1 UNITED STATES OF AMER I CA DEPARTMENT

OF TRANSPORTATION FEDERAL AVIATION

ADMINISTRATION WASH I NGTON, D. C

.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

JAMES J. HARKINS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE COD E OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 2, DJI PHANTOM 3, DJI INSPIRE 1 AND

DJI SPREADING WINGS S900 & S1000+ (W/ A2 FC)

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on Feb 1 2 th , 2016

James J. Harkins

PO Box 2217

Gearhart, OR 97138

Emai l: j im.deployed@gmail.com2 

### Table of Contents

GLOSSARY OF ABBREVIATIONS

................................ ................................ ............................. 3

SUMMARY

................................ ................................ ................................ ................................ ..... 4

I N TRODUCT I ON AND INTERESTS OF PETITIONER

................................ ............................. 4

BACKGROUND

................................ ................................ ................................ ............................. 4

BAS I S FOR PETITION

................................ ................................ ................................ .................. 5

NAME AND ADDRESS OF PETITIONER

................................ ................................ ........... 6

THE SPEC I

F I C SECTIONS OF 14 C.F.R. FROM WH I CH JAMES J. HAR KINS SEEKS

EXEMPT I ON

................................ ................................ ................................ ........................... 7

THE EXTENT OF WHICH JAMES J. HARKINS SEEKS THE RELIEF

............................ 9

THE REASONS WHY GRANTING JAMES J. HARKINS REQUEST WOU L D BE IN

THE PUBLIC INTEREST

................................ ................................ ................................ ..... 12

THE REASONS WHY GRANTING THE EXEMPT I ON WOULD NOT ADVERSE L Y

AFFECT SAFETY

................................ ................................ ................................ ................. 14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REG I STER

.................... 25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT JAMES J. HARKINS ’S REQUEST

................................ ................................ ... 25

CONC L USION

................................ ................................ ................................ .............................. 26

APPEND I CES

................................ ................................ ................................ ............................... 273 GLOSSARY OF ABBREVIATIONS

AG L Above Ground Leve l

AO I Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

A V Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FA A Fe deral Aviation Administration

FA R F ederal Aviation Regulation

FC Flight Controller

GCS Ground Control Station

GPS Global Positioning S y stem

LOL Loss of Link

N A S National Airspace S y stem

NOTAM Notice to Airman

P I C Pilot I n Command

RC Remote Control

Section 333 FA A Modernization & Reform Act of 2012 (FMRA) Section 333

S O Safety Observer

SOP Standard Operating Procedures

U A Unmanned Aircraft

UA S Unmanned Aircraft S y stem

VF R Visual Flight Rules

VLOS Visual L ine of Site

VMC Visual Meteorological C on ditions

VTOL Vertical Takeoff and Landing4 SUMMARY

JAMES J. HARKINS seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b), to operate an Unmanned Aircraft S y stem pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit JAMES J.

HARKINS

, to operate an Unmanned Aircraft S y stem (UAS) for the commercial purpose of

co n ducting aerial photography, videography, and cinematography for weddings, real estate,

construction site inspections

, special events, film sets, television, publ ic events,

newsgathering, land

, building and agricultural surveying and inspections

, aerial data collection

as well as create company photography and videography for promotional videos and training

for UAS operations over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

JAMES J. HARKINS provides his c lients with expertise and knowledge in production

and cinematography technologies as well provide audio/video solutions to present, produce,

and educate. JAMES J. HARKINS also provides its clients with the highest quality digital

equipment for use in their commercial , pe r sonal, and non

- profit multimedia projects.

JAMES J. HARKINS is an FAA certified Helicopter Air Transport Pilot and active duty Coast

Guard Flight Examiner with over 26 y e ars of military rotary

- wing a viation experience

. Additionally, JAMES J. HARKIN S is an FAA certified Airframe & Power Plant Mechanic.

JAMES J. HARKINS also has over 3 y e ars of aerial RC recreational/hobby experience

. The

objective of JAMES J. HARKINS ’s aerial video and photography operations is to provide

high quality imaging for a variety of promotional, wedding, comm e rcial, public, and

resi d ential uses, specifical l y targeting:

 Production and Motion Picture Filming

 Television/Film

 Wedding Videograp h y and Photograp h y

 Real Estate Videography and Photograp h y

 Land , Building, and Construction Surveying

 I n crease public knowledge of UAS

 Provide training and promote safe U AS operations for resale of DJI products by

doing promotional and training videos and flight demonstrations.5 BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , DJI S900 & S1000+

UASs

JAMES J. HARKINS seeks an exemp tion to operate DJI systems for compensation or

hire within the NAS. The DJI Phantom 2 , DJI Phantom 3, DJI Inspire 1 , and DJI Spreading

Wings S900 & S1000+ are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a

Ground Control Station (GCS) u tilizing electronic tablet or smart phone systems. The DJI

Phantom 2 has a maximum gross wei ght of approximately 2 pounds 13 ounces, while having a

length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of

approximately 29 knots. T he DJI Phantom 3 has a maximum gross weight of approximately 3

pounds , while having a length of 16 inches

, width of 16 inches, height of 8 inches, and a

maximum speed of approximately 31 knots. The DJI Inspire 1 has a maximum gross weight of 6

pounds 7.5 o unces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a

maximum speed of approximately 42 knots. The DJI S900 has a maximum gross weight of 18

pounds , a length of approx. 50 inches , width of 50 inches, height of approx. 15 inches , and a

maximum speed of approximately 42 knots. The DJI S1000+ has a maximum gross weight of 24

pounds 4 ounces , a length of approx. 53 inches , width of 53 inches, height of approx. 16 inches,

and a maximum speed of approxim ately 45 knots.

The DJI Phanto m 2 , DJI Phantom 3, and DJI Inspire 1UA ’ s are equipped with four main

rotors; driven by Lithium Polymer battery powered electric motors.

