### 1 of 24 9 January 201 6

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

Re: Exemption Request Under 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, Northwind Precision UAS , Inc. seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discusse d in Appendix A. This exemption is derived from a request by DJI , the develope r and operator of the Inspire 1 small Unmanned Aircraft System (“sUAS”). This exemption is also derived from a request from Aeryon Labs Inc. (“Aeryon”), the developer and
operat or of the SkyRanger small Unmanned Aircraft System (“sUAS”). Details of DJI and the Inspire 1 sUAS are described in Appendix B. Details of Aeryon and the SkyRanger sUAS are described in Appendix C. Attached as Appe ndix D is a summary of this request.

T he requested exemption would permit Northwind Precision UAS , Inc. commercial operation of two separate makes and models of sUAS: The DJI Inspire 1 (see details in Appendix B) which weighs 6.5 lbs. with imaging payload , and the Aeryon SkyRanger (see details in Appendix C), which weighs 6 lbs. with imaging payload, to perform Market Research, Aerial Surveys, Mapping, Testing, and Inspections that consist of still photographs, video, and other data taken by onboard sensors. The Inspire 1 and SkyRanger produce high quality imagery and data that can be used independently

- or in the case of surveying and mode ling, can be combined to produce precision digital point clouds, triangle models, and contour maps of the surveyed area. Applications for these sUASs includ e 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, cellular /radio frequency and other antenna inspecti ons, shipping and receiving containers and logistics stations, ranch and cattle operations, snow skiing industry, search and rescue, facility security, Law E nforcement operations, an d forestry. Use of the Inspire 1 and SkyRanger for these inspection and su rveying 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.

Northwind Precision UAS , Inc. is requesting exemption to allow the comme rcial operation of the Inspire

1 and SkyRanger at our designated and approved facilities, farms, mines, and other sites that require

aerial data and analysis for inspections and surveys.

### 2 of 24 As described in further detail below, the reque sted exemption would authorize Northwind Precision UAS

, Inc. to perform market research , analysis, and commercial operations of aerial inspections and surveys using the Inspire 1 1 and the SkyRanger 2 , which at 6 .5 lbs. and 6 lbs. respectively are small in size and powered electrically by battery. The Inspire 1 and SkyRanger will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; it will have automated control features, as described below. The DJI Inspire 1 and Aeryon SkyRanger are designed to be opera ted 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 wit hin 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 an FAA approved or equivalent ground training exam

and authorized DJI training program for the Ins pire 1 . Finally, the airspace in which the Inspire 1 and SkyRanger will operate will be disclosed to and approved, as needed, by the FAA in advance.

Northwind Precision UAS , Inc. respectfully submits that because this small, unmanned aerial system s

– the Inspire 1 and SkyRanger

– 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 ai rcraft systems in the national airspace system.”

The name and address of the applicant are:

Northwind Precision UAS , Inc.

Attn: Mr. Stephan Ceslovas Staniulis

Ph: ( 219 ) 323

- 3427

Email: Stephan.S@nwp

- uas.com Address: 12815 Baker Court

Crown Point, IN 46307



### The primary contact for this application is:

Mr. Stephan Ceslovas Staniulis

1 DJI and its customers have been granted many flight operation certificates to operate the DJI Inspire 1

- including Special Flight Operation Certificates in Canada for commercial use, and Certificates of Waiver or Authorization (COA) in the US for public agency use.

2 Aeryon and its customers have been granted many flight operation certificates to operate the SkyRanger

- including Special Flight Operation Certificates in Canada for commercial use, and Certificates of Waiver or Authorization (COA) in the US for public agency use.

### 3 of 24 The regulations 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; 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.

### 4 of 24 THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Northwind Precision UAS , Inc. submits that grant of this exemption application for use of the Inspire 1 and the SkyRanger in market research, analysis, surveying, mapping and inspections

, commercial and local government u ses that focus on safety, the reduction of overall costs of operations, and the ability to reduce the need for actual “manned” aircraft, thus reducing potential risk to personnel. Both t he Inspire 1 and the SkyRanger would be utilized with a variety of interested parties in the commercial sector to include, but not limited to elec trical power companies, oil/gas companies, railroad, real estate

, forest industry, and Law E nforcement. Tower inspections can be conducted on antenna towers,

electrical transmi ssion lines, and wind turbine towers without having to have a manned aircraft fly over the top of a tower, because the Inspire 1 can perform that function, and it reduces the actual climbing of the tower by a technician to inspect the tower. In the forest industry the Inspire 1 and SkyRanger can assist ranchers with locating cattle, utilize sensor equipment to locate too much undergrowth thus reducing forest fire activity, uses in recreation with snow skiing locating skiers and identifying potential

avalan che concerns. Oil pipeline inspections and railroad inspections could reduce the amount of resources needed to conduct these inspections and identify at early stages potential hazards reducing

risk. The Inspire 1 and SkyRanger would be used in law enforc ement, large event venues, and physical security protection providing additional tools with the purpose of keeping the public safe will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of sUASs

into the nati onal airspace system (“NAS”) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain sUASs may operate safely 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:

● The sUAS’s size, weight, speed, and oper ational capability;

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

● 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 mus t 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).

