UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

BILLY R. COOK JR.

FOR AN EXEMPTION SEEKING R ELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 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 3, LILY 1, AND DJI INSPIRE 1 UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on July 13 , 2015

BILLY R. COOK JR.

1853 Palomino Trail Suffolk, VA 23432

757

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- 8486TABLE OF CONTENTS Page

GLOSSARY OF

ABBREVIATIONS.................................................................................................................3

SUMMARY.................................................... ......................................................................... 4

INTRODUCTION AND INTERESTS OF PETITIONER......................................................4

BACKGROUND..................................................................................................................... 5

BASIS FOR PETITION........................................................................................................... 5

NAME AND ADDRESS OF PETITIONER................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

BILLY R. COOK JR. SEEKS EXEMPTION.........................

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

THE E XTENT OF RELIEF BILLY R. COOK JR. SEEKS AND

THE REASON BILLY R. COOK JR. SEEKS THE RELIEF...

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

THE REASONS WHY GRANTING BILLY R. COOK JR. REQUEST

WOULD BE IN THE PUBLIC INTEREST ............................... ..............................10

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY................................................ ..............................12

CONCLUSION........................................................................................ ...............................19GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View

LI

- PO Lithium Polymer battery

RCV Radio Controlled vehicleSUMMARY

BILLY R. COOK JR. 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 System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit BILLY R. COOK JR. to operate an Unmanned Aircraft System (UAS) for the commercia l purpose of conducting ae rial video and photography for m arketing, film sets, real estate photography, commercials, special events, wedding cinematography, and landscape over

certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETI TIONER

My name is BILLY R. COOK JR. , and I am a retired Air Traffic Controller and drone operator (pilot) with expertise and knowledge in aspects of building programing and operating multiple types of UAS'S along with camera set up and operation. My oper ation will provide clients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. BILLY R.

COOK JR. has 34 years of Air Traffic/Airspace experience as well as a lifetime of radio controlled (RC) aircraft experience.

The objective of BILLY R. COOK JR. ’ aerial video and photograph y operations is to provide high quality imaging for a variety of commercia l, public, and residential uses. It is imperative that operations

be conducted a safe location away fro m all obstacles and people at all times. BILLY R. COOK JR. will

also provide knowledge of UAS and promote safe UAS operations.BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs , and Lily UAS

BILLY R. COOK JR. seeks an exemption to operate DJI systems for compensation or hire within the

NAS. The DJI Phantom 3 , Lily 1, and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electroni c tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 h as a maximum gross weight of 6 pounds 7.5 ounces, 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 Phantom 3, Lily 1, and DJI Inspire 1 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The Lily UAS operates as a

“tag along” camera and remains within 30 meters of the operator at all times.

The DJI Phantom 3 , Lily 1, and DJI Inspire 1 UAs t hat will be operated by BILLY R. COOK JR. will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Markings.

BASIS FOR PETITION

Petitioner, BILLY R. COOK JR. , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special

Rules for Certain Unmanned A ircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs in the National 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 limited operating area associated with the unmanned aircraft and its operation, BILLY R. COOK JR. operation of DJI Phantom 3 , Lily 1, and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, BILLY R. COOK JR. 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 requirements for maintenance that only apply

to aircraft with an airworthiness certificate.

BILLY R. COOK JR. submits that th e requested relief is proper since an equivalent level of safety will

be ensured. BILLY R. COOK JR. will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3

, Lily 1, and DJI Inspire 1 Instruction Manual). Furthermore, BILLY R. COOK JR. will document and

maintain all maintenance records for the DJI Phantom 3 , Lily 1, and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by BILLY R. COOK JR. to the extent necessary to allow a Pilot in Command (PIC) hol ding a private pilot or higher level certificate, as well as an airman medicalcertificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements,

that the PIC is able to safely operate the DJI Phantom 3, Lily 1, and DJI Inspi re 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

BILLY R. COOK JR. seeks relief from Section 91.7(a), entitled Civil air craft airworthiness, because

the DJI Phantom 3 , Lily 1, and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, BILLY R. COOK JR. submits that he will

ensure that the DJI Phantom 3 , Lily 1, and DJI Inspire 1UASs 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 3 , Lily1, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

BILLY R. COOK JR. also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 , Lily 1, and DJI Inspire 1 UAs will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 , Lily 1, and DJI Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the G CS for active monitoring of the flight path. This altitude information, combined with BILLY R. COOK JR. operation of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equ ivalent to Section 91.121.

