August 18, 2015

Falcon Air Vistas, LLC

Jeffrey D Barlett, Chief Pilot/Founder 

690 SW 1st Ct. #1903

Miami, FL 33130

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” or “Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part

11, Falcon Air Vistas, LLC seeks an exemption from the Federal Aviation Regulations

(“FARs”) listed below and discussed in Appendix A to allow it to operate three different

small Unmanned Aircraft Systems (collectively, the “sUAS”): the DJI Phantom Vision+

v3.0, the DJI Phantom 3, and the DJI Inspire 1. Falcon Air Vistas, LLC is a startup

photography company that plans to use the sUAS for aerial photography and videography

in various industries. These industries include commercial and residential real estate,

where they intend to provide services primarily for homeowners, realtors, home builders,

home contractors, and/or home inspectors to use in real estate marketing and inspections

of home exteriors. Additionally, Falcon Air Vistas intends to provide similar services for

miscellaneous industries including weddings and sporting events. The company also

plans to use sUAS in the agriculture industry to include aerial surveys, mapping, and data

collection collected via onboard sensors.

The safety and public benefits of using sUAS for commercial photography/videography,

agricultural data collecting, and similar services are significant. The sUAS reduce the

need to operate manned aircraft, provide more accurate data in a manner that is more

safe, economical and efficient, and with a reduced impact on the environment. Because

Falcon Air Vistas, LLC plans to utilize the sUAS in many of its public infrastructure and

related projects, the operations will also directly translate to measurable savings for local,

state and federal agencies and ultimately, taxpayers.
Operations pursuant to 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. At 2.73 pounds for the Phantom Vision+, 2.82 pounds for the

Phantom 3, and 6.47 pounds for the Inspire 1, including payload, the proposed sUAS are

small in size and are powered electrically via small, rechargeable, lithium batteries. The

sUAS have extensive automated control features, redundant systems, and integrated failsafes, and will be operated under controlled conditions and at low altitudes in airspace

that is limited in scope.

Though the sUAS may safely be operated by one person, flight operations performed

pursuant to this exemption will consist of at least two people: a pilot-in-command (the

“PIC”) and visual observer. The PIC is responsible for the direct and safe operation of the

sUAS, monitoring its status and flight dynamics while maintaining visual line of sight

and keeping the flight within the manufacturer’s specified limits in terms of wind, flight

range, battery life, etc. The observer will be responsible for monitoring the airspace for

other aircraft and hazards, advising the PIC before and during flight of all such observed

risks, and monitoring the controlled operating area. Falcon Air Vistas, LLC's chief pilot

is currently a commercial 747 pilot with over 10,000 hours of international experience.

Individuals acting as the PIC will complete manufacturer-approved training specific to

the sUAS. The PIC will be a certificated airman with equal or better than recreational

pilot privileges and limitations.

Because the sUAS will be used in lieu of comparatively higher risk operations now

conducted with fixed wing and rotary manned aircraft, the FAA can have confidence that

Falcon Air Vistas, LLC’s operations will achieve at least an equivalent level of safety and

fulfill the Secretary of Transportation’s responsibilities under Section 333(c) of the

Reform Act to “establish requirements for the safe operation of such aircraft systems in

the national airspace system.”

Applicant Information

The name of the applicant is:

Falcon Air Vistas, LLC

The primary contact for this application is:

Jeffrey Barlett

Chief Pilot, Falcon Air Vistas, LLC

690 SW 1st Ct., Unit 1903

Miami, FL 33130 

Ph: (786) 600-2993

Fax: (815) 364-4281
Exemptions Requested

Falcon Air Vistas, LLC respectfully requests exemptions from the following regulations:

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14 C.F.R. Part 21, Subpart H; 14 C.F.R. § 91.7;

14 C.F.R. § 91.9(b)(2);

14 C.F.R. § 91.113; 

14 C.F.R. § 61.113(a), (b); 14 C.F.R. § 61.133(a);

14 C.F.R. § 91.119(c);

14 C.F.R. § 91.151; 

14 C.F.R. § 91.203;

14 C.F.R. § 91.405(a) and (b);

14 C.F.R. § 91.407(a)(1);

14 C.F.R. § 91.409(a)(1)-(2); and 

14 C.F.R. § 91.417(a).

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Grant of this exemption application for use of the sUAS in precision aerial surveys,

mapping and photography operations will advance the Congressional mandate in Section

333 of the Reform Act to accelerate the introduction of UAS into the national airspace

system ("NAS") if it can be accomplished safely. This law directs the Secretary of

Transportation to consider whether certain UAS may operate safely in the NAS before

completion of the rule making required under Section 332 of the Reform Act. In making

this determination, the Secretary is required to determine which types of UAS 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 UAS's size, weight, speed, and operational capability;

 · Operation of the UAS in close proximity to airports and populated areas;

· Operation of the UAS within visual line of sight of the operator.

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As set forth in Appendix C, Falcon Air Vistas, LLC will operate under similar operating conditions as

those required in the other grants of exemption, in which exemptions for certain FARs was deemed by

the FAA as “not necessary.” Accordingly, Falcon does not request FAA exemption from 14 C.F.R.

45.23(b), 91.103, and 91.109(a). Should the FAA determine that relief from these or any other regulation

is required for the operations proposed herein, Falcon will be happy to submit an amendment to this

request and include justifications for those necessary additional exemptions.
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).3

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

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

defined under §40101 of the Act, from the requirement that all civil aircraft must have a

current airworthiness certificate and those regulations requiring commercial pilots to

operate aircraft in commercial service:

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

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

the Administrator finds the exemption is in the public interest.

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

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 benefit, including enhanced safety and cost savings associated with

transitioning to UAS for aerial photography and the additional above mentioned

industries. Falcon Air Vistas, LLC therefore respectfully requests that the FAA grant the

requested exemption without delay.