The DJI S900 UA is equipped with 6 main rotors; driven by Lithium Polymer battery

powered electric motors

. The DJI S1 000+ UA is equipped with 8 main rotors; driven by Lithium Polymer battery

powered electric motors

BASIS FOR PETITION

Petitioner, JAMES J. HARKINS , pursuant t o the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernizati on and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the

Administrator to commercially o perate the DJI Phantom 2

, DJI Phantom 3, DJI Inspire 1 , DJI

Spreading Wings S900 & S1000+ UAS ’ s in the N ational Airspace System (NAS), and for an

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a) , 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and lim ited operating area associated with the

unmanned aircraft and its operation, JAMES J. HARKINS ’s operation of DJI Phantom 2

, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS ’ s meets the conditions

of FMRA Section 333 and therefore, wi ll not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H.

Accordingly, JAMES J. HARKINS requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requi rements for

maintenance that only apply to aircraft with an airworthiness certificate.

JAMES J. HARKINS submits that the requested relief is proper since an equivalent level

of safety will be ensured. JAMES J. HARKINS will perform maintenance, alterations , or6

preventive maintenance on the UAS ’ s using the methods, techniques, and practices prescribed in

the operating documents (i.e., Monthly Maintenance Log, an d DJI Phantom 2, DJI Phantom 3,

DJI Inspire 1 , DJI Spreading Wings S900 & S1000+ Instruction Manua ls). Furthermore, JAMES

J. HARKINS will document and maintain all maintenance records for the DJI Phantom 2

, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS ’ s. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command, is requested by JAMES J. HARKINS to the extent

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as

well as an airman medical certificate, and who h as demonstr ated, by meeting minimum flight

hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2

, DJI

Phantom 3, DJI Inspire 1 , DJI Spreading Wings S900 & S1000+ UAS ’ s in a manner consistent

with this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

JAMES J. HARKINS seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 2

, DJI Phantom 3, DJI Inspire 1 , DJI Spreading Wings

S900 & S1000+ UAS ’ s do not require an airworthiness certificate in accordance with 14 C.F. R.

Part 21, Subpart H. As such, JAMES J. HARKINS submits that he will ensure that the DJI

Phantom 2

, DJI Phantom 3, DJI Inspire 1 , DJI Spreading Wings S900 & S1000+ UAS ’ s are in

an airworthy condition, prior to every flight, by determining that the UASs are in compliance

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2

, DJI Phantom

3, DJI Inspire 1 , DJI Sprea ding Wings S900 & S1000+ Instruction Manual s ), and that the aircraft

are in a condition for safe flight.

JAMES J. HARKINS also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI Phantom 2

, DJI Phantom 3, DJ I Inspire 1 , DJI Spreading

Wings S900 & S1000+ UA ’ s will not have a typical barometric altimeter onboard. However,

altitude information of the DJI Phantom 2

, DJI Phantom 3, DJI Inspire 1 , DJI Spreading Wings

S900 & S1000+ UA ’ s will be provided to the PIC v ia Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlinks from the UA to the

GCS for active monitoring of the flight path. This altitude information, combined with JAMES J.

HARKINS ’s operation of the DJI Pha ntom 2

, DJI Phantom 3, DJI Inspire 1 , DJI Spreading

Wings S900 & S1000+ UAS ’ s within visual line of sight, at or below 500 feet AGL, will ensure

a level of safety equivalent to Section 91.121.

Additionall y

, JAMES J. HARKINS seeks an exemption from the req uirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions

. JAMES J. HARKINS submits

that safety will not be affected by operation of the DJ I Phantom 2, DJI Phantom 3, DJI Inspire 1

, DJI Spreading Wings S900 & S1000+ UAs during da y light hours in visual meteorological

conditions (VMC) under visual flight rules (VFR), with enough battery power to f l y fo r a total

duration of approximately 13 minutes to the first point of intended landing and, assuming normal

cruising speed, to f

l y after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, JAMES J. HARKINS provides the following

information in support of its petition for exemption:7

A . Name And Address Of The Petitioner:

The name and address of the Petitioner and po int of contact is:

JAMES J. HARKINS

PO Box 2217

Gearhart, OR 97138

Email: jim.deployed@gmail.com

B. The Speci fic Sections Of 14 C.F.R. From W hich JAMES J. HARKINS seeks

Exemption.

1. JAMES J. HARKINS Seeks Exemption Fro m The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may ac t as a pilot in command (PIC)

of an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircr aft in connection

with any business or employment if

— (1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. JAMES J. HARKINS Seeks Exe mption From The Requi rements Of Section

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. JAMES J. HARKINS Seeks Exe mption From The Require ments Of Section

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of

that aircraft, as the case may be, by reference to an altimeter that is set, when

operating

-- (1) Below 18,000 feet MSL, to

--

(i) The current reported altimeter setting of a station along the route and within

100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this

section, the current reported altimeter setting of an appropriate available station;

or (iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting avai lable before departure.8

4. JAMES J. HARKINS Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection

(b), states the following:

(b) No person may begin a flight in a roto rcraft 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, to fly after

that for at least 20 minutes

.

5. JAMES J. HARKINS Se eks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each

owner or operator of an aircraft

— (a) Shall have that aircr a ft 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[.]

6. JAMES J. HARKINS Seeks Exemption From The Requirements Of Section

91.407(a)(1)

Secti on 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has un dergone maintenance, preventive

maintenance, rebuilding, or alteratio n unless

--

(1) It has been approved for return to service by a person authorized under §43.7 of

this chapter[.]

7. JAMES J. HARKINS Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsec tion (a), states the following:

(a) Except as provided in paragraph (c) of this se ction, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had

--

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service b y a person authorized by § 43.7 of this chapter;

or9 (2) An inspection for the issuance of an airworthiness certificate in accordance with

part 21 of this chapter.

8. JAMES J. HARKINS Seeks Exemption From The R equirements Of Sections

91.417(a) And

91.417(b).