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

modifi cation in order to allow approval, to supply conditions for the safe operation of the sUAS . DJI and Aeryon

welcome the opportunity to consult with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may requ ire modification.

### 5 of 24 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 the significant public be nefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Airworthiness of the Inspire 1

A critical element of the exemption application involves evidence of the airworthiness of DJI sUAS including the Inspire 1

. DJI believes that it has shown compliance through a history of granted flight operations and succes sful flights

- including many operations with public agencies. The list of granted applicants includes: Utility/Energy/Infrastructure Companies, Real Estate and Construction Companies, Federal, State and Local Law Enforcement Agencies, and closed

- set Film and Media Companies

– A total of nearly 600 granted 333 Exemptions for the DJI Inspire 1

. In Canada, DJI has obtained Special Flight Operations Certificates (SFOCs) from Transport Canada and its customers have received multiple certificates to perform dem onstration, research and development, public and commercial operations. The criteria set forth in the certificates granted specify the substantive showings of the device’s safety and fitness for operation to ensure that the FAA has sufficient basis to eva luate the aircraft’s safety 3

. The Inspire 1 also has a significant set of automated features to ensure safe takeoff, flight and landing in many conditions, further details of operation can be found in Appendix B.

Airworthiness of the SkyRanger

A critical element of the exemption application involves evidence of the airworthiness of Aeryon sUAS including the SkyRanger. Aeryon 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: Michigan State Police, US Navy S PAWAR , Mass Development (Joint Base Cape Cod), Unmanned Experts (NIJ Partnership), Western Washington University, Aetos (via Northwest Michigan Coll ege), University of Alaska Fairbanks, University of New Mexico, Kansas State University, and Virginia Tech University. The SkyRanger has also successfully completed the Department of Homeland Security RAPS Trial in 2013. In Canada, Aeryon has obtained 19 Special Flight Operations Certificates (SFOCs) from Transport Canada over 5 years and its customers have received multiple certificates to perform demonstration, research and development, public and commercial operations.

The criteria set forth in the ce rtificates granted 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 4

. The Inspire 1 also has a significant set of automated features to ensure s afe takeoff, flight and landing in many conditions, further details of oper ation can be found in Appendix C

.

3 DJI can submit under confidentiality the following documents in support of this exemption application for the Inspire 1: 1) DJI Inspire 1 User Guide (Exhibit 1) which includes Safety and PreFlight Checklists; and 2) Training Manual (Exhibit 2).

4 Aeryon can submit under confidentiality the following documents in support of this exemption application for the SkyRanger: 1) Aeryon SkyRanger User Guide (Exhibit 3) which includes Safety and PreFlight C hecklists; and 2) Training Manual (Exhibit 4).

### 6 of 24 Mandatory Operating Conditions

Grant of the exemption to Northwind Precision UAS , Inc. 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:



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



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



### ● Operations to be conducted over private or controlled

- access property.



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

.



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



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



### ● VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (NM).



### ● Cylinder walls may be expand ed by observer with ability to control aircraft.



### ● Operations to occur during daylight hours.

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

● All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds.

● Operator will file a NOTAM for each flight.

● All required permissions and permits will be obtained fro m territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

● All operations will include one pilot for flight control and one observer for VLOS enhancement of surrounding area near the aircraft

Operator Requirements

Northwind Precision UAS , Inc. respectfully proposes that operator requirements should take into

account the characteristics of the se particular sUAS s . Certain sUASs, such as the DJI Inspire 1 and SkyRanger , are charact erized by a high degree of pre

- programmed control and various built

- in technical capabilities that limit the potential for operation outside of the operating conditions set forth above. The Inspire 1 and SkyRanger sUAS s also provide many built

- in functiona l and safety features to assist the operator in safe and reliable operation. 5

The DJI Inspire 1 and Aeryon pr ovide two semi

- autonomous flight modes using a point

- and

- click map and video interface. The user clicks on a map to direct the Inspire 1 or SkyRa nger 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 Inspire 1 and SkyRanger operate only within user

- specified flight parameters. All flight operations are GPS controlled making t he system easy to navigate. T he flight control system s also employ 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 dur ing a programmed flight and take

immediate control.

5 As of January 2016, Aeryon staff and customers have performed over 7811 flights, logging 873 hours of flight time with the SkyRanger with both development and release versions. The previous generation produc t, Scout, achieved over 7197 flights and 839 hours of flight time globally by Aeryon and its customers. This is a significant amount of flight time collected to understand and refine the Aeryon sUAS products. The DJI Inspire 1 is widely used by the comme rcial sUAS community with over 600 approved 333 exemptions and is nearly impossible to provide any accurate metrics.