Airworthiness of the sUAS

One element of the exemption application involves evidence of the airworthiness of the

sUAS. Falcon Air Vistas, LLC and the manufacturers of the sUAS – DJI – believe that

the sUAS have been shown to be airworthy and compliant with a significant level of

safety. Indeed, as discussed more fully in alternate exemption requests, numerous public

agencies and organizations have received FAA permission to operate DJI models.

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This provision places a duty on the Administrator to not only process applications for exemptions under

Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in

order to allow approval, to supply conditions for the safe operation of the UAS. Falcon Air Vistas, LLC

welcomes the opportunity to consult with FAA staff to address any issues or concerns that this proposal

may raise that they believe may require modification.
To enhance safety, it is also important to note that the sUAS are equipped with automated

features which enhance safe takeoff, flight, and landing in many conditions, further

details of which are provided in the descriptions of both aircraft (Appendices C-E), the

Inspire 1, Phantom Vision +, and Phantom 3 manufacturer manuals, and in the future

revisions to the Falcon Air Vistas, LLC General Operations Manual (“GOM”).

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To maintain airworthiness, Falcon Air Vistas, LLC will follow a strict inspection and

maintenance program. That program is enhanced by several automatic checks performed

by the sUAS. Malfunctions that occur during flight will be detected by the sUAS fault

detection systems, which communicate a fault warning to the PIC to take necessary

action. For certain malfunctions and faults (i.e., lost communications), the sUAS may be

preprogrammed to automatically respond and land either at a designated location (e.g., a

return-to-home or point of take-off) or in-place. In addition, Falcon Air Vistas, LLC will

maintain emergency checklists for proper and safe malfunction responses that will be

used by the PIC during operation of the sUAS. In the event of any malfunction, the sUAS

will undergo all maintenance required by the manufacturer and undergo flight testing

before recommencing commercial operations.

Proposed Operations and Associated Conditions

Falcon Air Vistas, LLC intends to use the sUAS that weigh significantly less than 55

pounds for the purpose of conducting aerial photography. In the aerial photography

context, for example, the sUAS will be used to acquire a unique perspective previously

cost restrictive to the general public. Similarly, Falcon plans to provide survey and data

acquisition-related services with the sUAS to a number of industries. This includes,

without limitation, the inspection of agriculture, such as land surveying and crop analysis.

All of the sUAS operations will occur under tightly controlled conditions on public or

privately owned land at the owner’s request and consent, solely during daylight hours,

and at altitudes well below that which would pose a risk to other aircraft. The operations

will take place in areas away from people, crowds and airports. Moreover, due to the

nature and purpose of the operations, Falcon Air Vistas, LLC anticipates that it will fly

the sUAS at relatively low altitudes and speeds. The risk of interference with another

aircraft is therefore minimal.

Grant of the exemptions to Falcon Air Vistas, LLC will be subject to the conditions listed

in Appendix B, which are based upon the operating conditions required by the FAA's

previous grants of exemptions.

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At the request of the FAA, Falcon Air Vistas, LLC will be pleased to provide, under confidentiality, its

General Operations Manual, currently under revision.
In terms of the specific aircraft Falcon Air Vistas, LLC will use for its operations, all are

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

capabilities that limit the potential for operation outside of the conditions set forth in

Appendix B. They were also designed with internal functional and safety features to

assist the operator in safe and reliable operation. With pre-programmed flights and

manual control, operators can easily maintain separation from manned aircraft operations

and avoid other hazards. In the controlled environment under the operations conditions in

Appendix B, operations will remain within visual line-of-sight (VLOS) and below 400

feet AGL. In addition, Falcon Air Vistas, LLC will obtain a Certificate of Waiver or

Authorization from the FAA Air Traffic Organization to address airspace requirements

and provide notification by a Notice to Airman (NOTAM).

Operator Requirements

Falcon Air Vistas, LLC will use a dedicated staff for the sUAS operations. As a condition

to the grant of the exemptions, Falcon will require that the PIC hold a recreational pilot’s

certificate. The PIC will have accumulated and logged a minimum number of flight

cycles and hours for daytime operations, as necessary. The PIC will also be subject to the

flight review requirements pursuant to the Federal Aviation Regulations (“FARs”).

In addition, the PIC must complete a manufacturer-approved training program for the

sUAS that he or she will operate. This training is specific to each sUAS and familiarizes

the PIC to the operations and limitations of each sUAS. Training will also include

discussions on the basic fundamentals of UAS aerodynamics and technical limitations, as

well as the more general topics of weather, the National Airspace System, and the legal

and regulatory framework.

Falcon Air Vistas, LLC does not believe that certified airmen, medical certificates, and

the related operating conditions, are necessary or required to operate the sUAS. However,

Falcon Air Vistas, LLC will accept these requirements as a condition to the grant of the

exemptions. If, and when, the FAA finds such conditions unnecessary for operations

conducted pursuant to Section 333 exemptions, Falcon Air Vistas, LLC respectfully

reserves the right to amend its operating conditions and request exemptions from the

relevant FARs to operate without such conditions.

Public Interest

The use of the sUAS in lieu of comparatively hazardous operations currently conducted

with conventional fixed wing and rotary aircraft offers a net safety benefit and will

achieve an enhanced level of safety, as mandated under Section 333(c) of the Reform

Act. Approval of this application will also benefit the public interest by allowing better,

safer, and more cost efficient information for Falcon Air Vistas, LLC and the public.

Conventional aerial photography operations using manned aircraft involve heavy aerial

aircraft that must transit from airports to the operational location, carrying significant

amounts of combustible fuel, and a multi-person crew. The nature of aerial photography

magnifies the dangers of using conventional aircraft, as the aircraft fly in unconventional
operations under FAA waivers and at dangerous altitudes in populated and developed

areas. Aerial inspection and analysis by traditional manned aircraft is also often times

impractical because the required altitudes for safe flight can reduce the operative

visibility below levels necessary to obtain meaningful data.