Section 91.417, entitled Maintenance records, sub sections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall kee p the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records

of the 100

- hour, annual, progressive, and other required or approved

inspections, as app ropriate, for each aircraft (including the airframe) and each

engine, propeller, rotor, and appliance of an aircraft. The records must include

--

(i) A description (or reference to data acceptable to the Administrator) of the

work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft

for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each en gine, each propeller, and

each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller,

rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are

required to be overhauled o n a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the aircraft

and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or safety

directive number and revision date. If the AD or safety directive involves

recurring action, the time and date when the next action is requ ired.10 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major

alteration to the airframe and currently installed engines, rotors, propellers,

and appliances.

(b) The owner or operator shall retain the following records for the per iods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work is

performed.

(2) The records specified in paragraph (a)(2) of this secti on shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this

chapter shall be retained until the defects are repaired and the aircraft is a pproved

for return to service.

C. The Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J.

HARKINS Seeks The Relief.

1. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J.

HARKINS Seeks Relief From

Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privi leges and limitations:

Pilot in command, is requested to the extent necessary to allow a PIC ho lding a private pilot or

higher level certificate, as well as a current and valid airman med ic al certificate, and who has

met certain flight

- hour and currency requirements, to conduct the proposed UAS flight

operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) stat e

That a pr ivate pilot may, for compensation or hire, act as PIC of an aircraft in connection with

any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property f or compensa tion or

hire.

As set forth more fully below, JAMES J. HARKINS submits that an equivalent level of

safety will be maintained because no PIC will be all owed to operate the DJI Phantom 2

, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ U AS ’s unless

that PIC has met c er tain flight

- hour and currency requirements, demonstrating that the PIC

is able to safely oper ate either the DJI Phantom 2 DJI Phantom 2

, DJI Phantom 3, DJI

Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS s in a manner co nsistent with the

operations specifications as described in this exemption, including evasive and e mergency

ma neuvers, as well as maintaining appropriate distances fro m people, vessels, vehicles and

structures.

Further, JAMES J. HARKINS submits that all fligh ts of the DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs, c onducted by11

the PIC pursuant to the gran t of this Petition: (1) will be incidental to JAMES J.

HARKINS ’s business; and ( 2) will not carry passengers or property for compensation or

hire.

2. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J.

HARKINS Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthines s , is requested to the extent

required to allow JAMES J. HARKINS to determine that the D J I Phantom 2, DJI Phantom 3,

DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS’s are in airwort h y condition prior

to every flight b y ensuring that the UAS is in compliance with the operating documents (i .e.,

JAMES J. HARKINS Aerial Operations Manual, Monthly Main t enance Log, and D J I Phantom

2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ I nstruction

Manuals).

JAMES J. HARKINS seeks the requested r elief because the DJI Phantom 2, DJ I Phantom

3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS ’ s do not require an

airworthiness ce rtificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, JAMES J.

HARKINS will ensure that the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading

Wings S900 & S1000+ UAS ’ s are in airworthy condition based upon its compliance with the

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2

, DJI Phantom 3, DJI

Inspire 1 , and DJI Spreading Wings S900 & S1000+ Instruct ion Manual s ) prior to every flight,

and further, determine that the aircraft are in condition for safe flight, as stated in the conditions

and limitations below.

3. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J.

HARKINS Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, ma y be required to allow flight

operations of the DJ I Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900

& S1000+ UAS’s, which utilize a barometric pressure sens or, GPS equipment, and a radio

communications telemetry data link to downlink altitude information from the UA to the P I C at

the ground control station (GCS). Since the FAA requires that a n y altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), JAMES J. HARKINS seeks the requested relief because the D J I Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UA’s altimeter may be set

on the ground to zero feet AG L , ra ther than the local barometric pressure or field altitude, before

each f light.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is

sought to the extent necessary to comply with the applicable conditions and limitation s stated

below. As more ful l y set forth herein, an equivalent level of safe t y will be maintained since the

DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UA’s

are equipped with a barometric pressure sensor and GPS equipm ent, which automatical l y ensures that a ground level pressure setting will be established prior to each flight, and provides th e P I C

with altitude information of the UA on the head s

- u p displa y of the GCS.12

4. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J.

HARKINS Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UA ’ s during daylight hours

in visual meteorological conditions (VMC), under visual flight rules (VFR), for a to tal duration

of 14.5 minutes to the first point of intended landing and, assuming normal cr uising speed, to fly

after that for at least 5.5 minutes. JAMES J. HARKINS seeks the requested relief because

without an exemption from Section 91.151(b), the flight time duration of the battery powered

DJI Phantom 2

, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UA ’ s will severely constrain the practicality of any aerial video or still photo flight operations that

JAMES J. HARKINS proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specific ations of the DJI Phantom 2

, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS ’ s, the DJI Phantom 2

, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ operating documents,

and JAMES J. HARKINS ’s proposed operating li mitations, ensure that JAMES J. HARKINS

will safely operate the battery powered DJI Phantom 2

, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreading Wings S900 & S1000+ UA ’ s during daylight hours in visual meteorological

conditions (VMC), under visual flight rul es (VFR), with enough battery power to fly for a tota l

duration of 14 .5 minutes to the first point of intended landing and, assuming normal cruising

speed, to fly after that for at least 5 .5 minutes.

5. Extent Of Relief JAMES J. HARKINS Seeks And The Reas on JAMES J.

HARKINS Seeks Relief Fro m

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certifica te, JAMES J. HARKINS requests relief from

these Sections because the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading

Wings S900 & S1000+ UAS ’ s do not require airworthiness certificates. As set forth more fully

below, the DJI Phantom 2, DJI P hantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 &

S1000+ UAS ’ s meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, JAMES J. HARKINS will perform maintenance, alterations, or

preventive maintenance on the UASs using the methods, techniques, and practices prescribed in

the UAS operating documents (i.e., the JAMES J. HARKINS Ae rial Operations Manual,

Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreading Wings S900 & S1000+ Instruction Manual s ). Furthermore, JAMES J. HARKINS will

document and maintain all maintenance records for the DJI Phantom 2, DJI Phantom 3, DJI

Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs.