### 7 of 24 Additional automated safety functions and safety enhancing features of the Inspire 1 and SkyRanger 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.

Given the above mentioned safety features, Northwind Precision UAS , Inc. proposes that operators o f

the Inspire 1 and SkyRanger should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:



### ● H ave 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;



### ● H ave completed DJI ’s and Aeryon’s authorized training program for operation and maintenance

of the sUAS.

Northwind Precision UAS , Inc. 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 when the mandatory operating conditions specified a bove 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

associ ated with the grant of airmen’s certificates. 49 USC §44701 (f).

In summary, Northwind Precision UAS , Inc. seeks an exemption from the FARs s et forth above and in Appendix D to allow market research and commercial operations of a small unmanned vehicle in surveying, mapping, inspections, and areas pertaining to commercial and government uses. Each industry has their own uses for this technology either by the use of cameras to obtain a visual inspection (i.e. electrical transmission lines, oil/gas pipel ines, bridges, towers, law enforcement needs, etc.), the use of various sensor equipment to identify certain chemicals in the air, certain biological identifiers in plants or animals, heat/cold sensors, radiation sensors, etc., in order for the customer to collect d ata with the ability to analyze the information for their mission and tasking. As the small unmanned vehicle operator, we would work with the various commercial and government users on their goals and objectives based on their criteria and missi on. Northwind Precision UAS , Inc. would in turn work with the customer, create a plan to accomplish their mission, and establish the proper flight protocols following the FAA guidelines. This creates an environment of safe flight operations by a certified operator using the specific s UAS this exemption has identified.

Approval of the exemption allowing commercial operations of the Inspire 1 and SkyRanger for surveying, mapping, and inspections operations will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles carrying significant

### 8 of 24 quantities of combustible fuels, and a multi

- person crew in piloting and observation r oles. These operations require transit to and from the location of the activity, and often take place in congested environments including proximity to physical obstacles and/or presence of the general public. By contrast, the Inspire 1 weighs 6 .5 lbs and SkyRanger weighs 6 lbs, inclu ding payloads and use a battery for power, are carried to/fr om the area of activity, remove the need for airborne pilots/observers, and

poses significantly 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 carr ying capacity, speed at which these sUAS operate , and the fact that it carries no explosives or other dangerous materials, the Inspire 1 and SkyRanger p ose no threat to national security.

The operation of the Inspire 1 and SkyRanger for market research, surveying, mapping and inspection operations in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting Northwind

Precision UAS , Inc. from the requirements of Part 21.

The Inspire 1 ’s and SkyRanger’s 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 t heir showing of an equivalent level of safety as it may relate to the requirement for a pilot’s license, provide more than adequate justification for the grant of the requested exemptions allowing Northwind Precision UAS , Inc. commercial operation of the I nspire

1 in market research, surveying, analysis, mapping and inspection operations.

Very truly yours,

Mr. Stephan Staniulis

Northwind Precision UAS , Inc.

### 9 of 24 APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Northwind Precision UAS , Inc. requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the Inspire 1 and SkyRanger sUASs :

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 Inspire 1 and SkyRanger aircraft ( 6.5 lbs. and 6 lbs. respectively ) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 S ubpart 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 cr iteria demonstrates that the Inspire 1 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 I nspire 1 weighs 6 .5 lbs. fully loaded and SkyRanger weighs 6 lbs. fully loaded. They 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 b oth 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 aircr aft, 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 Inspire 1 and SkyRanger provide at least an equ ivalent, and most likely exceed 6

, a level of saf ety 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 i n Appendix B , Appendix C and throughout this document highlight the design intentions towards safety and reliability on Inspire 1 and SkyRanger

.

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

Regulation 45.23 provides: (a) Each operator of an air craft must display on that aircraft marks consisting of the

6 An Aeryon internal report compares the crash kinetic energy dissipation rate of a commercial airline versus the Aeryon Inspire 1. The report found the MTTF of Inspire 1 needs to only be > 2.3 hours to equal the energy dissipation of the gold standard commercial aircraft. Transport Canada, has issued a report on low energy RPA and determined the Aeryon Scout to be well below the peak ene rgy level of 12J/cm2 on impact, since the SkyRanger and Inspire 1 are similar in construction it

could be considered to be below this threshold as well.

### 10 of 24 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 lett er. (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 display on that air craft 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.

Regulation 91.9(c) provide s: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

.

