ELECTRONIC SUBMISSION

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and

Past 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Todd Livdahl

, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix

A, to a llow commerci al operation o f a variety of UAS weighing les s than 55 pounds including payload

, provided such operations

are conducted within and under the conditions outline d herein or as may be established by the F AA as required by Section 333.

Appendix B attached to this exemption petition lis ts the aircraft that petitioner contemplates ope rating. In addition, petitioner

requests that it be granted permi ssion to operate those aircraft already approved in p revious Section 333 exemption petitions

(namely: exemptions: 11062, 11109, 11112, 11213, 11345, 12646, 12700, and 12701 ). P rofessional services would be provided

in the following areas:

1. Television and Movie Productions

2. Aerial Photography / Videography / Cinematography

3. Search and Rescue

4. Real Estate

5. Internet Video Productions

6. News

7. Tower / Crop / Roof Inspections

As described fully below, the requested exemptio n would permit the operation of a variety of small UA S as set forth in this

docu ment (Appendix B) under controlled conditio ns in the NAS that wo uld be a) limited b) controlled c) pred etermined and d)

safe. Approval of this exemption would increase public awareness of UAS operations and enhance safety to aid in fulfilling the

Secretary of Transportation's (the FAA Administrator 's) responsibilities to ".... esta blish requirements for the safe operation of

such aircraft systems in the national airspace system."

The name and address of the applicant are:

Todd Livdahl

PO BOX 27602

Anaheim, CA 92809

From which exemption is requested : 14 CFR 21 subpart H

14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CF R 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2)

14 CFR 91.417(a) and (b)

14 CFR 107.29

14 CFR 107.3314 CFR 107.35

14 CFR 107.37 (a)

14 CFR 107.39

14 CFR 107.41

14CFR 107 .51

Grants of exemption in circumstances simil ar in all material respects, In Gr ants of Exemption Nos. 11062 to Astraeus Aerial (see

Docket No. FAA−2014− 0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to V DOS Global, LLC (see Docket

No. FAA−2014−0382), 11213 to Ae ryon Labs, Inc. (see Docket No. FAA−2014−0642), and 12645 to All ied Drones (see Docket No.

FAA

- 2014

- 0804) Exemption Nos. 1106 2, 11109, 11112, 11213, and 12645; Nos. 11062, 11109, 11112, 11213, and 12645.

Additional Information.

The applicant Todd Livdahl seeks exemption for the FARs set forth in Appendix A

, and believes this exemptio n

request and associated safety con siderations adequately satisfy criteria provid ed in Section 333 of the Reform Act

of 2012, providing sufficient ju stification for the granting of commercial operations of the applicant's UAS

.

Thank you for your attention to this matter.

Sincerely,

Todd Livdahl

### LEGAL STANDARD UNDER SECTION 333

Petitioner submits that grant of this exemption application for use of the selected aircraft for

aerial data collection will advance the Congressional mandat e in Section 333 of the Reform Act

to accelerate the introduction of UASs into the national airspace system (“NAS”) if it can be

accomplished safely. This law directs the Secretary of Transportation to consider whether

certain UASs may operate safely in th e NAS before completion of the rulemaking required

under Section 332 of the Reform Act. In making this determination, the Secretary is required to

determine which types of UASs do not create a hazard to users of the NAS or the public or pose

a threat to na tional 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; and

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

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

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

of such aircraft in the national airspace system.” Id. § 333(c) (e mphasis added). 1



### 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 subsectio n (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 U.S.C. § 44711(a); 49 U.S.C. § 44704; 14 C.F.R.

§ 91.203(a)(1).

The grant of th e 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 UASs

for aerial surveying. Accordingly, the applicant respectfully requests that the FAA grant the

req uested exemption without delay. 2

1 Applicant s ubmits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 3 33, but for the

Administrator, if he deems the conditions proposed herein require modification to allow approval, to supply conditi ons for the safe operation of the

UAS. Petitioner welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this propo sal may raise that they

believe may require modification.