D. The Reasons Why Granting JAMES J. HARKINS ’s Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing JAMES J.

HARKINS to utilize his 26 y e ars of military rotary

- wing aviation exper ience to demonstrate,13

champion and support the safe operation of UAV’s in the national airspace

. Additionally, JAMES J.

HARKINS will showcase the safe, efficient, and economically perform ance of aerial video and

photography collection for wedding films, r eal estate, special events, film sets, and landscape

over certain areas of the United States

.

Furthermore

, the use of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading

Wings S900 & S1000+ UAS’s will decrease congestion of the NAS, reduce pollution, and

provide significant benefits to the economy. Notably, the benefits of JAMES J. HARKINS ’s

proposed operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading

Wings S900 & S1000+ UAS’s will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 &

S1000+ UA ’ s are battery powered and serve as a safe, efficient, and economical alternativ e to

the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Win gs S900 & S1000+ UAS ’s

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well

as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operatin g in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. The DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UA ’ s do

not require an airport to takeoff or land. Likewise, a reduct ion of manned aircraft conducting

aerial video and photography missions would result in fewer aircraft that must be handled by air

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight

operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000 + UAS ’ s.

Conducting aerial acquisitions with the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1

, and DJI Spreading Wings S900 & S1 000+ UAS ’ s, instead of manned aircraft, will greatly

benefit the public by drastically reducing the levels

of air and noise pollution generated during traditional aerial video and still photography flight

operations. By using battery power and electric mo tors, the DJI Phantom 2, DJI Phantom 3, DJI

Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS ’ s produce no air pollution, and is the

most viable environmentally conscious alternative to the cabin class, six cylinder internal

combustion engine aircraft t hat are typically utilized for aerial video and photography, while

burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAs, while reducing the

carbon f ootprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled

by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings

S90 0 & S1000+ UASs to perform aerial acquisitions, the substantial risk to life and property in

the air and on the ground, which is usually associated with traditional manned aircraft flight14

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight

crew members located onboard the aircraft, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1

, and DJI Spreading Wings S900 & S1000+ UAs (weighing approximately only 2 pounds 11

ounces to 24 pounds respectively, at their maximum gross weights

, with lengths of 16 inches to

53 inches respectively, widt hs of 16 inches to 53 inches respectively, and with no fuel on board),

has less physical potential for collateral damage to life and property on the ground, and in the air,

compared to the manned aircraft that typically conduct similar operations (weighing

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a

fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations W ith The DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs Will

Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1

, and DJI Spreading Wings S900 & S1000+ UASs are also an economical alternative to using

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs will allow

United States based companies, l ike JAMES J. HARKINS , to remain competitive and contribute

to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels,

U.S. owned a nd operated companies must adopt new and alternative technology in order to

remain competitive. Operating the battery powered DJI Phantom 2, DJI Phantom 3, DJI Inspire

1 , and DJI Spreading Wings S900 & S1000+ UASs is one such technology that not only allow s companies greater operational flexibility compared to manned aircraft, but provides such

flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wing s

S900 & S1000+ UASs, companies such as JAMES J. HARKINS , can remain competitive and

profitable, and therefore, provide greater job stability to employees and contractors, which will

ultimately contribute to growth of the U.S. economy. Improved financial p erformance of U.S.

companies, through commercial use of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and

DJI Spreading Wings S900 & S1000+ UASs, provides a stable workforce that increases

consumer spending; improves local, state, and federal tax revenu es; and allows companies to

invest in research and development in order to remain competitive both in the United States and

abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

d ecades, JAMES J. HARKINS ’s proposed operation of the D J I Phantom 2, DJI Phantom 3,

DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs will not implicate any privac y issues. Specifical l y

, th e D J I Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Sprea ding

Wings S900 & S1000+ UASs will be operated only in compliance with operating documents

(i.e.,the JAMES J. HARKINS Aerial Operations Manual, Monthly Maintenance Log, and D J I

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+

Instruction Manuals) which requires proper t y owner involvem e nt as well as local law15

enforcement notification, and in accordance with the Federal Aviation Regulations, including

the minimum altitude requirements of 14 C.F.R. §91.119.

E. The Reasons Why Gra nting The Exemption Would Not Adversely Affect Safety, Or

How The Exemption Would Provide A Level O f Safety At Least Equal To That

Provided By The Rule From Which JAMES J. HARKINS Seeks Exemption.

1. Reasons Why The DJI Phantom 2, DJI Phantom 3, D JI Inspire 1, and DJI

Spreading Wings S900 & S1000+ UASs Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated

with the unmanned aircraf t and its operation, JAMES J. HARKINS ’s operation of the DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+

UASs meet the conditions of FMRA Section 333, and will not require an airworthi ness

certifica te in accordance with 1 4 C.F.R.Part 21, Subpart H.

Section 333 provides authority for a UAS t o operate without airworthiness

certification and sets forth requirements for considering whe ther a UAS will create a hazard

to users of the NAS or the public, or otherwise pose a threa t to national secu rity. Specifically,

FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later

than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may operate

safely in the national airspace system before completion of the plan and

rulemaking required by section 332 of this Act or the guidance required by section

334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under

subsection (a), the Secretary shall determine, at a minimum

--

(1) which types of unmanned aircraft systems, if any, as a result of their size

, weight, speed, operational capability, proximity to airports and populated

areas, and operation within visual line of sight do not create a hazard to

users of the national airspace system or the public or pose a threat to

na tional security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems iden tified

under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section

that certain unmanned aircraft systems may operate safely in the national airspace16 system, the Secretary shall establis h requirements for the safe operation of such

aircraft systems in the national airspace system.