The Inspire 1 and SkyRanger have no entrance to the cabi n, 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 Inspire 1 and SkyR anger are currently marked with a fixed label containing DJI Inspire 1 or Aeryon SkyRanger serial placard measuring approximately 1.5” x 0.5” as well as a serial number located under the removable camera payload. Northwind Precision UAS , Inc. is prepared to mark the inspection system with the name of the organizatio n and location or origin and fulfil l 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 identificatio n 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 private pilots to non

- commercial operations. Unlike a conventional aircraft that carries a pilot, pass engers, and cargo, the Inspire 1 and SkyRanger in this ca se are 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 comp ensation or hire.

Northwind Precision UAS , Inc. respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. DJI ’s Inspire 1 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 Inspire 1 and SkyRanger have an all

- digital software platform with advanced features previously

restricted to fu ll size unmanned aircraft. Automated features and advanced fly

- safe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility.



### ● Plan your flight or fly ad

- hoc: The system can autonomously fly a programmed flight path or fly

in manual mode



### ● 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.

### 11 of 24 Flight safety is a priority, no mat ter the operating environment or project. The Inspire 1 and SkyRanger

offer 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 and Aeryon p latform s lead other sUAS with respect to safety.



### ● Intelligent fault handling: The system automatically detects potential issues

- with configurable automated response behavior such as a return

- home

- and

- land routine



### ● Automatic pre

- flight checks: The system self

- calibrates all of its sensors and performs self

- tests prior to takeoff to check for errors



### ● No

- fly zones: The system has the ability to set up visual no

- fly zones



### ● Self

- monitoring: Monitoring battery levels, in

- flight wind speeds, and other system and

e nvironmental conditions are automatically handled by the system



### ● Battery communication: 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 autom ated safety functions and safety enhancing features of the Inspire 1 and SkyRanger include the following:



### ● Auto detection of lost GPS warns the pilot and initiates an immediate l anding.



### ● Low battery on the Inspire 1 and SkyRanger triggers a Nonf atal Warnin g alarm to return home, land and replace the battery



### ● Very low battery on the SkyRanger triggers a Fatal Error alarm and initiates an emergency high speed descent landing.



### ● If the Inspire 1 or SkyRanger detects a lost

- link to the base

- station the vehicle wil l perform its

pre

- defined Non

- Fatal Condition Response.

Given these safety features, Northwind Precision UAS

, Inc. proposes that operators of the Inspire 1 and SkyRanger should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:



### ● H ave successfully completed, at a minimum, FAA private pilot ground instruction and passed

the FAA Private Pilot written examination or FAA

- recognized equivalents including ICAO issued commercial, private license and ground school;



### ● H ave completed DJI ’s and Aeryon’s training program for operation of the sUAS.

Northwind Precision UAS , Inc. 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 whe re 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 Inspire 1 and SkyRanger 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 Inspire 1 and SkyRanger (given their 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 saf ety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a).

### 12 of 24 14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may oper ate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the Inspire 1 and SkyRanger without an airworthiness certificate, no standard will exist for airworthiness of the Inspire 1 or SkyRan ger . Given the size of the aircraft and the previous COAs issued for DJI ’s Inspire 1 and Aeryon’s SkyRanger , an equivalent level of safety will be achieved by ensuring compliance with the DJI and Aeryon manuals prior to each flight.

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

The regulation provides: No person may operate a U.S.

- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination

thereof.

Given the size and configuration of the Inspire 1 and SkyRanger, they have 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 th e flight manual ( see

, e.g.

, Inspire 1 User Guide, Exhibit 1 and SkyRanger User Guide, Exhibit 3 ) 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 reg ulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

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 Inspire 1 and SkyRanger User Guide (Exhibit 1 and Exhibit 3 respectively ) under the ‘Getting Ready to Fly’ section. The PIC will take all actions including reviewing weather, flight battery requirements, landing and tak eoff 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 f or flight instruction unless that aircraft has fully functioning dual controls.

The Inspire 1 and SkyRanger are remotely pilo ted aircraft and by design, do not have fully functional dual controls. Flight control is accomplished through the use of a contr ol box that communicates with the aircraft via radio communications. The flight plan is either manually controlled through point

- and

click touchscreen navigation or pre

- programmed as way points or an AutoGrid 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 for the Inspire 1 and Exhibit 4 for the SkyRanger , 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

### 13 of 24 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 , Exhibit 4 and through the use of experienced and qualified pilots familiar with the Inspire 1 and SkyRanger

.

14 CFR § 91.119: Minimum Safe Alti tudes

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, except over open water or sparsely populat ed areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Inspire 1 and SkyRanger 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 l ow 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 Inspire 1 and SkyRanger are built. Also, no fl ight 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 o r rotorcraft weighing far more than 6 .5 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 operat ions 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 Inspire 1 batteries provide approximately 20 minutes of powered flight. SkyRanger batteries provide approximately 50 minutes of powered flight. Wi thout an exemption from § 14 CFR 91.151, the SkyRanger sUAS s flights would be limited to approximately 20 minutes in length and Inspire 1’s total flight time would be insufficient . 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.