By contrast, use of the sUAS is safe, economical and efficient. The Phantom Vision +

weighs a mere 2.73 lbs, the Phantom 3 weighs 2.82 lbs., and 6.47 lbs. for the Inspire 1,

including payload, the proposed sUAS are small in size and are powered electrically via

small, rechargeable, lithium batteries. They operate on battery power, and are carried

(not flown) to and from the area of activity, removing the need for an airborne crew, and

pose less risk to people and infrastructure on the ground, as well as other aircraft. sUAS

operations also avoid the need for inspection personnel to risk their lives to perform

inspections. If more detailed in-person inspections are required, planners can use

preliminary sUAS data and target areas of concern without putting inspectors and other

individuals at risk in hazardous areas. More frequent, safer, and cost-efficient inspections

by sUAS will also increase safety to the public. In addition, the sUAS can map the

conditions and problem areas of Falcon Air Vistas, LLC projects, assisting personnel to

determine areas of potential hazard and the need for heightened safety measures.

Increased inspections will also help to maintain crops and other agriculture, improving

overall quality while increasing saftey.

No national security issue is raised by the grant of the requested exemptions. Given the

size, load-carrying capacity, speed at which the sUAS operate (the Inspire 1 at 50mph,

the Phantom 3 at 35 mph, and the Phantom Vision + at less than 35 mph), and the fact

that they do not carry explosives or other dangerous materials, the use of the sUAS pose

no threat to national security. In fact, the threat of causing damage to critical national

infrastructure is significantly reduced with the extremely low sUAS weights and limited

operating areas. Any other security concerns are ameliorated by the fact that all

individuals holding a pilot certificate are subject to a security screening by the U.S.

Department of Homeland Security.

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

in Section 333, the Federal Aviation Act,5 the high and equivalent level of safety of the

proposed operations, and the significant public benefit, including enhanced safety and

cost savings to be realized as a result of the use of sUAS for aerial inspection and

photography services. Accordingly, Falcon respectfully requests that the FAA grant the

requested exemption without delay.

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The Federal Aviation Act ("FAAct") expressly grants the FAA the authority to issue exemptions: 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).
Very truly yours,

 Falcon Air Vistas, LLC

Jeffrey D Barlett
APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

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 very small size of the aircraft and the limited operating area

associated with their utilization, it is unnecessary to go through the certificate of

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

6

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 UAS involved.

In this case, an analysis of these criteria demonstrates that the sUAS 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 Inspire 1 weighs 6.47 lbs., the Phantom 3 weighs 2.82 lbs., and the

Phantom Vision 2+ weighs 2.72 lbs., including payload. The sUAS do not carry a pilot or

passenger, will not carry flammable fuel, and will operate exclusively within an area predisclosed and in compliance with conditions set forth herein. Operations under this

exemption will be tightly controlled and monitored by the operator, pursuant to the

conditions set forth in Appendix B, the Falcon Air Vistas, LLC GOM, the

manufacturers’ manuals, and by local public safety requirements.

6

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform

Act that the sUAS provide an equivalent level of safety when compared to aircraft normally used for the

same application. These criteria are satisfied and therefore no exemption is needed. See, e.g., Grant of

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352 at 13-14, 22. Should the FAA determine that

some characteristics of the sUAS fail to meet the requirements of the Reform Act, Falcon Air Vistas, LLC

respectfully requests an exemption.
The FAA will have advance notice of all operations through the filing of NOTAMs.

Receipt of the prior permission of the land owner (or lessee), the size of the aircraft, the

lack of flammable fuel, and the fact that the aircraft is carried to the location and not

flown there all establish the equivalent level of safety. The sUAS provide at least an

equivalent level of safety to that of such operations being conducted with conventional

manned aircraft that would be orders-of-magnitude larger and would be carrying

passengers, cargo, and flammable fuel. The safety features including the redundant sensor

systems, as described in Appendices C-D, the manufacturers’ manuals, and throughout

this document, underscore the importance placed on safety and reliability in the design

and manufacture of the sUAS.

14 C.F.R. § 91.7(a)-(b); Civil Aircraft Airworthiness

Section 91.7(a) requires that a civil aircraft must be in airworthy condition to be operated.

The FAA has concluded that no exemption is required under 14 C.F.R. § 91.7(a) to the

extent that the requirements of Part 21 are waived or otherwise found inapplicable. See

FAA Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352, Exemption

No. 11062, pp. 14-15, 19, 22. Falcon Air Vistas, LLC therefore respectfully requests that

the FAA find the requirements for section 91.7(a) in accordance with the agency’s

determination on 14 C.F.R. Part 21, Subpart H, discussed supra.

The agency similarly found that relief from section 91.7(b) is not warranted, which places

responsibility on the PIC to ensure an aircraft is in a condition safe for flight. See Grant

of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352, Exemption No. 11062, p.

19. To the extent, an exemption is required under section 91.7(a) or (b), Falcon Air

Vistas, LLC respectfully requests that the FAA find compliance with the manufacturer’s

manuals, the Falcon Air Vistas, LLC GOM, and requirements of the grant of exemption,

a sufficient means for ensuring the sUAS are and remain in an airworthy condition.

14 C.F.R. § 91.113; Right-of-Way Rules

Section 91.113 requires that vigilance be maintained by each person operating an aircraft

to see and avoid other aircraft. Unlike manned aircraft, the sUAS pilot is not on-board the

aircraft to observe and avoid other aircraft, operating the sUAS from the ground.

Falcon Air Vistas, LLC's proposed operating conditions will achieve an equivalent or

greater level of safety. All operations will involve two individuals—one certificated

RECREATIONAL pilot (or higher) as the PIC and one visual observer who will monitor

the immediate and surrounding airspace of the sUAS operation for potential obstruction

hazards and other possible intrusions. The sUAS will also be limited to designated areas

below 400 feet AGL and within a virtual fence. Falcon Air Vistas, LLC will notify the

FAA and other pilots of the sUAS operations by NOTAM.