In seeking this exemption, JAMES J. HARKINS submits that the DJI Phantom 2 and DJI

Inspire 1 UASs can operate safely in t he NAS pursuant to FMRA Secti on 3 33, as

demonstrated by: (a) the characteristics of the DJI Phantom , DJI Phantom 3, DJI Inspire

1 , and DJI Spreading Wings S900 & S1000+ UASs; (b) the p ilot certification re quirement;

and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and

DJI Spreading Wings S900 & S1000+ UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 &

S1000+ UASs do not create a hazard to users of the NAS or the public, or otherwise pose a

threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJ I Phantom 2, DJI Phantom 3, DJI

Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs , and DJI A2 FC

.

The technical specifications of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and

DJI Spreading Wings S900 & S1000+ UASs are set for th by the DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1 000+ Specifications and Data

Sheet, attached hereto as Appendices A, B , C, D, E and F

.

ii. The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading

Wings S900 & S1000+ UASs Autonomous Flight And Navigation Modes Enable The

UASs To Remain W ithin A Defined Operational Area.

The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 &

S1000+ UASs may be op erated in both manual and fully autonomous flight modes. A

complete description of the fligh t and navigational modes o f the DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UA Ss is provided at

pages 25

- 35 of the DJI Phantom 2, page 11

- 14 of the DJI Phantom 3, pages 12

- 16 and 45

- 50

of the DJI Inspire 1, and pages 23, 30

- 31 and 33

- 37 of the A2 FC (used for the DJI Spreading

Wings S900 & S1000+ UAVs) User Manuals, a ttached hereto as Appendices G, H, I, J, K

and L.

iii. The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading

Wings S900 & S1000+ UASs Are Designed For Automati c Return To Home Point Or

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and

DJI Spreading Wings S900 & S1000+ UAs will remain stationa ry, in flight, for 3 sec onds or

more. If, after 3 seconds, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreading Wings S900 & S1000+ UAs do not reacquire cont rol link data from the GCS, the

UAs will assume that the Control Link is lost and the UAs w ill return to the home position17

(i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions o f the DJI Phantom 2 UAS are set

forth at pages 27

- 29 , pages 12

- 14 for the DJI Phantom 3, pages 13

- 15 fo r the DJI Inspire 1,

and pages 30

- 31 of the A2 FC (used for the DJI Spreading Wings S900 & S1000+ UAVs)

User Manuals, attached hereto as Appendices G, H, I, J, K and L

.

b. Flight Operations Of DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and

DJI Sprea ding Wings S900 & S1000+ UASs Are Limited To The Line Of Sight Of A

Certificated PIC With A Safety Observer.

James Harkins currently hold s a Helicopter Air Transport license (ATP) and will only

utilize certificated pilots who possess a current and valid airman medical certificate to act

as a pilot in command (PIC) of the D J I Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreading Wings S900 & S1000+UASs. Additionall y , a safe t y observer will assist all

pilots during fligh t time.

c. Flights Of DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading

Wings S900 & S1000+ UASs Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, JAMES J. HARKINS proposes to c ommercially operate

DJ I Phanton 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+

UASs for the special purpose of conducting aerial video and photograp hy over certain

areas of United States, pursuant to the following specific operating limitations:

1. Oper ations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UASs weighing less than

55 pounds maximum gross weight: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1

, and DJI Spreading W ings S900 & S1000+ UASs . Proposed operations of any other

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

2. UAS operations under this exemption will be limited to conducting operations for

the purpose of aerial video

, photography and cinematography

.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground

level (AGL), as indicated by the procedures specified in the operating documents

unless a special request is made and approved by ATC. All altitudes reported to

ATC must be in feet AGL.

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

times. This requires the PIC to be able to use human vision unaided b y any device

other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical

certificate.18

6 . All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. The

SO and PIC must be able to communicate verbally at all times. Electronic

messaging or texting is not permitted during flight operations. The PIC must be

designated before the flight and cannot transfer his or her d esignation for the

durati on of the flight. The PIC must ensure that t he SO can perform the functions

prescribed in the operating documents.

7 . The SO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obsta cles/obstructions and is

not permitted to operate the camera or other instruments.

8 . The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant of

exemption and the procedures outlined in the operating documents, the conditions

and limitations contained in the grant of exemption take precedence and must be

followed. Otherwise, the oper ator must follow the procedures as outlined in its

operating documents. The operator may update or revise its operating documents.

It is the operator’s responsibility to track such revisions and present updated and

revised documents to the Administrator up on request. The operator must also

present updated and revised documents if it petitions for extension or amendment

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

would affect the basis upon which the FAA granted the exem ption, then the

operator must petition for amendment to its grant of exemption. The FAA’s UAS

Integration Office (AFS

- 80) may be contacted if questions arise regarding updates

or revisions to the operating documents.

9 . Prior to each flight the PIC must i nspect the UAS to ensure that it is in a condition

for safe flight. If the inspection reveals a condition that affects the safe operation of

the UAS, the aircraft is prohibited from operating until the necessary maintenance

has been performed and the UAS i s found to be in a condition for safe flight.

10 . Any UAS that has undergone maintenance or alterations that affect the UAS

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

must undergo a functional test flight. The P IC who conducts the functional test

flight must make an entry in the aircraft records.

11 . The pre

- flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the relevant

section s of the operating documents.

12 . The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.19

13 . The operator must carry out its maintenance, inspections, and record ke eping

requirements, in accordance with the operating documents. Maintenance,

inspection, alterations, and status of replacement/overhaul component parts must

be noted in the aircraft records, including total time in service, description

of work accomplish ed, and the signature of the authorized person returning the

UAS to service.

14 . Each UASs operated under this exemption mu st comply with all manufacturer

Safety Bulletins.

15 . The authorized person must make an entry in the aircraft record of the correc tive

action taken against discrepancies discovered between inspections.

16 . The PIC must possess at least a private pilot certificate and at least a current third

class medical certificate.

17 . The operator may not permit any PIC to operate unless the P IC meets the

operator’s qualification criteria and demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distan ces from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a m anner consistent with 14 C.F.R. §

61.51(b). Flights for the purposes of training the operator’s PICs are permitted

under the terms of the exemption. How ever, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and

experience

- building flights, all persons not essential for flight operations are

considered nonparticipants, and the PIC must operate the UA with appropriate

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

18 . UAS operations may not be conducted during night, as defined i n 14 C.F.R. § 1.1.

