS via radio signals from the controller and by the size and speed of the aircraft.

14 CFR 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will never operate at altitude higher than 400 AGL and all operations will occur during daylight hours under Visual Mete orological Conditi ons (VMC) only.The equivalent level of safety will be achieved given the size, weight and speed of the UAS as well as the location where it is opera ted. No flight will be taken without the permission of the property owne r. Because advance notice to the property owner and any onsite personnel, as well as the precautions outlined below, all a ffected individuals will be aware of the planned flight operations.

Flight operations will be conducted at least 500 feet from all non- participating persons (persons other than the pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, unless operati ons do not present an undue hazard.

The UAS will remain within vi sual line of sight of the PI C or VO. Flight operations will

be conducted at least 5 miles fr om an airport. The PIC or VO will provide notification to the local Flight Standards District Office and airport controlle r of all operat ions within 5 miles of an airport. The FAA will have adva nce notice of all operations through the filing

of notices-to-airmen.

Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS proposed herein, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft op erating at or below 500 feet AGL. In addition, the low-altit ude operations of the UAS w ill ensure separation between these UAS operations and the operations of conv entional aircraft that must comply with

Section 91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available befo re departure.” As th e UAS may not have a barometric altimeter, but instead a GPS altit ude read out, an exemption may be needed. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of

the UAS during daylight hours in visual fli ght rules (VFR) conditions to continue until 90 percent of remainin g battery power or fuel reserves remain. Mr. Burdge seeks the requested relief because without an exempti on from Section 91.151(a)(1), the flight time

duration of the selected aircraft will be reduced and seve rely constrain the practicality of any aerial acquisition of data that Mr. Bu rdge proposes to conduct pursuant to this

Petition.10 The technical specifications of the proposed UAS, their Operations Manuals, and Mr. Burdge’s proposed operating limitations, ensure that Mr. Burdge will safely operate

the selected aircraft during daylight hours in VFR conditions until 90 percent of remaining battery power or fuel reserves remain.

14 CFR 91.203(a) & (b): Carry ing civil aircraft certif ication and registration

The UAS has no cabin, cockpit or pilot station and is opera ted without an onboard pilot. Therefore, there is no ability or place to ca rry certification and re gistration documents or to display them on the UAS. An equivalent le vel of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescr ibed in subpart E of th is part and shall betw een required inspections, except as provided in paragra ph (c) of this section, have discrepancies repaired as prescribed in part 43 of this ch apter...,” and others sh all inspect or mainta in the aircraft in compliance with Part 43.

Given that these sections a nd Part 43 apply only to aircra ft with an airworthiness certificate, these sections will not appl y to Mr. Burdge. Maintenance will be accomplished pursuant to the User Guide or Op erating Manual. An equivalent level of safety will be achieved because the UAS i s limited in size and will carry a small payload and operate only in re stricted areas for limited peri ods of time. If mechanical issues arise, the UAS can land immediatel y and will be operating from no higher than

400 feet AGL. The PIC will ensure that the UAS is in working order prior to initiating flight, perform required maintenance and keep a log of any maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances safety while reducing risk. Manned aircraft in certain application such as pipeline monitoring create a greater risk because the aircraft are much larger and carry an onboard human pilot. In contrast, a UAS weighing 55 pounds or less will carry no passengers or crew and, theref ore, will not expose them to the risks asso ciated with manned aircraft flights. In addition, additio nal streams of aerial data will allow large

commercial entities to make decisions about how to best deploy ground resources and ensure the safety and cost-eff ectiveness of their operations.11 EQUIVALENT LEVEL OF SAFETY

Mr. Burdge proposes that the ex emption requested herein apply to civil aircraft that have

the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher le vel of safety to operations

under the current and proposed regulatory structure.

PRIVACY

All flights will occur over private or contro lled access property with the property owner’s prior consent and knowledge. Images or video ta ken of individuals will have consented to being filmed or otherwise th ey will be made anonymous.

NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which they will operate, our petition pr esents no national security issue.

FEDERAL REGISTER SUMMARY

Docket No.: No. FAA-2016- ___________ Petitioner: Mr. Burdge Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1 ), 409(a)(2), 417(a) and (b) of Title 14, Code of the Fede ral Regulations (14 CFR). Description of Relief Sought: Mr. Burdge is seeking an exemption to conduct

commercial acquisition of aerial data usi ng unmanned aircraft systems.

Based upon the foregoing, Mr. Burdge requests that the FAA grant it the necessary exemptions under Section 333 of the FAA Reform Act as requested herein to allow for commercial operations of UAS within the United States.

Sincerely,

Russell Burdge

1568 Meadowbrook Court Niceville, Florida 32578

850-585-143112 APPENDIX A

UAS DESCRIPTION

The following UAS to be used is as follows but not limited to providing they are within the scope of the exemption granted by the F AA. Mr. Burdge may update or revise the operating documents. It is the operator’s re sponsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. Mr. Burdge must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If Mr. Burdge determines that any update or revision would affect the basis upon which the FAA granted this exemption, then Mr. Burdge must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisi ons to the operating documents.