Additionally, BILLY R. COOK JR. seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. BILLY R. COOK JR. submits that safety will not be affected by operation of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15.5 minutes to the first point of int ended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, BILLY R. COOK JR. provides the following information in support of its petition for exemption:

A. Name And Address O f The Petitioner. The name and address of the Petitioner and point of contact is:

BILLY R. COOK JR.

2891 ROUTE 22 PATTERSON, NY 12563 ( 813 )

- 313

- 9939

Email: jaromirrivera@gmail.comB. The Specific Sections Of 14 C.F.R. f rom Which BILLY R. COOK JR. Seeks Exemption.

1. BILLY R. COOK JR. Seeks Exemption From 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 act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, fo r compensation or hire, act as PIC of an aircraft.

b. A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— i. The flight is only incidental to that business or employment; and

ii. The aircraft does not carry passengers or property for compensation or hire.

2. BILLY R. COOK JR. Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled civil aircraft airworthiness, subsection (a), stat es the following: (a) No

person may oper ate a civil aircraft unless it is in an airworthy condition.

3. BILLY R. COOK JR. Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection ( a), states the following, in part:

a. Each person operating an a ircraft shall maintain th e cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- Below 18,000 feet MSL, to

— i. The current reported altimeter setting of a station along the route and within 100

n autical 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;

iii. In the case of an aircraft not equipped wi th a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. BILLY R. COOK JR. Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR c onditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR condi tions 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 afte r that for at least 20 minutes.

5. BILLY R. COOK JR. Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), s tates the following: Each owner

or opera tor of an aircraft

— (a) 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 c hapter[.]

6. BILLY R. COOK JR. Seeks Exemption From The Requirements Of Section 91.407(a) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may oper ate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized un der § 43.7 of this chapter [.]

7. BILLY R. COOK JR. Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unle ss, 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 by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. BILLY R. COOK JR. Seeks Exemption From The Requirements 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 keep the following records for the periods specified in paragraph (b) of this section: Records of the m aintenance, preventive maintenance, and alteration

and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, 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 Administrat or) of the work performed; and

ii. The date of complet ion of the work performed; and

iii. The signature, and certificate number of the person approving the aircr aft for

return to service. Records containing the following information:

1. The total time in service of the airframe, each engine, each propeller, and

each rotor.

2. The current status of life

- limited parts of each airframe, engine, propeller, rotor, and applia nce. 3. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

4. 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.

5. 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. I f the AD or safety directive involves recurring action, the time and date when the next action is required.

6. Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors,

prop ellers, and appliances.

b. The owner or operator shall retain the following records for the periods prescribed:

i. 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 yea r after the work is performed.

ii. The records specified in paragraph (a)(2) of this section shall be retained and

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

iii. A list of defects furnished to a registered owner or operator under § 43.11 o f this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.C. The Extent Of Relief BILLY R. COOK JR. Seeks And The Reason BILLY R. COOK JR.

Seeks The Relief.

1. Extent Of Relief BILLY R. COOK JR. Seeks And The Reason BILLY R. COOK JR. Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current a nd valid airman medical certificate, and who has met certain flight

- hour and currenc y requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is re quested since the limitations set forth in S ection 61.113(a) and (b) state that a private 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 prop erty for compensation or hire. As set forth more fully below, BILLY R. COOK JR. su bmits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requir ements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the operations specifications a s described in this exemption, including evasive and emergency maneuvers, as well as maintain ing appropriate distances from people, vessels, vehicles and structures. Further, BILLY R. COOK JR. submits that all flights of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to BILLY R. COOK JR. ' business; and (2) will not ca rry passengers or property for compensation or hire.

2. Extent Of Relief BILLY R. COOK JR. Seeks And The Reason BILLY R. COOK JR. Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airw orthiness, is requested to the extent required to allow BILLY R. COOK JR. to determine that the DJI Phantom 3, Lily 1, and DJ I Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., BILLY R. COOK JR. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, Lily 1, and DJI Inspire 1 Instruction Manual).