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

If f light at night is required, a special request will be made at the FAA office

closest to proposed area of operations. Flights under special visual flight rules

(SVFR) are not authorized.

19 . The UA may not operate within 5 nautical miles of an airport refe rence point as

denoted on a current FAA

- published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of

agreeme nt with the airport management must be made available to the

Administrator upon request.

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

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

PIC

.20

21 . If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in

accordance with the operating documents.

23. The PIC must abort the flight in the eve nt of unpredicted obstacles or emergencies

in accordance with the operating documents.

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

forecast weather conditions) there is enough power to fly at normal cruising speed

to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under the grant

of exemption. T his COA will also require the operator to request a Notice to

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours

prior to the operation. All operations shall be conducted in accordance with

airspace requirements in the ATO issued COA including class of airspace, altitude

level and potential transponder requirements.

26. All aircraft operated in accordance with the COA exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identific ation (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart

C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation

and control of the UA must comply with the Federal Comm unications Commission

(FCC) or other appropriate government oversight agency requirements.

29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC f rom any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator

must ensure that nonparticipating persons remain under such protection. If

a situation arises where nonparticip ating persons leave such protection and

are within 500 feet of the UA, flight operations must cease immediately

and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of21 operating closer to those objects and determined that it does not present an

undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with

permission from the land owner/controller or authorized representative. Permission

from land owner/controller o r authorized representative will be obtained for each

flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical

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

reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours.

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

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

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

JAMES J. HARKINS submits that the equivalent level of safety e stablished by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed t o

oper ate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading

Wings S900 & S1000+ UASs unless that PIC has demonstrated, by meeting

minimum flight

- hour and curr ency requirements, that the PIC is able to safely

operate t he DJI Phantom 2, DJI Phanto m 3, DJI Inspire 1 , and DJI preading

Wings S900 & S1000+ UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from

people, ves sels, vehicles and structures. Considering JAMES J. HARK INS ’s

proposed area of operations, an d the operating limitations set

forth

- above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption

No.11 062); and the airmanship skills necessa ry to safely operate the DJI Phantom

2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS,

JAMES J. HARKINS sub mits that the additional manned

airmanship experience of a commercially certificated pilot would not correlate to

the airma nship skills necessary for JAMES J. HARKINS ’s specific proposed flight

operations.

The FAA has previously granted relief from Sectio n 61.113(a) and (b) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Ex emption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

JAMES J. HARKINS will not allow any PIC to operate the DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJ I Spreading Wings S900 & S1000+ UAS un less that PIC22

has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS training

and currency requirements, that the PIC is able to s afely operate the DJI Phantom 2 or DJI

Inspire 1 UAS in a manner consistent with this exemption, i ncluding evasive and

emergency maneuvers and maintaining appropriate distances fro m people, vessels,

vehicles and structures.

Specifically, the PIC must have accumulated and logg ed, in a manner consistent with

14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorc raft pilot (with a minimum of 5

hours of those hours as a UAS pilot operating the same m ake and model of UAS to be used

for operat ions under the exemption). In addition to the hour requirements, th e PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, pri or documented flight experience

that was obt ained in compliance with applicable regulations will ensure an equi valent level of

safety during JAMES J. HARKINS ’s proposed operations. The Ad ministrator has held that

prior documented flight experience that was obtained in complia nce with applicable

regu lations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior t o conducting operations for the

purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent wi th 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot

with a multi

- rotor UAS. Prior to operations und er Exemption No. 11062, the PIC

must also have accumulated and logged a mi ni mum of 5 hours as a UAS pilot

operating the same make and model of UAS to b e used for operations under the

exemption. For clarification, the FAA considers the se minimum hour requirements to

be inclusive rather than additive; i.e. 5 hours make and model tim e may be included

in the 10 hours of multi

- rotor time and t he 10 hours may be included in the total 25

hours of UAS rotorcraft time. In additio n to the hour requirements, the PIC must

accomplish 3 takeoffs and landing s in the preceding 90 days (for currenc y purposes).

The FAA finds that at a minimum, the flight

- hou r requirements in Exemption No.

11062 are appropriate to practice and build profici ency in the skills necessary to

safely conduct the petitioner’s proposed operations . The FAA also finds that prio r documented flight experience that was obtained in complia nce with applicable

regulations would satisfy this requirement. Traini ng, proficiency, and experience

building flights can also be conducted under the grant of exemption to accomplish the

required flight time. Du ring training, proficiency, and experience

- b uilding flights the

PIC is required to operate the UA with appropriate distances in accordance with 14

C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, JAMES J. HARKINS will ensure safe operat ions by not allowing any

PIC to operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading

Wings S900 & S1000+ UAS unles s that PIC has demonstrated, by meeting minimum

flight

- hour and currency requir ements, that the PIC is able to saf ely operate the DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+23

UAS in a manner consistent with the exemption, including evasive and emergency

maneuv ers and maintaining appropriate distances from people, vessels, vehicles and

structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety

The equivalent level of safety established by Sec tion 91.7(a) will be maintained

because prior to every flight, JAMES J. HARKINS will ensure that the DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UAS is in an airworthy

condition based upon the UAS’s compliance with its operating documents and as stated in the

conditions and limitations herein.

Additio nally, the FAA has previously granted relief f rom Section 91.7(a) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e. g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

1113 6, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Se ction 91.121 will be maintained

be cause the altitude information of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreading Wings S900 & S1000+ UAs will be provided to the PIC via GPS equipment and a

radio communications telemetry data link, which downl inks from the UA to the GC S for

active monitoring of the flight path and altitude. This alti tude information, combined with

JAMES J. HARKINS ’s operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and

DJI Spreading Wings S900 & S1000+ UAs within vis ual line of sight, at or below 500 feet

AGL, will ensure a level of safety eq uivalent to Section 91.121. The altitude information will

be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero

altitude initiation point is automatic ally established by the UASs at ground level.