2 In filing this application, petitione r also is requesting that the FAA combine the grant of the Section 333 exemption with a stand

- alone Certificate

of Operation (“COA”) that will allow commercial operations without the necessity of filing for a COA for each flight. Complia nce with the condit ions

agreed to herein and that may be imposed by the FAA, as set forth in prior Section 333 exemptions, provide the separation nee ded from other

aircraft.AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for at

least an equivalent or even higher level of safety to operations under the current regulatory

structure because the proposed operations represent a safety enhancement to operations that

would be conducted with conventional aircraft. These conditions are drawn from Exemptions

11062, 11109, 11112, 11213, 11345, 12646, 12700, and 12701.

These limitations and condi tions to which Todd Livdahl , (or “petitioner” or “operator”)

agrees to be bound when conducting commercial operations under an FAA issued exemption

include:

1. Oper ations of the UAS include the aircraft listed in Appendix B, which are miniature

aircraft that weigh less than 55 pounds, and other aircraft previously approved for

exemption under Section 333.

2. The UA may not be flown at an indicated airspeed exceeding 50 knots.

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

(“AGL”). All altitudes reported to Air Traffic Control (“ATC”) must be in feet AGL.

4. The UA must be operated within visual line of sight (“VLOS”) of the pilot

- in

- command

(“PIC”) at all times. This requires the PIC to be able to use human vision unaided by any

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

- issued airman

medical certificate.

5. All operations must utilize a visual observer (“VO ”). The VO may be used to satisfy the

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

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

before the flight and cannot transfer his or her design ation for the duration of the flight.

The PIC must ensure that the VO can perform the functions prescribed in the operator’s

manual.

6. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe

flight. If the inspection rev eals 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 is found to be in a condition for safe flight. The ground control

station must be include d in the preflight inspection. All maintenance and alterations

must be properly documented in the aircraft records.

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

or flight characteristics, e.g., replacement of a fli ght critical component, must undergo a

functional test flight in accordance with the operator’s manual. The PIC who conducts

the functional test flight must make an entry in the UAS aircraft records of the flight.

8. The preflight inspection section in the manuals includes the following requirement: the

preflight inspection must account for all discrepancies, i.e., inoperable components,

items, or equipment, not covered in the relevant preflight inspection sections of the

operator’s manual.9. The operator must follow the manufacturer’s UA aircraft/component, maintenance,

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

flight critical components that may not be addressed i n the manufacturer’s manuals.

10. Operator must carry out maintenance, inspections, and record keeping requirements

in accordance with the manuals. Maintenance, inspection, and alterations must be

noted in the aircraft logbook, including total flight hours and description of work

accomplished.

11. Each UAS operated under the exemption must comply with all manufacturer’s system

and safety bulletins.

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

- class airman medical

certificate. Th e PIC must also meet the flight review requirements specified in 14 C.F.R.

61.56 as to the UAS.

13. The operator may not permit any PIC to operate unless that PIC has demonstrated

that the PIC is able to safely operate the UA in a manner consistent with ho w the UAS

will be operated under this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles, and structures.

14. If the UAS loses communications or loses its GPS signal, the UA must return to a

predetermined location within the private or controlled

- access property and land or be

recovered in accordance with the manuals.

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

accordance with the manuals.

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

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

and, assuming normal cruising speed, to fly after that for at least 10 minutes.

17. All aircraft operated in accordance with the exemption must be identified by serial

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

(N

- Numb er) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must

be as large as practicable.

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

control of the UA must comply with the Federal Communications Comm ission (“FCC”) or

other appropriate government oversight agency requirements.

19. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the PIC

at the ground control station of the UAS any time the aircraft is operating. These

documen ts must be made available to the Administrator or any law enforcement official

upon request.

20. The UA must remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehic les, parachute activities,

parasailing activities, hang gliders, etc.).

21. The UAS may not be operated by the PIC from any moving device or vehicle.22. UAS operations may not be conducted during night, as defined in 14 C.F.R. 1.1.