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, passengers, and cargo, the sUAS in this case 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 act as pilot in command of an

aircraft for compensation or hire.

Falcon Air Vistas, LLC respectfully proposes that operator requirements should take into

account the characteristics of the particular UAS. Here, the sUAS have 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 Appendix B and

the exemption application. The small size, endurance, range and payload capacities of the

sUAS mean that no passengers and/or cargo will ever be carried by the aircraft. Rather,

commercial operations will be mostly limited to conducting aerial photography and

agricultural surveying.

Considering these conditions, operating limitations and restrictions, an equivalent level of

safety will be provided by allowing operation of the sUAS by Falcon Air Vistas, LLC

with individuals who possess a valid FAA recreational (or higher) pilot certificate. The

risks associated with the operation of the sUAS (given their small size, speed, operational

capabilities and limitations, and lack of combustible fuel) are so diminished from the

level of risk associated with commercial operations (and even operations permitted with a

private pilot certificate) contemplated by Part 61 with manned aircraft, that allowing

operations of the sUAS as set forth in Appendix B meets and exceeds the present level of

safety provided under 14 C.F.R. § 61.113(a)-(b), and does not call for a commercial pilot

certificate as set forth in § 61.133.

14 CFR § 91.119: Minimum Safe Altitudes

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

91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500

feet above the surface, except over open water or sparsely populated 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 sUAS will not operate at higher than 400 feet AGL. The sUAS

will, however, be operated to avoid congested or populated areas. Because aerial

photography work must be accomplished at relatively low altitudes and at altitudes less

than 500 feet AGL, an exemption from Section 91.119(c) is needed.

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

with which the sUAS are built. Also, no flight will takeoff or land 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 operations conducted with aircraft or rotorcraft weighing far more than the

sUAS, and carrying flammable fuel, any risk associated with these operations will be

significantly less than those currently allowed with conventional aircraft operating at or
below 500 feet AGL. Indeed, the low-altitude operations of the sUAS will maintain

separation from 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 is powered by a removable, rechargeable, lithium-polymer battery that

provides approximately 20 minutes of powered flight. Without an exemption from § 14

CFR 91.151, the Inspire 1 flights by Falcon Air Vistas, LLC would not be permissible.

The Phantom 3 and Phantom Vision + are also powered by a lithium- polymer battery

that provides up to 23 minutes of powered flight. Without an exemption from 91.151 for

it, flights would be limited to 10 minutes in duration. Given the limitations on the

proposed operations and their locations, a longer time frame for flight in daylight VFR

conditions is reasonable.

An exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior

exemption. See Grant of Exemption to Lockheed Martin Corporation, Docket No. FAA2014-10673 (allowing operations 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 operate. The

fact that they carry no pilot, passenger, or cargo also enhances their safety. As does the

fact that the operations will be conducted within the VLOS of the PIC and in a strictly

controlled location. In the unlikely event that the sUAS should run out of fuel, each

aircraft is designed to land on its own (e.g., an auto-land function is initiated upon a

critical battery warning). Given their design, weight and construction material, the risks

are less than contemplated by the current regulation.

For all above mentioned DJI-made sUAS, an equivalent level of safety can be achieved

by maintaining 5 minutes of reserve fuel, which would be more than adequate to return

the UAS to its planned landing zone from anywhere in its operating area given that the

systems are designed to be flown within direct VLOS of the PIC.

Similar exemptions have been granted to other operators and systems. See Docket Nos.

2689F, 5745, and 10673.
14 C.F.R. §§ 91.9(b)(2); 91.203(a)-(b); Carriage of Civil Aircraft Airworthiness

Certificate and Registration

Sections 91.9(b) and 91.203(a)-(b) require an aircraft operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft at all times. Because the sUAS

are small in size and contain no cabin or flight deck, carriage of such documents and

manuals is impossible.

The intent of these regulations is to ensure that the PIC has access to important

documents during flight. Here, an equivalent level of safety is achieved if the PIC has

access to the applicable sUAS manual(s), registration certificate and other required

documents from the Ground Control Station from which he or she is operating the sUAS.

This is consistent with a prior opinion of the FAA Office of the Chief Counsel, and other

grants of exemptions for commercial UAS operations. See Memorandum from Mark

Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, to

John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also FAA Grant of

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352, Exemption No. 11062, pp.

16-18.

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

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

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

except as provided in paragraph (c) of this section, have discrepancies repaired as

prescribed in part 43 of this chapter....” Section 91.407 similarly makes reference to

requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the

issuance of an airworthiness 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.

An equivalent level of safety will be achieved because the sUAS are small in size, will

solely operate in restricted predetermined areas and are not complex mechanical devices.

Falcon will perform all maintenance and inspections in accordance with the

manufacturers’ manuals and any required manufacturer Safety or Service Bulletins. In

addition, the PIC will conduct a pre- flight inspection of the sUAS and all associated

equipment to account for all discrepancies and/or inoperable components, pursuant to the

DJI manufacturer recommendations and the Falcon Air Vistas, LLC GOM. Maintenance

will be performed and verified to address any conditions potentially affecting safe

operation of the sUAS and no flights will occur unless and until all flight critical

components of the sUAS have been found to be airworthy and in a condition for safe

operation. A functional flight test will be conducted following the replacement of any

flight-critical components. As required by the Falcon GOM, the PIC who conducts the

functional test flight will make an entry for the flight in the aircraft records, and all flight

data is automatically recorded by the DJI software.
The Falcon GOM also includes requirements to follow the manufacturer’s

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit

requirements for all applicable components identified by each manufacturer. In addition,

the GOM includes procedures to document and maintain a record of sUAS maintenance

under this grant of exemption. Finally, Falcon will incorporate any additional required

high-time component maintenance and replacement requirements into its GOM that is

requested by DJI and/or the FAA.
APPENDIX B

FALCON OPERATING RESTRICTIONS AND LIMITATIONS

• 1) Operations shall be limited to the following aircraft described in the Falcon

Air Vistas, LLC General Operations Manual (“GOM”): the DJI Inspire 1 model

aircraft, the DJI Phantom Vision+ v3.0, and the DJI Phantom 3 (collectively

“sUAS”). All three of the aircraft weigh less than 10 pounds. Proposed operations

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

• 2) The sUAS shall not be flown at a ground speed exceeding 50 mph or no more

than the maximum permissible operating speed required by the manufacturer,

whichever is less.