Northwind Precision UAS , Inc. believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowin g 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 o perates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting the SkyRanger’s flights to 20 minutes would greatly reduce their utility. In the unlikely event that the Inspire 1 or SkyRanger should run out of fuel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.

Northwind Precision UAS , Inc. believes that an equivalent level of safety c an be achieved by maintaining

7 minutes of reserve fuel, which would be more than adequate to return the sUAS s to their planned landing zone from anywhere in its operating area.

### 14 of 2 4 The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and

10808.

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

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and current

airworthiness certificate. (b) 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.

The Inspire 1 fully loaded weighs approximately 6 .5 lbs. The SkyRanger fully loaded weighs approximately 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 n o 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 regula tion. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 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 o perator 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 Inspire 1 and SkyRanger are nearly maintenance free, they perform automatic pre

- fli ght 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 flight and at predefined intervals as part of the Maintenance Schedule in the User Guide (see Exhib it 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, command station, radio repeater station)

An equivalent level of safety will be achie ved because the sUAS s are small in size, will carry no external payload, will operate only in restr icted predetermined areas and are not a complex mechanical devise. As provided in the attached User Guide (System Maintenance section), the operator of Inspi re 1 and SkyRanger 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.

### 15 of 24 The Inspire 1 ’s and SkyRanger’s 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 Non

- Fatal Conditioned Response (NFCR), depending on the type of failure.

### 16 of 24 APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

Northwind Precision UAS , Inc. Corporate Overview : Northwind Precision UAS , Inc. is a n Indiana

based Veteran

- owned Engineering , Consulting and Services company

. Northwind Precision UAS is

focused on developing and integrating specialized payloads in direct support of Law Enforcement, Fire and Rescue, Search and Rescue, Government and Military requirements

. Northwind Precision UAS professionals have also supported technical UAS operations in Afghanistan in support of Operati on Enduring Freedom, as well as Operation Iraqi Freedom. Our Consulting and Services Division supports Residential and Commercial Real Estate, Construction and Inspections.

DJI sUAS systems have been approved by the FAA for research COAs and have a demonstrated a safety track record. Many customers from milita ry, to education to police and even commercial operations have been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces.

Inspire 1 Overview : DJI unmanned systems have been used in Commercial and Residential construction survey s, Agriculture, Utility/Energy/Infrastructure inspections, and provide Intelligence,

Surveillance and Reconnaissance for State and Local Law Enforcement.

The DJI Inspire 1 can carry payloads up to 600 g. The Inspire 1 flies with a maxi mum wind threshold o f

25 M.P.H. for sustai ned winds and wind gusts up to 3 5 M.P.H.. What is unique about the DJI Inspire 1 is the system automatically compensates for wind versus relying on the operator’s ‘sense of feel’ for what the impact of the wind is at the altitude the system is flying. The end result is a system capable of gathering high quality ae rial intelligence at high wind thresholds. A trait that is imperative for many aerial inspection operations.

The Inspire 1 has an operational rang e of up to 5 km (2.7 NM).

All flight operations are GPS controlled making the system extremely easy to navigate. At any point if the operator is not explicitly commanding the system to move, the system automatically holds its GPS position (i.e. GPS hold for reliable location hover). The flight control system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the most stability of any system in its class

- regardless of the wind.

The DJI Inspire 1 can be operated in both semi and fully autonomous flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking on the map to create a preplanned flight path. In semi

- autonomous mode, the operator clicks on the map and the DJI Inspire 1 automatically flies to the point on the map where the operator is pointing. Pre

- mi ssion waypoints, Landing zone points and flight area dimensions can all be entered during preflight ensuring the Inspire 1 operates only within specified parameters.

The DJI Inspire 1 includes many advanced safety features that makes the Inspire 1 the saf est choice

for both urban and non

- urban environments. Built

- in intelligent fault handling allows the Inspire 1 to detect a system fault while in the air, and to automatically fly back to its take

- off location and land. Faults

that can be detected include: loss of communication; pre

- set wind thresholds exceeded; and low battery levels. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. And before every take

- off automated flight checks ensure the system is flight ready before it takes off.

### 17 of 24 The DJI Inspire 1 can be operated entirely by a touch

- screen, m ap based interface. This means t he operator only needs to command the system where to go, and the system does all the flying for the operator. Maps can be saved and flight plans can be made or recalled with no internet connection required.

Inspire 1 Operating Manual

- System user manual available upon request.

Physical Characteristics

Measurements

– 438 x 451 x 301 mm ( 17.25 x 17.75 x 11.85 in.)

Weight (without payload)

– 2.9kg (6.39 lbs

. )

Fuel

– Lithium polymer batteries are self

- contained high duration systems with “SMART” intelligence

on

- board. This includes cycle charge times, locations, GPS antenna, chemical management, and real

time data feeds to ensure maximum flight duration and sub

- syste m safety processes. Charging is done

in the included DJI Battery charger and can be charged via standard wall outlet, or via a vehicle.