23. All operations shal l be conducted in Class G airspace.

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

25. During operations in Class G airspace, the UA may not operate within 5 nautical miles of

the geographic center of an airport as denoted on a current FAA

- published aeronautical

chart unless a letter of agreement with that ai rport’s management is obtained, and the

operation is conducted in accordance with a NOTAM as required by the operator’s COA.

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

Administrator upon request.

26. The UA may not be operated over congested or densely populated areas. These

populated areas include, but are not limited to, the yellow areas depicted on World

Aeronautical Charts (“WAC”), Sectional Aeronautical Charts (“Sectionals”), or Terminal

Area Charts (“TAC”). However, aeronautical charts may not reflect pertinent local

information. Ultimately, it is the PIC’s responsibility to maintain the minimum safe

altitudes required by § 91.119.

27. Operations must be conducted at least 500 feet from a ll nonparticipating persons

(persons other than the PIC or VO), vessels, vehicles, and structures unless:

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

from debris in the event of an accident. The operator must en sure that

nonparticipating persons remain under such protection. If a situation arises in which

nonparticipating persons leave such protection and are within 500 feet of the UA,

flight operations must cease immediately; and/or

b. the aircraft is operated n ear vessels, vehicles, or structures where the land

owner/controller has granted permission and the PIC has made a safety assessment

of the risk of operating closer to those objects; and

c. operations near the PIC or VO do not present an undue hazard to th e PIC or VO, per

§ 91.119(a).

28. 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 or authorized representative w ill be obtained for each flight to be

conducted.

29. In the event COAs are required, 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

.APPENDIX A

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

Command; Commercial Pilot Privileges and Limita tions.

Section 61.113(a) & (b) limit private pilots to non

- commercial operations. Unlike a conventional

aircraft that carries a pilot, passengers, and cargo, the selected aircraft in this case are remotely

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

individual with a commercial pilot’s license to be pilot in command of any aircraft for

compensation or hire. Petitioner respectfully proposes that operator requirements should take

into account the characteristics of the particular UASs. The UAS contemplated have a high

degree of pre

- programmed control and various built

- in technical capabilities that strictly limit

— or

allow the operator to control

— the potential for operation outside of the operating conditions set

forth in the exemption application.

Many of the UAS contemplated have autonomous navigation and control systems. Flights are

preprogrammed with precision GPS guidance and do not require human intervention. In the

case of unplanned events, the operator can manually intervene to take one of the following

actions:

(i) command the aircraft to begin to autonomously return to the recovery area and land;

(ii) command the aircraft to autonomously return to the recovery are a where the pilot will

assume control and land the aircraft; or(iii) manually assume control of the aircraft via the hand

controller and return the craft to the recovery area where the operator lands it.

Additional automated safety functions and safety enh ancing features are common on the

contemplated aircraft.

The risks associated with the contemplated aircraft (given their size, speed, operational

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

with commerci al operations contemplated by Part 61 with conventional aircraft (fixed wing or

rotorcraft) that allowing operations of the UAS as set forth above meets or exceeds the present

level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of

requiring a commercial pilot to operate the aircraft under § 61.133(a).

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

operation of the selected aircraft, with a private pilot’s certificate, under the conditions set forth

in the exemption request. The FAA has granted exemptions to conduct similar operations in

Exemptions 11062, 11109, 11112, 11213, 11345, 12646, 12700, and 12701.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

The regulati on requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft petitioner

contemplates operating, should this exemption be granted, no FAA regulatory standa rd

will exist for determining airworthiness. Given the size of the aircraft and the operational

restrictions put on the aircraft, an equivalent level of safety will be provided. The FAA has

granted exemptions to conduct similar operations in Exemptions 110 62, 11109, 11112, 11213,

11345, 12646, 12700, and 12701.

14 C.F.R. § 91.119(c): 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 congeste d areas to an altitude of 500 feet above thesurface, 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 contemplated aircraft, will never operate at higher than 400 feet AGL.