Parrot Bebop 2

Width: 382 mm

Length: 328 mm

Height: 89 mm

Cruise Speed: 10 m/s

Approx. Max Air Speed: 18 m/s

Minimum Airspeed: 0 m/s

Maximum Range: 1.2 miles / 0.8 km

Multi-Rotor Weight w/ battery: 500 g

Payload Capacity: Not designed fo r payload, total weight is 500 g

Maximum Take-off Weight: 500 g

Autonomous capabilities: Auto-Return to Home if lost communications or lost data link; Auto-Loiter, Auto-Landing, Emergency Auto-Landing if Low Power Emergency

Maximum Wind Speed: 38 mph

Normal Flight Time: 25 minutes13 Power Source:

Lithium polymer or Lithium ion batteries. Ch arging of batteries can be completed via: standard wall outlet, direct connection to ve hicle battery, or via the vehicle’s cigarette lighter.

Propulsion System:

The UAS described herein is powered by elec tric direct drive brushless DC motors.

Autonomous Flight:

The key element of the UAS described he rein is the system’s autopilot which automatically compensates for wind versus relying on the operator’s sense of feel for what the impact of the wind is at launch or at the altitude the system is flying. All flight operations are GPS and aut opilot controlled making the system extremely easy to operate and navigate. The autop ilot serves in a “cruise control” like manner limiting the operator from placing the UAS described herein in an unusual attitude while maintaining desired altitude. At any point if the signal between the Ground Control Station (GCS) and the aircraft is lost, the aircraft will return to the designated home station and loiter or land as preprogrammed.

Landing styles/types – Aided or Autonomous:

In “Aided” landing mode the autopilot con tinues to assist the pilot in maintaining altitude and stability as the pilot controls the UAS to the desired landing location.

In “Autonomous” Landing mode without hum an intervention, the UAS autopilot can land the aircraft consistently within a narrow and limited landi ng area, even in crosswinds. The autopilot intelligently mana ges the landing patter n and glideslope to minimize overshoot or undershoot. If signal is lost and cannot be r eestablished for some reason, the autopilot will initially re turn to home location and loiter.

Onboard Flight Instruments:

The UAS described herein are equipped with an Inertial Navigation System (3axis gyroscope, 3axis magnetometer, GPS receiver, and static pressure sensor and secure radio link to the operator).

Onboard Computer Systems:

The UAS described herein are equipped with onboard computer systems to monitor, control, and communicate the essentia l fight status to the PIC and VO.

Frequency Allocations:

2.4 GHz OR 5.8 GHz14 Navigation System:

Specific maps can be downloaded to the di splay screen (such as air sectional and geographic maps) which are overlaid w ith GPS positional data. Waypoints can be created before and during fli ght operations, thus creating sp ecific locations and flight sequences for the aircraft. During flight waypoints can be clic ked and dragged to change their location and/or altitude.

Command and Control Systems:

All missions will be flown in using a handhe ld radio transmitter in conjunction with ground control station (GSC) computers pr oviding PIC and VO all of the essential flight data via telemetry from th e UAS at least once per second.

GCS Data Displayed:

 UAS Barometric Altitude

 UAS Bearing

 UAS Heading

 UAS Ground Speed

 UAS Climb Rate

 UAS Flight Time

 UAS Data Link Quality

 UAS Position

 GPS Number of Satellites

 UAS Battery Level

 Altitude

 Local Time

 Direction to Home

 Active Flight Mode

 UAS Status

 Pitch/Roll/Yaw Horizon

Emergency Procedures and System Failures:

Sensor Failure- Failure of onboard flight instrume nts/sensors will degrade the UAS performance and will result in either a fatal critical response or a non-fatal critical response, depending on the nature and severity. If the UAS becomes unstable due to sensor failure, this may result in loss of performance or feat ures but still allow for stable Pilot in Command flight, an automated landi ng or in extreme cases a fatal response.

Motor Failure- This will cause a fatal response in th e UAS flight performance if one or15 more motors fails.

Airframe Failure- Depending on the nature and severity, this may result in decreased flight performance or a fatal response.

Navigation System Failure- In a navigation system failu re, degraded GPS will result in a response warning to the pilot where-by the system would be flown in manual mode. This will result in degraded GPS position performance, manual Pilot in Command flight

will not be effected.

Power Failure - A complete battery failure which re sults in power loss to the UAS will result in a fatal response.

Low Battery Condition - Operator will be alerted of a low battery condition and will

land the UAS as soon as able.

Critical Battery Condition - Operator will be alerted of a Critical low battery

condition and will land the UAS as soon as ab le, the UAS will begin to descend at a

controlled rate.

Line of Sight Loss - All flight operations will be c onducted with the UAS within visual sight of the pilot. If the pilot's view beco mes obstructed and line of sight is lost, the pilot may instruct the

UAS to hover in place until line of sight is re-established, to return to the takeoff position, or to land at the current position.

Security - The system and communication links are encrypted by the manufacturer's proprietary software.