• 3) Above Ground Level (“AGL”) altitude shall be restricted to 400 feet, as

indicated by the procedures specified in the GOM. All altitudes reported to Air

Traffic Control (“ATC”) shall be in feet AGL.

• 4) The sUAS shall be operated within Visual Line-of-Sight (“VLOS”) of the

pilot-in- command (“PIC”) and visual observer at all times. The PIC must use

human vision unaided by any device other than corrective lenses.

• 5) All operations must utilize a visual observer. The visual observer may be used

to satisfy the VLOS requirement as long as the PIC maintains VLOS capability.

The observer and PIC must be able to communicate verbally at all times. The PIC

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

the duration of the flight. The PIC must confirm that the visual observer can

perform the functions prescribed in the GOM.

• 6) Any and all additional requirements identified in the exemption grant by the

FAA shall be added to the GOM. The GOM must be maintained and made

available to the Administrator upon request. If a discrepancy exists between the

conditions and limitations in the granted exemptions and the GOM, the conditions

and limitations in the granted exemptions shall take precedence and must be

followed. Otherwise, the operator must follow the procedures outlined in the

GOM.

The operator may update or revise its GOM. It is the operator’s responsibility to

track such revisions and present updated and revised documents to the

Administrator upon the request. The operator must also present updated and

revised documents if it petitions for an extension or amendment of the granted
exemptions. If the operator determines that any update or revision would affect

the basis upon which the FAA granted the exemptions, then the operator must

petition for amendment to its exemptions. The FAA’s UAS Integration Office

(AFS-80) may be contacted if questions arise regarding updates or revisions to the

GOM.

• 7) Prior to each flight the PIC must inspect the sUAS to confirm that it is in a

condition for safe flight. The PIC shall not operate the aircraft if the inspection

reveals a condition that affects the safe operation of the sUAS until the necessary

maintenance has been performed and the sUAS is found to be in a condition for

safe flight. The Ground Control Station (“GCS”) shall be included in the preflight

inspection. All maintenance and alternations must be properly documented in the

aircraft records.

• 8) Any sUAS that has undergone maintenance or alterations that affect the sUAS

operation or flight characteristics (e.g., replacement of a flight critical component)

must undergo a functional test flight in accordance with the GOM. The PIC who

conducts the functional test flight must make an entry in the sUAS aircraft records

of the flight. The requirements and procedures for a functional test flight and

aircraft record entry shall be included in the GOM.

• 9) Falcon must follow the manufacturer’s UAS aircraft/component maintenance,

overhaul, replacement, inspection, and life limit requirements, with particular

attention to flight critical components that may not be addressed in the

manufacturer’s manuals.

• 10) Falcon shall carry out their maintenance, inspections, and record keeping

requirements, in accordance with the GOM. Maintenance, inspection, and

alterations must be noted in the aircraft logbook, including total flight hours,

description of work accomplished, and the signature of the authorized sUAS

technician returning the sUAS to service.

• 11) sUAS technicians must receive and document training referenced in the

GOM.

• 12) sUAS maintenance technicians must make a record entry in the sUAS

logbook or equivalent document of the corrective action taken against

discrepancies discovered between inspections.

• 13) The PIC must possess at least a recreational pilot certificate. The PIC must

also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an
aircraft in which the PIC is rated on his or her pilot certificate.

• 14) Falcon will not permit any PIC to operate the sUAS unless and until that PIC

has demonstrated through the training and currency requirements set forth in the

GOM, that the PIC is able to safely operate the sUAS in a manner consistent with

how the sUAS will be operated pursuant to this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

• 15) Prior to the operation, the PIC must have accumulated and logged a

minimum of 1 hour as sUAS pilot operating the sUAS and three take-offs and

three landings within the preceding 90 days.7

• 16) Prior to operations, a flight demonstration as set forth in the GOM,

administered by an Falcon-approved and qualified-pilot must be successfully

completed and documented. This documentation must be available for review

upon request by the Administrator. The flight demonstration shall be conducted in

accordance with the GOM.

• 17) The sUAS shall not be operated directly over any person, except authorized

and consenting individuals, below an altitude that is hazardous to persons or

property on the surface in the event of a sUAS failure or emergency.

• 18) Operating of the sUAS may be conducted at distances less than 500 feet from

participating persons, vessels, vehicles or structures that perform an essential

function in connection with these special purpose operations. Operations closer

than 500 feet from the PIC, visual observer, operator trainees, and essential

persons, are permitted when operationally necessary; but never so close as to

present an undue hazard, per § 91.119(a).

• 19) Operations of the sUAS may be conducted at distances less than 500 feet

from vessels, vehicles or structures so long as the owner/controller grants such

permission and the operation closer to these objects presents no safety hazard to

nonparticipating persons or property.

7

Training, proficiency, experience-building, and take-off and landing currency flights can be conducted

under this grant of exemption to accomplish the required flight time and 90 day currency. During training,

proficiency, experience building, and take-off and landing currency flights all persons not essential for

flight operations are considered nonparticipants and the operator must operate the sUAS with appropriate.
• 20) Operation of the sUAS must be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures.