BILLY R. COOK JR. seeks the requested relief bec ause the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs do not require an airworthiness certificate in acco rdance with 14 C.F.R. Part
21, Subpart H. Therefore, BILLY R. COOK JR. will ensure that the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, Lily 1, and DJI Inspire 1

Instruction Manual) prior to eve ry flight, and further, determine that the airc raft are in condition

for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief BILLY R. COOK JR. Seeks And The Reason BILLY R. COOK JR. Seeks

Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to dow nlink altitude information from the UA to the PIC at the ground contr ol station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), BILLY R. COOK J R. seeks the requested

relief because the DJI Phantom 3, Lily 1, and DJI Inspire 1 UA’s altimeter may be set on theground to zero feet AGL, rather than the local barometric pressure or field altitude, before each

flight. 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 limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the

DJI P hantom 3, Lily 1, and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude informa tion of the UA on the

heads

- up display of the GCS.

4. Extent Of Relief BILLY R. COOK JR. Seeks And The Reason BILLY R. COOK JR. Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements fo r flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for a t least 4.5 minutes. BILLY R.

COOK JR. seeks the requested relief because without an exe mption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or stil l photo flight operations that BILLY

R. COOK JR. proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs, the DJI Phantom 3, Lily 1, and DJI Inspire 1 operating documents, and

BILLY R. COOK JR. proposed operating limitations, ensure that BILLY R. COOK JR. will safely operate the battery powered DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight ru les (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of inte nded landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief BILLY R. COOK JR. Seeks And The Reason BILLY R. COOK JR. Seeks Relief From 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 certificate, BILLY R. COOK JR. requests relief from these

Sections because the DJI Phantom 3, Lily 1, and DJI Inspire 1 UAS s do not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an

airworthine ss certificate. Accordingly, BILLY R. COOK JR. will use trained techn icians to perform maintenance, alterations, or preventive maintenance on the UASs usin g the methods, techniques, and practices prescribed in the UAS operating documents (i.e., BILLY R. COOK JR. Aerial Operations Manual, Monthly Mainte nance Log, and DJI Phantom 3, Lily 1, and DJI Inspire 1 Instruction Manual). Furthermore, BILLY R. COOK JR. will document and maintain all

maintenance records for the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs.

D. The Reasons Why Granting BILLY R. COOK JR. 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 BILLY R.

COOK JR. to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs will decreasecongestion of the NAS, reduce pollution, crashes and ac cidents caused by pilot error and

provide significant benefits to the economy. Notably, the benefits of BILLY R. COOK JR. ’ proposed operation of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs will be realized

without implicating any privacy issues.

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

The DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtai n aerial image ry. By reducing the amount of manned aircraft needed to p erform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as inc rease the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs do not require an airport t o takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photog raphy 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 Efficien cy Of The DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs. Conducting aerial acquisitions with the DJI Phantom 3, Lily 1, and DJI In spire 1 UASs, 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 motors, the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious

alternati ve to the cabin class, six cylinder internal combustion engine aircraft that are typically

utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hou r of leaded aviation fuel. The DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pol lution, as the UAs ar e propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and property in the ai r and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fu el 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 approximat ely 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs Will Benefit The Economy. In addition to being safe and efficient, the DJI Pha ntom 3, Lily 1, and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs

will allow United States based companies, l ike Fiquett Drones, to remain competitive and

co ntribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel an d

the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation
fuels, U.S. owned and operated companies must adopt new and alternative technology i n orderto remain competitive. Operating the battery powered DJI Phantom 3, Lily 1, and DJI Inspire 1

UASs is one such technology that not only allows companies greater operational flexibility

co mpared to manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft. By operating the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs, companies such as Fiquett
Drones, and Lily Robotics 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 performance of U.S. companies, through commercial use of

the DJI Phant om 3, Lily 1, and DJI Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the Unit ed States and

abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operation s that have been conducted for decades,

BILLY R. COOK JR. proposed operation of the DJI Phantom 3, Lily 1, and DJI Inspire 1

UASs would not implic ate any privacy issues. Specifically, the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs will be operated only in compliance with operat ing documents (i.e., BILLY R.