They will, however, be operated to avoid congested or populated areas that are depicted in

yellow on VFR sectional charts. Because aerial survey work must be ac complished 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 selected aircraft are built. Also, no flight will be taken without the permission of the

landowner or those who control the land as well as local officials. Because of advance notice to

the landowner, all affected individuals will be aware of the survey flights. Compared to aer ial

survey operations conducted with aircraft or rotorcraft weighing far more than 5.5 lbs. and

carrying flammable fuel, any risk associated with these operations will be far less than the risks

currently posed by conventional aircraft operating at or belo w 500 feet AGL. Indeed, the lowaltitude

operations of the UAS will maintain separation between these small

- UAS operations

and the operations of conventional aircraft that must comply with Section 91.119. The FAA has

granted exemptions to conduct similar op erations in Exemptions 11062, 11109, 11112, 11213,

11345, 12646, 12700, and 12701.

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 un less (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 th at for at least 45 minutes.”

Petitioner believes that an exemption from 14 C.F.R. § 91.151(a) is safe and within the scope of

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

without compliance with 91.151(a)). Operati ng the small UAS 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 UAS operates. The fact that it carries no pilot, passenger, or cargo also

enhances its safety. Limiting sUAS flights to 30 minutes would greatly reduce their utility. In the

unlikely event that the sUAS achieves a low battery state, it would simply land. Given their

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

Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of a variety of

UAS during daylight hours in visual flight rules (VFR) c onditions to continue until 90 percent of

remaining battery power or fuel reserves remain. Petitioner seeks the requested relief because

without an exemption from Section 91.151(a)(1), the flight time duration of the selected aircraft

will be reduced and s everely constrain the practicality of any aerial data collection that petitioner

proposes to conduct pursuant to this Petition

The technical specifications of the proposed UAS, their Operations Manuals, and petitioner’s

proposed operating limitations, ensu re that petitioner will safely operate the selected aircraft

during daylight hours in VFR conditions until 90 percent of remaining battery power or fuel

reserves remain.

Similar exemptions have been granted to other operators, including Exemptions 2689F, 5 745,

10673, 10808, and Exemptions 11062, 11109, 11112, 11213, 11345, 12646, 12700, and 12701.14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): 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 m akes 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.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to petitioner. Maintenance will be accomplished pursuant to the

User Guide or Operating Manual. An equivalent level of safety will be achieved because these

UASs are limited in size and will carry a small payload and operate only in restricted areas for

limited periods of time. If mechanical issues arise, the UAS can land immediately and will be

operating from no higher than 400 feet AGL. The PIC will ensure that the UAS is in working

order prior to initiating flight, perform required maintenance, and keep a log of any maintenance

performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to

maintain the aircraft in an airworthy condition to provide the e quivalent level of safety. The FAA

has granted exemptions for similar operations in Exemptions 11062, 11109, 11112, 11213,

11345, 12646, 12700, and 12701.

14 C.F.R. § 91.405(a): Civil aircraft flight manual, marking and placard requirements

The UAS, given its size and configuration has no ability or place to carry such a flight manual on

the aircraft, not only because there is no pilot on board, but because there is no room or

capacity to carry such an item on the aircraft. The equivalent level of safety wi ll be maintained

by keeping the Operating Manuals at the ground control point where the pilot flying the UAS will

have immediate access to it.

14 C.F.R. § 91.103: Preflight action

This regulation requires that each pilot in command take certain actions bef ore flight to ensure

the safety of flight. An exemption is needed from this requirement, as the pilot will take separate

preflight actions, including checking for weather conditions, checking flight battery or fuel

requirements, checking takeoff and landin g distances, and all other actions in the Operating

Manual and safety checklists. These actions will provide an equivalent level of safety.