• 21) If the sUAS loses communications or loses its GPS signal, the sUAS must

return to a pre-determined location within the security perimeter and land or be

recovered in accordance with the GOM.

• 22) The sUAS must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the GOM.

• 23) The PIC is prohibited from beginning a sUAS flight unless (considering wind

and weather conditions) there is enough power to fly to the intended point of

landing and, assuming normal cruising speed, to fly after that for at least 5

minutes for the sUAS.

• 24) Falcon shall obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver of Authorization (COA) prior to conducting any operation. This COA will

also require the filing of the NOTAM not more than 72 hours in advance, but not

less than 48 hours prior to the operation.

• 25) All aircraft operated in accordance with the requested exemption must be

identified by serial number, registered in accordance with 14 C.F.R. Part 47, and

have identification (N-Number) markings in accordance with 14 C.F.R. Part 45,

Subpart C. Markings shall be as large as practicable.

• 26) Each sUAS must comply with all manufacturer System and Safety Bulletins.

• 27) The preflight inspection required in the GOM shall account for all

discrepancies (i.e., inoperable components, items, or equipment) not covered in

the relevant pre-flight inspection sections of the manufacturer’s operating manual.

• 28) The radio frequency spectrum used for operation and control of the sUAS

must comply with Federal Communication (FCC) or other appropriate

government oversight agency requirements.

• 29) The documents required under 14 C.F.R. §§ 91.9 and 91.203 shall be

available to the operator at the Ground Control Station of the sUAS any time the

aircraft is operating. These documents must be made available to the
Administrator or any law enforcement official upon request.

8

• 30) The sUAS must remain clear and yield the right of way to all other manned

operations and activities at all times (including, without limitation, ultralight

vehicles, parachute activities, parasailing activities, hang gliders, etc.).

• 31) Operations shall occur under Visual Meteorological Conditions (VMC);

flights under special visual flight rules (SVFR) shall not be conducted.

• 32) sUAS shall not be operated from any moving device or vehicle.

• 33) sUAS shall not be operated less than 500 feet below or less than 2,000 feet

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

PIC.

• 34) Operations shall not occur in congested or densely populated areas. The

sUAS may not operate in Class B, C, D or E airspace without written approval

from the controlling authority. Operations will not be conducted within a 5 NM

range of the geographic center of an airport as denoted on a current FAApublished aeronautical chart unless permission has been obtained from the local

control tower or, in the case of a non- towered airport, written notice has been

provided to the airport’s management, and the operation is conducted in

accordance with a NOTAM as required by the grant of this exemption.

• 35) Take-off and landing operations shall be conducted over private and/or

controlled-access property (i.e. no unauthorized persons). Permission from the

landowner, controller, manager or authorized representative will be obtained for

each flight to be conducted.

8

This is consistent with an FAA Office of Chief Counsel Opinion, dated August 8, 2014, and prepared by

Dean E. Griffith, AGC-220, in which it was acknowledged that the intent of 14 C.F.R. § 91.9(b) and

91.203(a), (b) is met if the PIC of the sUAS has access to the aircraft flight manual, registration certificate,

and other required documents from the ground control station from which he or she is operating the sUAS.

Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also FAA Grant of

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352, Exemption No. 11062,pp. 16-18.
• 36) Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA shall

be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours.

Accidents shall be reported to the National Transportation Safety Board (NTSB)

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

• 37) UAS operations may not be conducted during night, as defined by 14 C.F.R.

§ 1.1. All operations must be conducted under visual meteorological conditions

(“VMC”). Flights under special visual flight rules (SVFR) are not authorized.
APPENDIX C

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION DJI Inspire 1

DJI systems have been approved by the FAA for operational COAs and have a

demonstrated safety track record. Many customers from emergency services, to

education to police and even commercial operations for industrial inspections have been

given approval to fly in US, Canada, UK, Australia, Japan, amongst others.

Systems Overview

The DJI Inspire 1 system can carry small payloads up to 2 lbs. The Inspire 1 operates

with a maximum wind threshold of 30 mph for sustained winds and wind gusts up to 35

mph. The system contains many sensors on-board, including gyros, magnetometers,

accelerometers, a barometric pressure sensor and GPS module. This sensor package

provides for default of level flight and does not allow the Inspire 1 to go beyond a 35

degree angle. This eliminates the difficult portion of flying. Meaning that, the operator is

only steering the aircraft (controlling the system’s latitudinal direction) and adjusting its

altitude.

All flight operations are capable of control through GPS, making the system easy to

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

pilot-in-command (“PIC”) to provide manual navigation inputs to assist in landing the

vehicle. At all times through the ground control station, the PIC is able to monitor the

sUAS location through the mapping function and is provided with continuous altitude

information. In GPS mode, the aircraft compensates for wind at the altitude the system is

operating. The end result is a system capable of gathering high quality aerial data at much

higher wind thresholds and is a trait that is imperative for many aerial inspection

operations. While GPS Position Hold mode is one available benefit of the system, it is

not necessary for operation of the aircraft. When GPS is either not available or has

degraded, the PIC may still ensure safe operations.

The Inspire 1 has an operational range of over 1/2 a mile,

9 but was designed to be flown

within the direct Visual Line-of-Sight (“VLOS”) of the operator at all times. All flight

operations take place as a result of direct input by the PIC. Flight adjustments are made

based on a two joystick control system, which allows for very precise movements and

makes it extremely easy to navigate in either Manual or GPS Position Hold.

9

Control transmission signal is rated for in excess of 1⁄2 mile; however, battery flight endurance limits

require the operator to restrict maximum distance to ensure safe return of the sUAS.
In the Manual mode, flight altitude is maintained based on barometric pressure and can

be easily adjusted by the PIC using the left joystick. In the GPS Position Hold mode, the

system is designed to hold its GPS position (and altitude and heading) if the PIC is not

explicitly commanding the system to move. Camera stability is further enhanced by a 3

axis brushless mount to ensure the most stability and least amount of vibration regardless

of the wind speed.