COOK JR. Aerial Operations Manual, Monthly Maintena nce Log, and DJI Phantom 3, Lily 1,

and DJI Inspire 1 Instruction Manual) which requires property owne r involvement as well as

local law 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 Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule

From Which BILLY R. COOK JR. Seeks Exemption.

1. Reasons Why The DJI Phantom 3, L ily 1, and DJI Inspire 1 UAs 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 aircraft and its operation, BILLY R. COOK JR. ’ operation of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs meet the conditions of FMRA Sectio n 333, and will not require

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Secti on 333 provides authority for a UAS to operate without airworthiness certificati on and sets forth requirements for considering whether a UAS will create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security. Specificall y, FMRA Section 333 states

the foll owing, 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 Sec retary of Transportation shall determine if certain unmanned aircraft systems may operate s af ely 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

— i. Which types of unmanned aircraft systems, if a ny, 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

n ational airspace system or the public or pose a threat to national security; and

whether a certifi cate of waiver, certificate of authorization, or airworthinesscertification under section 44704 of title 49, Un ited States Code, is required for the operation of unmanned aircraft systems identified 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 airspace system,

the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, BILLY R. COOK JR. submits that the DJI Phantom 3, Lily 1, and DJI Inspire 1 U ASs can operate safely in the NAS pu rsuant to FMRA Section 333,

as demonstrated by: (a) the characteristics of the DJI Phantom 3, Lily 1, and DJI Inspire

1 UASs; (b) the pilot certification requirement; and (c) the s pecific operating

limitations.

i. The Specifications Of The DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs

Demonstrate Its Safe Characteristics.

The DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs do not create a hazard to

users of the NAS or the public, or otherwise pose a threat to nation al security considering its size, weight, speed, and operational capability.

ii. Technical Specifications Of The DJI Phantom 3, Lily 1, and DJI Inspire 1

UASs.

The DJI Phantom 3, Lily 1, and DJI Inspire 1 Specifications and Data Sheet,

attached hereto as Ap pendix A and B, set the technical specifications of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs forth

. iii. The DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs Autonomous Flight

And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs may be ope rated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs is provided at pag es 25

- 35 of the DJI Phantom 3 and pages 12

- 16 and 45

- 50 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

iv. The DJI Phantom 3, Lily 1, and DJI Inspire 1 UAS s Are Designed For

Automatic 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 3, Lily 1, and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds,

the DJI Phantom 3, Lily 1, and DJI Inspire 1 UAs do not rea cquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode ) via GPS, and will

descend to the takeoff position and shutdown. A complete description of the Fails afe Functions of the DJI Phantom 3 UAS are

set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15

of the DJI Phantom 3, Lily 1, and DJI Inspire 1 User Manuals, attached hereto

as Exhibit C and D.

v. The DJI Phantom 3, Lily 1, and D JI Inspire 1 GCS And It’s Operation. A complete description of the operation and specifica tions of the DJI Phantom 3, Lily 1, and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 3 User Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI Phantom 3, Lily 1, and DJI Inspire 1 User

Manuals are attached hereto as Exhibits C and D.vi. Flight Operations Of DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs Are

Limited To The Line Of Sight Of A Certificated Pilot in Co mmand With A Safety Observer.

BILLY R. COOK JR. will only utilize certificated pilots who possess a current

and valid airman medical certificate to act as a pilot in command (PIC ) of the DJI Phantom 3, Lil y 1, and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.

vii. Flights Of DJI Phantom 3, Lily 1, and DJI Inspire 1 UAS s Will Be

Conducted Pursu ant To Specific Operating Limitations. In seeking this exemption, B ILLY R. COOK JR. proposes to commercially

operate DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to th e following specific operating limitation s: 1. Operations authorized by this grant of exemption wi ll be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 3, Lily 1, and DJI Inspire 1 Unmanned Aircra ft Systems. 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 and photography.