14 C.F.R. § 91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. By design, UAS do not have fully functional dual controls. Flight control is

accomplished through the use of a control box that commun icates with the aircraft via radio

communications. The equivalent level of safety is provided by the fact that neither a pilot nor

passengers will be carried in the aircraft, the ability to control the UAS via radio signals from the

controller and by the s ize and speed of the aircraft.14 C.F.R. § 91.121: Altimeter Settings

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

reference to an altimeter that is set “...to the elevation of the departure airport or an app ropriate

altimeter setting available before departure.” As the UAS may not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of

safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS

altitude indicator before flight.

14 C.F.R. § 91.203(a) & (b): Carrying civil aircraft certification and registration

The UAS has no cabin, cockpit or pilot stat ion and is operated without an onboard pilot.

Therefore, there is no ability or place to carry certification and registration documents or

to display them on the UAS. An equivalent level of safety will be achieved by keeping

these documents at the ground c ontrol point where the pilot flying the UAS will have

immediate access to them, to the extent they are applicable to the UAS.

14 C.F.R

. § 1 07.29 Daylight operation.

(a) No person may operate a small unmanned aircraft system during night.

(b ) No person may operate a small unmanned aircraft system during periods of civil twilight unless the small

unmanned aircraft has lighted anti

- collision lighting visible for at least 3 statute miles. The remote pilot in

command may reduce the intensity of t he anti

- collision lighting if he or she determines that, because of operating

conditions, it would be in the interest of safety to do so.

(c) For purposes of paragraph (b) of this section, civil twilight refers to the following:

(1) Except for Alaska, a pe riod of time that begins 30 minutes before official sunrise and ends at official sunrise;

(2) Except for Alaska, a period of time that begins at official sunset and ends 30 minutes after official sunset; and

(3) In Alaska, the period of civil twilight as d efined in the Air Almanac.

14 C.F.R. § 107.33 Visual observer.

If a visual observer is used during the aircraft operation, all of the following requirements must be met:

(a) The remote pil ot in command, the person manipulating the flight controls of the small unmanned aircraft

system, and the visual observer must maintain effective communication with each other at all times.

(b) The remote pilot in command must ensure that the visual observ er is able to see the unmanned aircraft in the

manner specified in § 107.31.

(c) The remote pilot in command, the person manipulating the flight controls of the small unmanned aircraft

system, and the visual observer must coordinate to do the following:

(1 ) Scan the airspace where the small unmanned aircraft is operating for any potential collision hazard; and

(2) Maintain awareness of the position of the small unmanned aircraft through direct visual observation.

14 C.F.R. § 107.35 Operation of multiple small unmanned aircraft.

A person may not operate or act as a remote pilot in command or visual observer in the operation of more than

one unmanned aircraft at the same time.

14 C.F.R. § 107.37 Operation near aircraft; right

- of

- way rules.

(a) Each small unmanned aircraft must yield the right of way to all aircraft, airborne vehicles, and launch and

reentry vehicles. Yielding the right of way means that the small unmanned aircraft must give way to the

aircraft or vehicle and may not pass over, under, or ahead of it unless well clear.14 C.F.R. § 107.39 Operation over human beings.

No person may operate a small unmanned aircraft over a human being unless that human being is:

(a) Directly participating in the operation of the small unmanned aircraft; or

(b) Located under a covered structure or inside a s tationary vehicle that can provide reasonable protection from a

falling small unmanned aircraft.

14 C.F.R. § 107.41 Operation in certain airspace.

No person may operate a small unmanned aircraft in Class B, Class C, or Class D airspace or within the lateral

boundaries of the surface area of Class E airspace designated for an airport unless that person has prior

authorization from Air Traffic Co ntrol (ATC).

14 C.F.R. § 107.51 Operating limitations for small unmanned aircraft.

A remote pilot in command and the person manipulating the flight controls of the small unmanned aircraft system

must comply with all of the following operating limitations when operating a small unmanned air craft system:

(a) The groundspeed of the small unmanned aircraft may not exceed 87 knots (100 miles per hour).