The Inspire 1 provides two semi-autonomous flight modes using a two joystick

configuration and video interface. The user controls the aircraft in either a

Manual/Altitude (Manual) Hold mode or GPS Position Hold mode to the areas of interest

maintaining VLOS of the aircraft at all times. Instrumentation indicating heading,

bearing, altitude, climb rate, horizontal speed, GPS position, battery level, data link, and

GPS accuracy are additional aids made available to the PIC on the ground control station

(“GCS”).

Autonomous operations are also available through pre-programmed flight plans, which

must be uploaded to the aircraft prior to take-off. After departing the ground, the PIC can

execute the preprogramed flight. At any time during the programmed flight, the PIC can

provide inputs to abort and/or override the programmed flight to take immediate control

of the aircraft. For pre- programmed flight, the PIC may utilize additional navigation

settings, including landing zones and flight area (including visual no-fly zones, maximum

altitude, and minimum altitude), so that the sUAS operates only within operator-specified

flight parameters. In other words, Falcon will set up virtual fencing around the

operational area, preventing the Inspire 1 and the PIC from operating outside the planned

flight area, including altitude. This reduces the needed operating area by omitting the

need to factor in additional room for PIC operating error.

The ability to fly in both Manual mode and GPS Position Hold, as well as in a GPS

deprived environment, makes the Inspire 1 one of the safest choices for both urban and

nonurban environments. Many advanced safety features were also designed into the

aircraft, including intelligent fault handling that allows the aircraft to detect a system fault

while airborne, and to automatically fly back to its take-off location and land. For

example, the Inspire 1 detects a loss of GPS and warns the PIC of the status. Other faults

that can be detected include loss of communication, low battery levels, magnetic

anomalies, battery cell imbalances, and temperature fluctuations. Prior to takeoff, the

aircraft completes a sensor self-check. If an error is detected in the pitch, roll or yaw

gyros between the time motors are engaged and takeoff, the aircraft will abort the takeoff

and issue an alarm message. It should also be noted that the PIC can create maximum

flight altitudes so the sUAS cannot go above a pre-set maximum altitude.
Physical Characteristics of the Inspire 1

Dimensions

- Width: 438 mm (17.2in) - Length: 451mm (17.8in) - Height: 301mm

(11.9in)

Weight and payload

- Quadcopter weight w/battery: 2,935g (6.5lbs)

Flight characteristics

- Max climb rate: 5m/s (16.5ft/s)

- Max descent rate: 4m/s (13.1ft/s)

- Max turn rate: Pitch 300 degrees/sec, Yaw 150 degrees/sec

- Approx max air speed: 22 m/s (50mph) 

- Minimum air speed: 0km/h (0mph)

- Launch type: VTOL

- Max altitude ASL 4,500m (15,000ft)

Landing style/type - Autonomous vertical lift

Propulsion System

• Engines - The Inspire 1 is powered by 4 electric direct drive brushless DC 

motors.

• Batteries - The Inspire 1 utilizes a removable, rechargeable, lithium-polymer

battery. The charge level status from the battery on the aircraft is continually

monitored and real time levels are displayed on the control system used by the

PIC. Predefined voltage levels indicate a low battery warning, which provides the

PIC with a warning alarm that is both visual and audible. A critical battery

warning alarm that is both visual and audible is also provided to the PIC. At the

critical battery warning alarm, the aircraft also initiates a safe descent and land at

a pre-determined controlled rate. At any time during the battery warnings, full

control of the aircraft is maintained. However, ignoring the critical battery

warning and overriding the descent feature could result in a critical flight system

failure at which point the aircraft may crash. The battery is charged using a

standard wall charger that is provided with the aircraft.
Maintenance - The Inspire 1 is nearly maintenance free. The airframe has only minimal

bearings per motor and, thus, has very few moving parts. Maintenance consists of

inspections and verification of communications performed by a qualified person prior to

each flight.

Preflight checklist includes but is not limited to:

• Visual inspection of the airframe, including the boom and canopy, side arms,

 landing gear, rotors, and motors;

• Visual inspections of rotor integrity;

• All payload system connections and components;

• Check charge of all batteries (aerial vehicle, control system, video repeater

station).

Reliability – The Inspire 1 is designed for maximum reliability and to maintain

performance over its life. The only components that experience routine wear are rotors,

batteries, motors, and 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.

The Inspire 1detects 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 calibration checks prevent the aircraft from

taking off if such conditions are present. An automatic preflight check also tests the

calibrations of the pitch, rolls and yaw gyros, and aborts the takeoff and delivers an alarm

message, should an error be detected. During flight, a degradation or loss of

communications between the Inspire 1 and the ground station may initiate a failsafe action

of return-to-home, where the aircraft returns to its point of take-off at its current altitude.

At that point, the PIC may land the aircraft, or an auto- land is initiated in which the

aircraft descends at a controlled rate from its current position. For the failsafe action of

Return-To-Home, the Inspire 1 must be in GPS Position Hold mode. Otherwise, the

aircraft is set for a default to auto-land. In the event that the system senses a low battery of

the Inspire 1 during a Return-to-Home action, the aircraft defaults to the auto-land

maneuver.

Command and Control Systems - The DJI GCS, which is used by the Inspire 1 (and

several other DJI models), allows the PIC simultaneous control over the aircraft and any

payloads. The joysticks, located on the GCS, allow for quick navigation and the display

screen provides all essential flight data to the PIC. Telemetry data is transmitted to the

GCS at least once per second. The GCS display screen provides all essential data to the

operator.
Displayed on GCS:

· Barometric Altitude

· Bearing

· Heading10

· Attitude

· Ground Speed

· Climb Rate

· Flight Time

· Data Link

· Position

· GPS Satellite (number of satellites)

· GPS Satellite Precision Dilution of Precision (PDOP)

11

· GPS satellite errors

· Control system battery level

· Inspire 1 battery level

· Local time
· UAS failsafe action

· UAS Status

Onboard Flight Instruments - The Inspire 1 is equipped with an Inertial Navigation

System (3- axis gyroscope, 3-axis magnetometer, 3 axis accelerometers, GPS receiver,

barometric pressure sensor and GPS module).