3. The UAs m ay 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 P IC

at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lense s, as specified on the PIC’s

FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety ob server (SO) is

not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requir ement as long as the PIC always maintains

VLOS c apability. 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 designation for the duration of the flight. The

PIC must ensu re that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond ass isting the PIC with seeing and avoiding other air traffic and other ground based

obstacles/obstru ctions and is not permitted to operate the camera or other

instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administ rator upon request. If a discrepancy exists between the conditions and limitations contained in the grant o f exemption and the procedures outlined in the operating documents, the conditions and limitat ionscontained in the grant of exemption take precedence and must be

followed. Otherwise , the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to tr ack such revisions and present u pdated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the gran t of exemption. If the

operator determin es that any update or revision would affect the basis upon which the FAA granted the exe mption, then the operator must petition for amendment to its grant of exemption. The FAA’s U AS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operati ng documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

condition f or safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the nec essary main tenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control

Station must be included in the preflight inspection. All maintenance an d alterations must be properly docu mented in the aircraft records.

11. A ny UAS that has undergone maintenance or alterations that affect the

UA S operation or flight characteristics, e.g. replacement of a flight

cr itical component, must undergo a functional test flight. The PIC who

conducts the functional tes t flight must make an entry in the a ircraft

records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered i n the

relevant sections of the operating documents.

13. The operator must follow t he UAS manufacturer’s aircraft /component, maintenance, overhaul, replacement, inspectio n, and life limit requirements.

14. The operator must carry out its maintenance, i nspections, and record keeping requirements, in accordance with the operating documents.

Ma intenance, inspec tion, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accompli shed, and the signature of

the authorized perso n returning the UAS to service.

15. Each UASs operated under this exemption must comply with all

manufacturer Safety Bulletins.

16. The authorized person must make an entry in the air craft record of the

corrective action taken against discrepancies discovered between inspections.

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

current third

- class medical certificate.

18. The operator may not permit any PIC to operate unles s the PIC meets the operator’s qualification criteria and demonstrates the ability to safely

o perate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and e mergency maneuvers and maintaining appropriate distances f rom persons, vessels,vehicles and structures. PIC qualification flight hours must be logged in a

manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the opera tor’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. Dur ing training, proficiency, and ex perience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must o perate the UA with appropriate distance from nonparticipants in accord ance with 14 C.F.R. §

91.119

. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA offi ce closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference 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 conduc ted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport managem ent

must be made available to the Administrator upo n request.
21. 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.

22. If the UA loses communications or loses its GPS s ignal, it must return to

a pre

- d etermined 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 event of unpredicte d obstacles or emergencies in accordance with the operating documents.

24. The PI C 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 obta in an Air Traffic Organizati on (ATO) issued

Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the

operator to requ est a Notice to Airman (NOTAM) not more than 72 hours

i n advance, but not less than 48 hou rs prior to the operation. All operations shall be conducted in accordance with airspace requirements

in the ATO issued CO A including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemptio n must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and

have identifica tion (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C . Markings must be as large as prac ticable.

27. Before conducting operations, the radio frequency s pectrum used for operation and control of the UA must comply with the Federal

Communicat ions Commission (FCC) or other appropriate government oversight agency requirements.28. The documents require d fewer than 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 UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UA m ust remain clear and yield the right of way to all manned aviation operation s and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or

vehicle.

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

non partici pating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehic les, 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 protectio n. If a

situation arises where nonparticipating persons leave such protection and are wit hin 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 th e PIC has made a safety assessment of the risk of operating closer to those objects and deter mined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator traine es 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 c ontrolled

- access property with permission from the land owner/controller or authorized

repres entative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight op eration that transg resses the lateral or

vertical boundaries of the operational area as defined by the applicab le COA must be reported to the FAA's UAS Integration Office (AFS

- 80)

within 24 hours. Acc idents must be reported to the National Transportation S afety Board (NTSB) per instructions containe d on the

NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requireme nts Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

BILLY R. COOK JR. submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3, Lily 1, and DJI Inspire 1 UASs unless that PIC has de monstrated, by meeting

minimum flight

- hour and currency requirements, that the P IC is able to sa fely operate the DJI

Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the ex emption, including evasive

and emergency maneuvers and maintaining appropriate distances from people, vessels , vehicles

and structures. Considering BILLY R. COOK JR. ’ proposed area of operations, and the operating limitations

set forth

- above; the parallel nature of privat e pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS, BILLY R. COOK JR.submits that the additional manned airmanship experience of a commercially certificated

pilot would not correlate to the airmanship skills necessary for BILLY R. COOK J R. ’ specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) 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, 1111 0, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). BILLY R. COOK JR. will not allow any PIC to operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum fligh t