(b) The altitude of the small unmanned aircraft cannot be higher than 400 feet above ground level, unless the

small unmanned aircraft:

(1) Is flo wn within a 400

- foot radius of a structure; and

(2) Does not fly higher than 400 feet above the structure's immediate uppermost limit.

(c) The minimum flight visibility, as observed from the location of the control station must be no less than 3 statute

mi les. For purposes of this section, flight visibility means the average slant distance from the control station at

which prominent unlighted objects may be seen and identified by day and prominent lighted objects may be seen

and identified by night.

(d) The minimum distance of the small unmanned aircraft from clouds must be no less than:

(1) 500 feet below the cloud; and

(2) 2,000 feet horizontally from the cloud.



### APPENDIX B

1. 2AgEagle

2. 3D Robotics Aero

- M

3. 3D Robotics Iris

4. 3D Robotics Iris+

5. 3D Robotics X8

6. 3DRobotics Fixed Wing

7. 3DRobotics Multirotor

8. 3DRobotics Quadrotor

9. 3DR Solo

10. 3DR Spektre

11. 3DRobotics Spektre Industrial Multi

- Rotor Aerial Vehic le

12. 3D Robotics Solo

13. 3DRobotics X8+

### 14. 3D Robotics X8

- M

15. 3D Robotics Y6

16. Aerial Mob Heavy Lifter

17. Aerial Mob Light Lifter

18. Aerial Remote Mineral Detection System (ARMDS)

19. Aerialtronics Zenith with intergrated Airware system

20. Aerialtronics Altura Zenith ATX8

21. Aerigon

22. Aerobo

23. AeroCine Kopterworx Hammer X12

24. Aeromao AeroMapper 300

25. Aeromao Talon

26. Aeromao Aeromapper 300

27. Aeromao Aeromapper EV

- 2

28. AeroVironment Shrike

29. AeroVironment Puma

30. Aeronavic s X4 Titanium

31. Aeryon Sky Ranger

32. Aervonics Sky Jib frame with a DJI A2 flight system

33. Aero

- M

34. Aeryon Scout

35. Aeryon SkyRanger

36. AgEagle

37. AgEagle Robotic

38. AgScout

39. AgScout Mini

40. Agribotix Hornet Drone

41. Agribotix Enduro Quad

42. AgriView VK Ranger EX

43. Aibot

44. Aibotix X

- 6

45. Air Rover AR

- 3000

46. AirCover QR

- 425s

47. AirRobot AR 180

48. AirRobot AR 100

49. AirRobot AR200

50. Air

- X

51. Align M690

52. Altavian Nova

53. Altavian Nova F6500

54. Altavian Nova R8400

55. Altus X

- 4

56. Altus X

- 8

57. American Drones, LLC Eagle

58. Apprentice

59. Arch Aerial OCTO multi

- rotor UAS

60. Arris hexacoper

61. AR

- 960 Hex Rotor

### 62. AR

- 540 Quad Rotor

63. ARF

- MikroKopter OktoXL

64. ARF

- MikroKopter OktoXL +

65. ArrowLite

66. AscTec Falcon

67. A scTec Falcon 8

68. Astraeus Aerial Cinema System V.3CS

69. Atlantic RC Aircraft LC04

70. Auburn Trimble UX5

71. Auburn War Eagle

72. Auburn EasyStar

73. Auburn

74. AV44

75. Bixler 3DR Plane

76. Blade 350QX

77. Bixler 2

78. Boomerang Carbon Fiber Frame (The Identified System)

79. Bormatec Maja UAV

80. BOSH Technologies Super Swiper

81. Bumblebee

- S

82. C

- Astral Bramor gEO

83. CarbonCore Octocopter 1000

84. Carbon Core Cortex Quadcopter

85. CCO w/Wkm M

86. Chameleon Pro

87. CinesStar

88. Cinestar 6

89. Cinestar X8

90. Cinestar 8

91. Cinestar 8 HL

92. Cinestar 8 Okto XL

93. Coaxial Quad Multirotor VAO1

- V1