Landing style/type

– Autonomous vertical lift

Propulsion System

● Engines

– The Inspire 1 is powered by 4 electric brush less DC motors.

● Batteries

– Lithium polymer batteries are self

- contained high duration systems with SMART intelligence on

- board. This includes cycle charge times, locations, GPS antenna, chemical management, and real

- time data feeds to ensure maximum fligh t duration and sub

- system safety processes. Charging is done in the included DJI Battery charger and can be charged via standard wall outlet, or via a vehicle.

Performance Characteristics

● Maximum Service Ceiling

– 1 4700 ft. MSL

● Maximum Endurance

– 20 minu tes

● Maximum Range

– 3 km

● Weather Minimums

-

● Winds Maximum

– 25 MPH sustained, 3 5 mph gusts

● Minimum ceiling: 500 ft

● Minimum visibility: 1 SM

● Icing conditions

– no icing conditions

● Precipitation

– no visible moisture

Maintenance

– The UAS is nearly maintena nce free, it performs automatic pre

- flight 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 flight.

Pre

- flight checklist includes:

● Visual inspection of the airframe

● Visual inspections of rotor integrity

● Check charge of all batteries (aerial vehicle, command station, radio repeater station)

Reliability

– The system is designed for maximum reliability and to maintain performance over its life. The only components experience routine wear are rotors, batteries, motors, and legs. Battery and motor conditions are monitored by the system with deviations reported to the operator.

### 18 of 24 Contact with other objects during flight may cause other components, particularl y rotors, and motor arms, to become damaged. Damaged components are likely to be detected during the full visual inspection of the airframe performed before each flight. Structural damage affecting flight characteristics will be detected by on

- board sensor s.

The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations. Automatic pre

- flight checks prevent the UAV from takin g off if such conditions are present; or, if the condition is detected during flight, the system will trigger a Fatal Conditioned Response.

Fault Tolerance

- The key feature of the UAV fault tolerance is its mechanical simplicity. It uses four

fixed pitched rotors, each mounted on a separate motor. No control surfaces or other actuators are required for the UAS to fly. Any component failure detectable by the system will be reported to the control station and will cause the UAV to perform a Fatal Condi tion Response (FCR) or Non

- Fatal Conditioned Response (NFCR), depending on the type of failure.

Command and Control Systems

The Inspire 1 Ground Control station allows the operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second.

Displayed on GCS:

● UAS Position

● Navigation Route

● UAS Posi tion

● UAS Altitude

● UAS Heading

● North Seeking Arrow

● Range to Target

● Calculated target position

● Date/time

● Sensor heading and orientation relative to UAS

On

- board Flight Instruments

– The UAV is equipped with an Inertial Navigation System (3

- axis

gyroscope, 3

- axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for precision AGL altitude measurement.

On

– board computer systems

– The UAS is equipped on

- board computer systems to monitor (sensors, battery, etc.), control (speeds, altit ude, position, etc.), and communicate (control, telemetry, etc.).

On

- board guidance and navigation equipment

– The UAS can operate autonomously; it does not require any input from ground

- based equipment, or from the pilot to hover in place.

Frequency All ocations

– 9 00 MHz, 2.4 GHz, 5.8 GHz

Flight termination link

– to prevent a “fly away” or other potenti ally dangerous situation a Return To Home Capability is available to the operator at the GCS.

Takeoff and Landing

– The Inspire 1 has vertical lift aut onomous launch and recovery. A Landing Zone

### 19 of 24 “LZ” is designated by the operators and identified in the GCS software. For launch procedures the aircraft will takeoff and hover 3 meters directly above the LZ and hold until furt her operator instruction is give n. The aircraft will automatically adjust for wind during this period.

Navigation System

– Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be crea ted before and during flight operation creating specific locations and sequences for the aircraft.

Redundant Systems

– The UAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal system performance , a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure.

Emergency Procedures and System Failures Failure Handling

– The UAS has extensive failure detection and handling capabilities. All failures are

deeded to be either fatal or non

- fatal. Failures classified as fatal result in a Fatal Condition Response (FCR); and failures classified as non

- fatal result in a Non

- Fatal Condition Response (NFCR).

Sensor Failure

– Failure of on

- board flight instruments/sensors will degrade the UAS performance and will result in either a FCR or a NFCR, depending on their severity. If the UAS becomes unstable due to sensor failure, it will stop all four motors and free fall to avoid a fly away condition.

Moto r Failure

– The UAS flight performance will degrade significantly if one or more motors fails.

Airframe Failure

– If airframe is damaged in ways that impacts flight characteristics, the UAS will

behave similar to if an on

- board flight instrument failed.