The FAA has previously granted relief from Sec tion 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presen ted herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 110 80, 11 109, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of s afety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical sp ecifications of the DJI Phantom

2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs; (2) the

limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, JAMES J. HARKINS will ens ure that it will safely operate the

battery powered DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings

S900 & S1000+ U As during daylight hours in VFR co nditions, with enough battery power to

fly for a total durati on of 13.5 minutes to the first point of intended landing and, assuming24

normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specif ications of the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs; the

limitations on the proposed flight operations; and the locat ion of the proposed operations,

will ensure an equivalent le vel of safety established by 14 C.F.R. Section 91.151(b).

Furthermore, safety will be ensured as the DJI Phantom 2 and DJI Inspire 1 UASs provide

audible and visual warnings to the PIC at the GCS when the UAs experiences low battery

voltage, the first warning occurring at approxima tely 3 3% remaining battery power, and

again at approximately 10% remaining battery power. At the cr itically low battery level, the

DJI Phantom and DJI Inspire 1 UASs will descend and land automatically.

Significantly, previous exemptions granted by th e F AA concerning Section 91.151

establish that safety is not adversely affected when the technica l characteristics and operating

limitations of the UAS are considered. Reli ef has been granted for manned aircraft to operate

at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689,

5745, and 10650. Moreover, the FAA has previously gra nted relief from Section 91.151

specific to UAS, in circumstances similar, in all material resp ects, to those presented herein

(e.g. Exemption Nos. 8811 , 108 08, 10673, 11042, 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 111 36, 11138, 11150, 11153, 11156, 11157, 11158, 11159,

11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1 ) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, JAMES J. HARKINS submits that the equivalent level of

safety with regard to the regulatory maintenance and alteration requi rements established by

Sections 91.40 5(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because JAMES J. HARKINS is a trained A&P licensed mechanic and will perform

maintena nce, alterations, or preventive maintenance on the UASs using the methods,

techniques, and pract ices prescribed in the operating documents (i.e., the JAMES J.

HARKINS Aerial Operati ons Manual, Monthly Maintenance Log, and DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ Instruction Manual).

Furthermore, JAMES J. HARK INS will document and maintain all maintenance records for

the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+

UASs.

Since the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings

S900 & S1000+ UASs wil l be inspected as prescribed by the operating documents, JAMES J.

HARKINS will maintain the equivalent level of safety established by Se ctions 91.405(a),

91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1

, and DJI Spre ading Wings S900 & S1000+ User Manuals are attach ed hereto as Appendices

A, B, C, D, E and F; a copy of the DJI Phantom 2 and DJI Inspire 1 UAS Mainte nance LOG

is attached hereto as Appendix G

.

Likewise, the exemption sought will not adversely affect saf ety because

JAMES J. HARKINS is a trained A&P licensed mechanic and will perform maintenance,25

alterations o r preventive maintenance on the UAS using the methods, techniques, and

practices prescribed by the operating documents.

Furthermore, the exemption so ught would maintai n an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), bec ause all maintenance of the DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs

will be performed in accordanc e with prescribed operating documents . Maintenance wi ll be

documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.4 17(a) & ( b) establish that safety is not

adversely affected when the technical characteristics and opera ting limitations of the UAS are

considered.

In consideration of JAMES J. HARKINS ’s proposed opera ting limitations, the

operating documents, and the te chnical aspects of the DJI Phantom 2, DJI Phantom 3, DJI

Inspire 1

, and DJI Spreading Wings S900 & S1000+ UASs, JAMES J. HARKINS submits

that safety will not be adversely affected by granting exemption from 14 C.F.R. S ections

91.405(a), 91.407(a)(1) and (a )(2), 91.409(a)(2), and 91.417(a) and (b). The FA A has

previously granted relief specific to UAS in circumstances similar, in all material resp ects,

to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 110 66,

11067, 11080, 11109, 1111 0,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Moder nization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 2 1.16 entitled Special Conditions, JAMES J. HARKINS requests

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs, which

contain such safety stand ards that the Administrator finds necessary to establish a level of

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F. R §§

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2),

and 91. 417(a) & (b). Such s pecial conditions will permit safe operation of the UAs for th e limited purpose of conducting aerial video and photography over certain areas of the United

S tates for compensation or hire.

FMRA Section 333 sets forth the requirements fo r considering whether a UAS w ill create a

hazard to users of the NAS or the public, or otherwise pose a t hreat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification in

accordance with any requ irements that must be established fo r the safe operation of the UAS

in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreadin g Wings S900 & S1000+ UASs, since the airworthiness regulations of 14 C.F.R.

Part 21 do not contain adequate or appropriate safety standar ds, due to the novel or unusual

design features of the aircraft. Section 21.16, entitled Special Conditions, states th e following:

If the FAA finds that the airworthiness regulations of this subchapte r do not contain

adequate or appropriate safety standards for an aircraft , aircraft engine, or propeller26

because of a novel or unusual design feature of t he aircraft, aircraf t engine or

propeller, he prescribes special conditions and amendments thereto for the product.

The special conditions are issued in accordance w ith Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the FAA

finds necessary to establish a level of safety equivalent to that establi shed in the

regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

may prescribe special conditions for JAMES J. HARKINS ’ intend ed operation of the DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs,

which contain such safety standards that the Administrator finds ne cessary to establish a level

of s afety eq uivalent to that established by 14 C.F.R. Part 21, S ubpart H, and 14 C.F.R

Sections 61 .113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.40 7(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Feder al Register, stating: The Rules

From Which JAMES J. HARKINS Seeks Exemption:

JAMES J. HARKINS seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.1 51(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417 (a) & (b).

A Brief Description Of The Nature Of Th e Exemption JAMES J. HARKINS Seeks:

This exemption will permit JAMES J. HARKINS to commercially operate an Unmanned

Aircraft System (UAS) for the purpose of conducting aerial video , photography and

cinem atography including photo and/or video for television, public events, newsgathering,

real estate and land surveying over certain areas of the United States. As well as assist

with company promotional videos and training demonstrations for UAS operations.