94. Coaxial Quad Multirotor VAO2

- V2

95. CopelandRED LLC Delta Wing Aircraft

96. CyberQuad Maxi

97. DJI Flame Wheel F450

98. DJI Flame Wheel F550

99. DAx8

100. DJI Inspire

101. DJI Inspire 1

102. DJI Inspire 2

103. DJI M P330z

104. DJI Phantom

105. DJI Phantom 1

106. DJI Phantom 2

107. DJI Phantom 2+

108. DJI Phantom 2 Vision

109. DJI Phantom 2 Vision+

### 110. DJI Phantom Visio n +

111. DJI Phantom 3

112. DJI Phantom FC40

113. DJI Spreading Wings S900

114. DJI Spreading Wings S1000

115. DJI Spreading Wings S1000+

116. DJI S800

117. DJI S800 EVO

118. DJI T600

119. Draganflyer Guardian

120. Draganflyer X4ES

121. Draganflyer X4P

122 . Draganflyer X6

123. DT

- 18

124. DYS D800

- X8

125. Eagle VTOL

126. Eagle V2

127. E

- Flite Apprentice

128. Event 38 E384

129. F

- 450

130. Falcon VTOL

131. Fire Fly 6

132. First Aerial Responder UAV

133. Flame Wheel G4 7.8 Skycrane

134. Flying

- Cam 3.0 SARAH

135. Foxtech Kraken 130 V2

136. FreeFly Systems ALTA RTF

137. FreeFly Systems Octocopter Airframe (Legacy)

138. G4

139. G4 models

140. GeoStar

141. GerMAP G220

142. GerMAP G180

143. goFarm GF

- 1

144. Gryphon Dynamics X8

145. GT80X

146. Harris 18 HL

147. HEF F

148. Helicopters West DJI Inspire

149. Helicopters West SkyJib 8

150. Helios 960

151. Hawkeye Mk

- III

152. HexaCrafter HC

- 1100 85.

153. HexaCrafter HO

- 1250

154. HH Blade 350QX2 AP

155. Hobbyking “Bixler” Fixed Wing Trainer

156. HoneyComb AgDrone

157. Horizon Hobby Blade 350 Qx2 quadcopter

### 158. Hoverfly LiveSky, BigSky 60 and H

- Frame

159. Hubsan X4 micro drone

160. HVP 14301 Multi Rotor

161. Identified System

162. IMT Global xFold Cinema

163. Indago

164. InovalDrone:Inova One

165. InstantEye Mk

- 2

1 66. InstantEye Mk

- 2 Gen2

167. Intuitive Aerial Aeragon

168. K130 Octocopter

169. KongCopter X8

170. Kopterworx Hammer X12

171. Latitude HQ

- 4 Hybrid Multirotor

172. LB700

173. Leading Edge Precision Vision 10

174. Leptron Avenger

175. Lewis Realty Associate s Hexacopter 650

176. Liberty 1

177. Lockheed Martin Desert Hawk III

178. Lockheed Martin Indago

179. Matrix quad copter

180. MaxFlight

181. MD4

- 200

182. MD4

- 1000

183. Mikrokopter 2.5

184. MLB Company Super Bat

185. MU

- 1H

186. Multirotor G4 7.8 Skycrane

187. Nighthawk

188. Nighthawk VTOL

189. OktoXL 6S12

190. PAG X4

191. Parksone Radian RTF

192. Parrot Bebop drone

193. Parrot PF 725100 Bebop Drone 14MP

194. Parrot Skycontroller

195. Patriot X4

196. Patriot X8

197. Finwing Penguin V2

198. Birdseyeview Fire Fly 6

199. Phoenix

200. Phoenix VTOL

201. Phoenix 60

202. Phoenix 60LE

203. Pixhawk

204. Precision Drone Pacesetter

205. PrecisionHawk

### 206. PrecisionHawk Hawkeye Mk

- III

207. PrecisionHawk Lancaster

208. Precision Lancaster MK3

209. Prioria Hex

210. Prioria ’s Maveric

211. Pulse Aerospace, PA 01 Vapor

212. Pulse Aerospace Pulse Vapor 35

213. Pulse Vapor

214. Puma AE DDL

215. PV 14817 Multi Rotor

216. PV HL1

217. PV HL2

218. Q1

219. Quadcopter LLC MikroKopter

220. Quiet UAV

221. Qube

222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift Prof.