On-board computer systems - The Inspire 1 is equipped with on-board computer

systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and

communicate (control, telemetry, etc.) with the PIC.

On-board Guidance and Navigation Equipment - The Inspire 1 can operate

autonomously. As described, supra, autonomous flight first requires the PIC to initiate

and complete the takeoff sequence, and then place the aircraft into GPS mode. The PIC

also retains the ability to immediately take control of the Inpsire 1 with Manual flight

mode.

Frequency Allocations – 900 MHz, 2.4 GHz, and 5.8 GHz.

Flight termination link – A flight termination link is available to the PIC on the GCS to

prevent a "fly away" or other potentially dangerous situation.

 Takeoff and Landing – The Inspire 1 has vertical lift autonomous launch. For takeoff,

the UAS will takeoff and hover approximately 3-4 feet until further inputs are made by

the PIC. Horizontal position of the aircraft is controlled by the PIC using the right

joystick.

10

The Inspire 1 may be pointed in one direction yet fly towards a completely different direction. In

other words, the heading and bearing can be different. Thus, both parameters are displayed on the Inspire

1 GCS home screen.

11

This is the accuracy to the real time GPS reading.
Navigation System – In most cases, navigation of the aircraft is through the visual lineof- sight of the PIC. However, the Inspire 1 may also be operated through preprogrammed flight plans, which are uploaded to the aircraft prior to take-off. Once the

auto-takeoff is complete, the PIC can execute the programmed flight which is performed

through an autopilot function. At any time during the preprogrammed flight, the PIC can

override the autopilot, abort the mission, and take immediate control of the aircraft. In

preprogrammed flight, there are several navigation settings and/or tools, including

landing zones and flight areas (including visual no- fly zones, maximum altitude, and

minimum altitude). This has the effect of creating a virtual fencing around the operational

area.

Redundant Systems – The X4-ES combines the input from a multitude of sensors. Even

though the data from all sensors is required for optimal system performance, dependent

on the sensor, a single sensor malfunction is likely to result in degraded performance

rather than a fatal response.

Emergency Procedures and System Failures

Sensor Failure – A failure of onboard flight instruments and/or sensors will

degrade the Inspire 1 performance and will result in either a fatal critical response

or a non-fatal critical response.

12The type of response will depend on the nature

and severity of the failure. If the aircraft becomes unstable due to sensor failure,

this may result in loss of performance or features. In most instances, the aircraft

remains in stable flight so that the PIC may initiate a landing, the aircraft itself

initiates an auto-land. For instance, a magnetometer failure may lead to a nonfatal critical response. In extreme cases, like an accelerometer failure, a fatal

response may result that causes the aircraft a fatal response such as a crash.

Motor Failure – This will cause a fatal response in flight performance if one or

more motors fails.

Airframe Failure – Depending on the nature and severity, an airframe failure may

result in decreased flight performance or a fatal response such as a crash,

depending on the nature of the airframe failure.

12

A fatal response generally references a complete and catastrophic systems failure leading to the loss of

control of the aircraft, causing it to enter an uncontrolled descent and ultimately impacting the ground or

other object.
Navigation System Failure – In a navigation system failure, degraded GPS will

result in a response warning to the pilot in which the system would be flown in

manual mode. This will result in degraded GPS position performance, but manual

flight by the PIC is not affected.

Power Failure – A complete battery failure which results in power loss to the

aircraft will result in a fatal response and the aircraft may shutdown and crash, if

airborne.

Low Battery Condition – The PIC/operator is alerted of a low battery condition

through both a visual and aural warning. In a critical battery condition, the

PIC/operator is again alerted through an aural and visual warning, and the Inspire

1 will begin an auto- land at a controlled and safe rate of descent.

Line-of-Sight Loss – All flight operations will be conducted with the Inspire 1

within visual sight of the pilot. If the PIC's view becomes obstructed and line-ofsight is lost, the PIC may instruct the aircraft to hover in place until line-of-sight

is re-established, return to the takeoff position, or land at the current position.

Security – The Inspire 1 and communications links are encrypted by the

manufacturer’s proprietary software.
APPENDIX D

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

DJI Phantom series

Systems Overview

The DJI Phantom 2 and 3 series have been well documented in a number of other

approved 333 exemptions and therefore have been removed here for brevity.
APPENDIX E

FEDERAL REGISTRY SUMMARY

Pursuant to 14 C.F.R. Part 11, Falcon Air Vistas, LLC offers the following summary for

publication in the Federal Register, should publication be necessary:

Falcon Air Vistas, LLC seeks an exemption from the following rules:

14 C.F.R. Part 21, Subpart H; 14 C.F.R. § 91.7; 14 C.F.R. § 91.9(b)(2); 14 C.F.R. §

91.113; 14 C.F.R. § 61.113(a)-(b); 14 C.F.R. § 61.133(a); 14 C.F.R. § 91.119(c); 14

C.F.R. § 91.151; 14 C.F.R. § 91.203; 14 C.F.R. § 91.405(a)-(b); 14 C.F.R. §

91.407(a)(1); 14 C.F.R. § 91.409(a)(1)-(2); and, 14 C.F.R. § 91.417(a).

Approval of these exemptions will permit Falcon to conduct commercial unmanned

aircraft systems (“UAS”) operations in a number of industries and applications. The

exemptions will enhance safety by reducing risk to the general public and property

owners from the risk and hazards associated with performing equivalent work through

conventional manned aircraft.