G. Any Additional Information, Views, Or Arguments Available To Support

JAMES J. HARKINS ’s Request.

This Petition is made pursuant to the FAA Moder nization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transpo rtation to deter mine if certain

UAS may operate safely in the NAS. As such, JAMES J. HARKINS ’s request for exemption

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set

forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or othe rwise pose a threat to national

security; and further, provides the authority for such UAS t o operate without airworthiness

certification.

As discussed in detail abo ve, JAMES J. HARKINS will operate the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs safely in

the NAS, without creating a hazard to users of the NAS, or the public, or othe rwise pose a

threat to national security.2728 CONCLUSION

As set forth herein, JAMES J. HARKINS seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which

will permit safe operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreading Wings S900 & S1000+ UASs commercially, without an airworthine ss certificate,

for the limited purpose of conducting aerial video and photography over cert ain areas of the

United States. By granting this Petition, the FAA Administrator will be fulfi lling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the inter ests of the public, by allowing JAMES J. HARKINS to safely, efficiently,

and econo mically operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI

Spreading Wings S900 & S1000+ UASs commercially within the NAS.

WHEREFORE , in accordance with the Federal A viation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, JAMES J. HARKINS respectfully

requests t hat the Administrator grant this Petition for an exemption fr om the requirements of

14 C.F.R Sections 61.113(a) & (b), 91.7(a) , 91.121, 91.151(b), 91.405(a), 91 .407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit James Harkins t o operate the DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1 , and DJI Spreading Wings S900 & S1000+ UASs

commercially for t he purpose of conducting aerial video and photography over cert ain areas

of the United States.

Dated: Feb 12 th , 201 6

Respectfully sub mitted,

JAMES J. HARKINS

PO Box 2217

Gearhart, OR 97138

jim.deployed@gmail.com29

Appendices:

A

– DJI Phantom 2 Specifications Data Sh eet

B

– DJI Phantom 3 Specifications Data Sheet

C

– DJI Inspire 1 Specifications Data Sheet

D

– DJI S900 Specifications Data Sheet

E

– DJI S1000+ Specifications Data Sheet

F

– DJI A2 Flight Controller Data Sheet

G

– DJI Phantom 2 Manufacturer’s User Manua l

H

– DJI Phant om 3 Manufacturer’s User Manual

I

– DJI Inspire 1 Manufacturer’s User Manual

J

– DJI S900 Manufacturer’s User Manual

K

– DJI S1000+ Manufacturer’s User Manual

L

– DJI A2 FC Manufacturer’s User Manual

M

– Monthly Maintenance Log30 APPENDIX

– A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking software enabling the

user to set parameters which will not allo w fl ight into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitude as well as limit

flight to a predetermined and set distance. In addition, DJI software provides real

- time

altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)

1.1 DJI Phantom 2

1.1.1 Aircraft

1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.1.3 H over Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity

- 200 0 /s

1.1.1.5 Max Tilt Angel

- 35 0

1.1.1.6 Max Ascent Speed

– 6m/s

1.1.1.7 Max Descent Speed

– 2m/s

1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA

1.1.2.2 Control A ccuracy

- ±0.03 0

1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0

1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s3132 APPENDIX

– B

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking software enabling the

user to set parameters which will not allow flight into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitu de as well as limit

flight to a predetermined and set distance. In addition, DJI software provides real

- time

altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)33

2.2 DJI Phantom 33435 APPENDIX

– C

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking software enabling the

user to set parameters which will not allow fligh t into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitude as well as limit

flight to a predetermined and set distance. In addition, DJI software provides real

- time

altitude and location inform ation to the PIC via the linked monitor (smart phone/tablet

devices)36

3.3 DJI Inspire 137383940 APPENDIX

– D

DJI SPREADING WINGS S900 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking software enabling the

user to set parameters which will not allow flight into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitude as well as limit

flight to a predetermined and set distance. In addition, DJI software provides real

- time

altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)4142 APPENDIX

– E

DJI SPREADING WINGS S1000 + TECHNICAL SPECIFICATIONS

JAMES J. HARKINS only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking software enabling the

user to set parameters which will not allow flight into co ntrolled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitude as well as limit

flight to a predetermined and set distance. In addition, DJI software provides real

- time

altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)4344 APPENDIX

– F

DJI A2 FLIGHT CONTROLLER TECHNICAL SPECIFICATIONS

(USED AS THE FC FOR DJI SPREADING WINGS S900 & S1000+)

JAMES J. HARKINS only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking software enabling the

user to set parameters which will not allow flight into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermine d and set altitude as well as limit

flight to a predetermined and set distance. In addition, DJI software provides real

- time

altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)4546 APPENDIX

– G

DJI Phantom 2 Manufacturer’s User Manual47 APPENDIX

– H

DJI Phantom 3 Manufacturer’s User Manual48 APPENDIX

– I

DJI Inspire 1 Manufacturer’s User Manual49 APPENDIX

– J

DJI Spreading Wings S900 Manufacturer’s User Manual50 APPENDIX

– K

DJI Spreading Wings S1000+ Manufacturer’s User Manual51 APPENDIX

– L

DJI A2 Flight Controller Manufacturer’s User Manual52 APPENDIX

– M

MONTHLY MAINTENANCE LOG

U A S : $ D a t e I s s u e

D is c o v e r e d D a t e I s s u e

A dd r e s s e d I ss u e D e s cr i p t i on & M a i n t e n a n c e C o n du c te d M a i n t e n a n c e P e r fo rm e d By:

( P r i n t & S i g n )

S of t w a re ( U pd a t e s )

A i r f r a m e

En g i n e s

P r op e l l e r s

C a m e r a ( G i m b a l )

L a nd i n g ( G e a r )

V i b r a t i on ( D a m p e n i n g )

O t h er :