- hour requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with this exemption, including e vasive and emergency mane uvers and maintaining appropriate distances from people, vess els, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a ma nner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a m inimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3

takeoffs and landings in the preceding 90 days (for cu rrency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during BILLY R. COOK JR. ’ proposed operations. The A dministrator has held that prior documented flight experience t hat was obtained in compliance with applicable regulations

would ensure safe o perations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 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 mul ti

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FA A considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10

hours of multi

- rotor time and the 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 landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight hour 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 prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficienc y, and experience

building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in acc ordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15. Accordingly, BILLY R. COOK JR. will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PI C has demonstrated, by meeting

minimum fl ight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with th e exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vesse ls, vehicles

and structures.CONCLUSION

BILLY R. COOK JR. 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 3, Lily 1, and DJI Inspire 1 UASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing BILLY R. COOK JR. to safely, efficiently, and economically operate the DJI Phantom 3, Lily 1, and D JI Inspire 1 UA Ss commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, BILLY R.

COOK JR. respectfully requests that the Administrator grant this Petition for an exemption from 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 BILLY R. COOK JR. to operate the DJI Phantom 3, Lily 1, and DJI Inspir e 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: October 20, 2015 Submitted by

BILLY R. COOK JR.APPENDIX

– A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

BILLY R. COOK JR. 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/t ablet devices)

DJI Phantom 3

1.1 Aircraft

1.1.1 Supported Battery

– DJI 6000AH LiPo Battery

1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

1.1.4 M ax Yaw Angular Velocity

- 200/s

1.1.5 Max Tilt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s

1.1.6 Max Descent Speed

– 2m/s

1.1.7 Max Flight S peed

– 15m/s (NOT RECOMMENDED)

1.2 Gimbal

1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA

1.2.2 Control Accuracy

- ±0.03

1.2.3 Controllable Range

– Pi tch:

- 90

- 0

1.2.4 Maxim um Angu lar Speed

– Pitch: 90/s

1.3 Camera

1.3.1 Operating Temperature Range

- 32F

- 104F (0C

- 40C)

1.3.2 Sensor Size

– 1/2.3”

1.3.3 Effective Pixels

– 14M

1.3.4 Resolution

– 4384x3288

1.3.5 HD Vide o Recording

– 1080p30 & 720p

1.3.6 Recording Field of View

- 110/85APPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

BILLY R. COOK JR. 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 w ill 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)

DJI Inspire 1

1.1 Aircraft

1.1.1 Model

– T600

1.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g)

1.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m

1.1.4 Max Angula r Velocity

– Pitch: 300 0 /s; Yaw: 150 0 /s

1.1.5 Max Tilt Angle

- 35 0

1.1.6 Max Ascent Speed

– 5m/s

1.1.7 Max Descent Speed

– 4m/s

1.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED)

1.1.9 Max Flight Altitude

– 4500m

1.1.10 Max Wind Resistance

– 10m/s

1.1.11 Max Flight Time

– Approximately 18 minutes

1.1.12 Motor Model

– DJI 3510

1.1.13 Propeller Model

– DJI 1345

1.1.14 Operating Temperature Range

– 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

1.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

1.2 Gimbal

1.2.1 Model

– ZENMUSE X3

1.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W

1.2.3 Operating Current

– Static: 750mA; In Motion: 900mA

1.2.4 Angular Vibration Range

- ±0.03 0

1.2.5 Mounting

– Detachable

1.2.6 Controllable Range

– Pitch:

- 90 0 to +30 0 ; Pan: ±320 0

1.2.7 Mechanical Range

– Pitch:

- 125 0 to 45 0 ; Pan: ±330 0

1.2.8 Max Controllable Sp eed

– Pitch: 120 0 /s; Pan: 180 0 /s

1.3 Transmitter1.3.1 Name

– C1

1.3.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz

1.3.3 Communicating Distance (unobstructed)

– 2000m

1.3.4 Output Power

– 9W

1.3.5 Operating Temperature Range

- 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

1.3.6 Battery

– 600mAh LiPo 2S

All specifications can be found in the attached user manual or at http://www.dji.com/product/inspire

- 1/spec

All technical information on the Lily Robotics camera can be found at: https://www.lily.camera/tech

- specs/