Multi Rotor

223. Frame Ronin Edition Microdrones:MD4

- 1000

224. RCTimer Hexacopter

225. RDASS

226. REHawk 500

227. REHawk 680

228. RF

- 70

229. Riegl RiCopter

230. RITEWING Z3 Spade 47”

231. Ritew ing Drake 60”

232. RITEWING Z3 Spade 70”

233. RITEWING Z4 Spade 52”

234. RMAX

235. Roboflight

236. Rotomotion SR

- 15

237. RV Jet

238. Scout X4

239. SD02

240. Seahawk 1.2

241. SelectTech Geospacial’s EH

- 4

242. SenseFly eBee

243. SenseFly eBee RTK

244. SenseFly eXom

245. Sensurion Magpie MP

- 1

246. Service

- Drone Recon One

247. Service

- Drone Blackbird

248. SH 900

249. ShadowHawk

250. Shrike

251. Sirius

252. SkyCatch

### 253. SkyJib 8 v.2 Heavy Lifter

254. SkyPhilly MI

255. Skywalker Aero

256. Skywalker Fl ying Wing X8

257. SnapRoll Media SUAS

258. Solutions Phoenix 30

259. SteadiDrone

260. Steadidrone Quad

261. Steadydrone QU4D

262. Steadidrone Mavik

263. SuperX/P2 Multirotor

264. Swift Radioplanes Lynx

265. Tali 500

266. Talon 120LE

267. Tarot FY690S Hexacopter

268. Tarot quadcopter

269. Tarot 680pro

270. Tarot 690

271. Tarot 900

272. Tarot 960

273. Tarot T

- 15

274. Tarot T15 C/F Folding Octocopter

275. Tarot T18 UAV

276. Tarot T690

277. Tarot T810

278. Tarot T960

279. Tarsier Systems MoAC

280. Tayzu Robotics Titan X8

281. TBS Discovery Pro

282. Team Black Sheep Discovery Pro Tarot T15

283. T

- Rex 700E F3C

284. TREX 800E DFC PRO

285. Trimble UX5

286. Trimble UX5 hp

287. Trimble ZX5

288. Turningy Talon 500

289. TUP X8

- 800

290. Turbo Ace C INEWING 6

291. TurboAce Matrix

- G quadcopter

292. Turbo Ace matrix

- E

293. Turbo Ace MATRIX

- 1

294. UAV Solutions Phoenix 60

295. Universeye Penguin

296. Unmanned Flying Rolling Orb “UFRO”

297. US2 GreenHawk

298. UtiliCopter ITX8

299. VA03

- v1

300. VA04

- v1

### 301. VA07

- v1

302. Viking UAS Multicopter (VTOL)

303. Viking UAS FF

- X4/X8

304. VK

- Patriot X4/X8

305. Viking UAS Patriot X4/X8 Multirotor

306. Viking UAS X6 Model 800

307. Viking UAS Viking ONE

308. VK

- 450

309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

310. Viking VK

- FF

- X4

311. VK

- Ranger EX

- SAR Fixed Wing UAS

312. Volantex Raptor Tarot T

- 18

313. Volt Aerial Robotics Octane

314. Vulcan frame controlled by a DJI A2 flight controller

315. Vulcan Mantis

316. Vulcan Octocopter

317. Vulcan Raven

3 18. Vulcan UAV

319. Walkera TALI H500

320. Walkera Scout X4

321. Wookong DJI 5800

322. xCel Drones XD550CDR

323. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12

Copter

324. X8

- M