Navigation System Failure

– In a navigation system failure, degraded GPS will result in FCR or NFCR ‘s depending on failures.

Power Failure

– A complete battery failure which results in power loss to the UAS will result in degraded flight performance.

Lo w Battery Condition

– Operator will be alerted of a low battery condition and will land the aircraft

as soon as able.

Line

- of

- Sight Loss

– All flight operations will be conducted with the UAS within visual sight of the pilot. If the pilot’s view becomes o bstructed and line

- of

- sight is lost, the pilot may instruct the UAS to hover in place until line

- of

- sight is reestablished, to return to the take

- off position, or to land at the current position.

Security

An onboard GCS scanner searches for and maintains the cleanest channels for command and control.

### 20 of 24 APPENDIX C

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

Aeryon sUAS systems have been approved by the FAA for research COAs and have a demonstrated a safety track record. The Aeryon sUAS platforms were the first to officially fly at one of the FAA’s UAS Test Sites (UAF Alaska). Many customers from military, to education to police and even commercial operations have been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces.

SkyRan ger Overview : Aeryon unmanned systems have been used to fight terrorism in Iraq, Afghanistan and Nigeria, monitor hostile borders between Saudi Arabia and Yemen, ensure the safety of world leaders at the G50 Nuclear Summit in Seoul, escort a fuel tanker an d ice breaker into a remote Alaskan community, monitor wildlife on the Aleutian Islands, map remote communities in South America, keep our highways clear and safe; and provide volumetric analysis for open pit mines.

The Aeryon SkyRanger can carry payloads up to 600 g. The SkyRanger flies with a maximum wind threshold of 40 M.P.H. for sustained winds and wind gusts up to 55 M.P.H.. What is unique about the Aeryon SkyRanger is the system automatically compensates for wind versus relying on the operator’s

‘se nse of feel’ for what the impact of the wind is at the altitude the system is flying. The end result is a system capable of gathering high quality aerial intelligence at much higher wind thresholds. A trait that is imperative for many aerial inspection op erations.

The SkyRanger has an operational range of up to 3 km (1.6 NM) with the standard offering and up to 5 km (2.7 NM).

All flight operations are GPS controlled making the system extremely easy to navigate. At any point if the operator is not explicitly commanding the system to move, the system automatically holds its GPS position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for the most sophisticated camera targeting available. The flight cont rol system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the most stability of any system in its class

- regardless of the wind.

The Aeryon SkyRanger can be opera ted in both semi and fully autonomous flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking on the map to create a preplanned flight path. In semi

- autonomous mode, the operator clicks on the map and the Aeryon

S kyRanger automatically flies to the point on the map where the operator is pointing. Pre

- mission waypoints, Landing zone points and flight area dimensions can all be entered during preflight ensuring the SkyRanger operates only within specified parameters.

The Aeryon SkyRanger includes many advanced safety features that makes the SkyRanger the safest

choice for both urban and non

- urban environments. Built

- in intelligent fault handling allows the SkyRanger to detect a system fault while in the air, and to a utomatically fly back to its take

- off location and land. Faults that can be detected include: loss of communication; pre

- set wind thresholds exceeded; and low battery levels. In addition, the operator can create no fly zones or maximum flight ranges and

al titudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. And before every

take

- off automated flight checks ensure the system is flight ready before it takes off.

The Aeryon SkyRanger can be operated entirely by a touch

- screen, map based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. Maps can be saved and flight plans can be made or recalled with no internet connection required.

### 21 of 24 SkyRanger Oper ating Manual

- System user manual available upon request.

Physical Characteristics

Measurements

– 40” diameter deployed, 20x10” folded

Weight (without payload)

– 2.4kg (5.3 lbs)

Fuel

– Lithium polymer batteries are self

- contained high duration systems with “SMART” intelligence

on

- board. This includes cycle charge times, locations, GPS antenna, chemical management, and real

time data feeds to ensure maximum flight duration and sub

- system safety processes. Charging is done in the included Aeryon Battery c harger and can be charged via standard wall outlet, or via a vehicle.

Landing style/type

– Autonomous vertical lift

Propulsion System

● Engines

– The SkyRanger is powered by 4 electric brushless DC motors.

● Batteries

– Lithium polymer batteries are self

- con tained high duration systems with SMART intelligence on

- board. This includes cycle charge times, locations, GPS antenna, chemical management, and real

- time data feeds to ensure maximum flight duration and sub

- system safety processes. Charging is done in th e included Aeryon Battery charger and can be charged via standard wall outlet, or via a vehicle.

Performance Characteristics

● Maximum Altitude

– 1500 ft.

● Maximum Endurance

– 50 minutes

● Maximum Range

– 3 km

● Weather Minimums

-

● Winds Maximum

– 40 MPH sustained, 55 mph gusts

● Minimum ceiling: 500 ft

● Minimum visibility: 1 SM

● Icing conditions

– no icing conditions

● Precipitation

– no visible moisture

Maintenance

– The UAS is nearly maintenance free, it performs automatic pre

- flight checks and the

failure o f any check will prevent take

- off. Checks which cannot be done by the system will be performed by a qualified person prior to each flight.

Pre

- flight checklist includes:

● Visual inspection of the airframe

● Visual inspections of rotor integrity

● Check charge of all batteries (aerial vehicle, command station, radio repeater station)

Reliability

– The system is designed for maximum reliability and to maintain performance over its life. The only components experience routine wear are rotors, batteries, motors, a nd legs. Battery and motor conditions are monitored by the system with deviations reported to the operator.

Contact with other objects during flight may cause other components, particularly rotors, and motor arms, to become damaged. Damaged components are likely to be detected during the full visual inspection of the airframe performed before each flight. Structural damage affecting flight characteristics will be detected by on

- board sensors.

### 22 of 24 The UAV system detects numerous conditions which may make flyin g unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations. Automatic pre

- flight checks prevent the UAV from taking off if such conditions are present; or, if the condition is detec ted during flight, the system will trigger a Fatal Conditioned Response.

Fault Tolerance

- The key feature of the UAV fault tolerance is its mechanical simplicity. It uses four fixed pitched rotors, each mounted on a separate motor. No control surfaces or other actuators are required for the UAS to fly. 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 Non

- Fatal Conditioned Response (NFCR), depending on the type of failure.

Command and Control Systems The SkyRanger Ground Control station allows the operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen

prov ides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second.

Displayed on GCS:

● UAS Position

● Navigation Route

● UAS Tail Number

● UAS Position

● UAS Altitude

● UAS Heading

● North Seeking Arrow

● Range to Target

● Calculated target position

● Date/time

● Sensor heading and orientation relative to UAS

On

- board Flight Instruments

– The UAV is equipped with an Inertial Navigation System (3

- axis gyroscope, 3

- axis magnetometer, GPS receiver, and static pressure se nsor) and a sonar sensor for precision AGL altitude measurement.

On

– board computer systems

– The UAS is equipped on

- board computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry , etc.).

On

- board guidance and navigation equipment

– The UAS can operate autonomously; it does not require any input from ground

- based equipment, or from the pilot to hover in place.

Frequency Allocations

– 900 MHz, 2.4 GHz, 5.8 GHz, custom

Flight termination link

– to prevent a “fly away” or other potentially dangerous situation a flight termination link is available to the operator at the GCS.

Takeoff and Landing

– The SkyRanger has vertical lift autonomous launch and recovery. A Landing

Zone “LZ ” is designated by the operators and identified in the GCS software. For launch procedures the aircraft will takeoff and hover 3 meters directly above the LZ and hold until further operator instruction is given. The aircraft will automatically adjust for w ind during this period.

### 23 of 24 Navigation System

– Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and during flight operation creating specific locations and sequences for the aircraft.

Redundant Systems

– The UAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal system performance, a single sensor malfunction is likely to

resu lt in degraded performance rather than leading to a catastrophic failure.

Emergency Procedures and System Failures Failure Handling

– The UAS has extensive failure detection and handling capabilities. All failures are

deeded to be either fatal or non

- fata l. Failures classified as fatal result in a Fatal Condition Response (FCR); and failures classified as non

- fatal result in a Non

- Fatal Condition Response (NFCR).

Sensor Failure

– Failure of on

- board flight instruments/sensors will degrade the UAS performance and will result in either a FCR or a NFCR, depending on their severity. If the UAS becomes unstable due to sensor failure, it will stop all four motors and free fall to avoi d a fly away condition.

Motor Failure

– The UAS flight performance will degrade significantly if one or more motors fails.

Airframe Failure

– If airframe is damaged in ways that impacts flight characteristics, the UAS will

behave similar to if an on

- boar d flight instrument failed.

Navigation System Failure

– In a navigation system failure, degraded GPS will result in FCR or NFCR ‘s depending on failures.

Power Failure

– A complete battery failure which results in power loss to the UAS will result in deg raded flight performance.

Low Battery Condition

– Operator will be alerted of a low battery condition and will land the aircraft

as soon as able.

Line

- of

- Sight Loss

– All flight operations will be conducted with the UAS within visual sight of the pilot. If the pilot’s view becomes obstructed and line

- of

- sight is lost, the pilot may instruct the UAS to hover in place until line

- of

- sight is reestablished, to return to the take

- off position, or to land at the current position.

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

### 24 of 24 APPENDIX D

SUMMARY OF NORTHWIND PRECISION UAS SECTION 333 EXEMPTION REQUEST

Northwind Precision UAS

, Inc. hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the Inspire 1 and SkyRanger small unmanned system s in market research, analysis, precision aerial survey work, mapping and inspections . An exemptio n is 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).