11 October 2015

Attention: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

RE:
New Wave Systems, Inc. r equest s exemption from Title 14 requirements of the Code of Federal Regulations (C.F.R.), sections:

- 45.23
, 61.113(a)
, 61.113(b)
, 91.105(a)(2 ), 91.7(a)
, 91.121
, 91.151(b)
, 91.405(a)
, 91.407(a)(1)
, 91.409(a)(1)
, 91.409(a)(2)
, 91.417(a)
, 91.417(b) , and 91.417(d) Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act (MARA) of 2012 (Public Law 112

- 95).

Michael Breslow

President & CEO New Wave Systems, Inc. (480) 201

- 1100 mbreslow@newwave.systemsRevision 1.0 December 2015 2 CONTENTS 14 C.F.R Exemption Request Section

................................ ................................ ...... 3
INTRODUCTION

................................ ................................ ................................ .............. 3
BASIS FOR PETITION

................................ ................................ ................................ ... 4 SECTION 91.105(a)(2)

................................ ................................ ................................ .......................... 4 SECTIONS 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a), 91.417(b), 91.417(d), and 91.7(a)

................................ ................................ ................................ ........................... 5 SECTION 45.23

................................ ................................ ................................ ................................ .... 10 SECTIONS 61.113(a) & 61.113(b)

................................ ................................ ................................ .... 11 SECTION 91.121

................................ ................................ ................................ ................................ . 13 SECTION 91.151(b)

................................ ................................ ................................ ............................. 14 OPERATIONAL CONSIDERATIONS

................................ ................................ ........ 16 GLOSSARY OF ABBREVIATIONS

................................ ................................ ........... 21 Appendix A

– DJI S1000

................................ ................................ ............................. 22 Appendix B

– JR GSR260Z

................................ ................................ ........................ 23 Appendix C

– D Series (D800

- X4, D800

- X8, D800

- V6, D1100

- V8)

.................... 24 Appendix D

– Pixhawk Autopilot

................................ ................................ ............. 25Revision 1.0 December 2015 3 14 C.F.R Exemption Request Section New Wave Systems, Inc. seeks exemption from the requirements of 14 C.F.R §§ 45.23, 61.113(a), 61.113 (b), 91.105(a)(2), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409 (a)(2), 91.417(a), and 91.417 (b), to operate Unmanned Aerial System (s) (UAS) pursuant to Section 333 of the FAA MARA. This exemption will permit New Wave Systems, Inc. to operate UAS for the commercial purposes of conducting aerial video and photography of agricultural fields/sites and public lands as they relate to agricult ure over areas within the United States (US).

INTRODUCTION New Wave Systems, Inc. employ s many prior military aviation UAS pilots, engineers , and
aviation technicians who have a combined 25+ years of unmanned/manned aviation experience from the US Departm ent of Defense (DOD) . New Wave Systems, Inc. pilots have flown over 3,000 combat hours in a variety of environments on a variety of UAS platforms , while our engineering staff has many years of autopilot (AP) software development, power plants development, and general unmanned aviation experience. New Wave System, Inc. objective is to take the DOD methodology and experience while operating our UAS in a more affordable , safer, and reliable manner for a variety of agricultural inspection purposes.Revision 1.0 December 2015 4 BASIS FOR PETITION New Wave Systems, Inc. , pursuant to the provisions of the FAA 14 C.F.R. § 11.61 and
the FAA MARA , Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to allow New Wave Systems, Inc. to commercially operate the DJI S

- 1000, JR GSR260Z , and D

- Series UAS in the National Airspace System (NAS).

New Wave Systems, Inc. submits that the requested relief is proper since an equivalent level of safety can be ensured. New Wave Systems, Inc. uses experienced per sonnel,
technicians , and engineers that have come from the DOD UAS industry to operate and perform scheduled and un

- scheduled maintenance, UAS alterations, and/ or preventive
maintenance on the various UAS using methods, techniques, and practices prescr ibed in the operating documents. Additionally, New Wave Systems, Inc. has established procedures and practices i n accordance with established UAS manufacturer practices as well as DOD b est practices where applicable.

SECTION 91.105(a)(2 )
Section 91.105 , titled: Flight Crew Members at Stations , s ubsection (a ) prescribe the following, in relevant part: a) During takeoff and landing, and while en route, each required flight crewmember
shall: 1) Keep the safety belt fastened while at the crewmember station.

New Wave Systems, Inc. seeks relief from the requirements of Section 91.105(a)(2 ),
titled: Flight Crew Members at Stations

. The flight crew will not be aboard the UAV , but will instead be located outside of the UAV on the ground. All crewmembers will either be
standi ng or sitting in a chair with no available s eat belt. Given that the crewmembers will be on the ground and in a fixed position there should be no need to provide a seat belt as that will not increase safety

.Revision 1.0 December 2015 5 SECTIONS 91.405(a), 91.407(a)(1), 91.4 09 (a)(1), 91.409(a)(2), 91.417(a), 91.417(b) , 91.417(d), and 91.7(a) Section 91.405, titled: Maintenance Required , subsection (a) prescribes the following, in relevant part:
Each o wner or operator 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 chapter;

Section 91.407, titled: Operation After Maintenance, Pr eventive Maintenance, Rebuilding,
or Alteration , subsection (a)(1) prescribes the following, in relevant part: a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—Revision 1.0 December 2015 6 1) It has been approv ed for return to service by a person authorized under §43.7 of this chapter;

Section 91.409, titled: Inspections , subsections (a)(1) and (a)(2) prescribes the following, in relevant part: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had 1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or 2) An inspection fo r the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person autho rized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records. 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 p eriods specified in paragraph (b) of this section: 1) Records of the maintenance, preventive maintenance, and alteration and
records of the 100

- hour, annual, progressive, and other required or approved inspections, as 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 Administrator) of the work performed; and
ii. The date of completion of the work performed; and
iii. The signature, and certificate number of the person approving the
aircraft for return to service.Revision 1.0 December 2015 7 2) Records containing the following information:
i. The total time in service of the airframe, each engine, each propeller, and each rotor
ii. The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.
iii. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
iv. The current inspection status of the aircraft, inclu ding the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

v. The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of c ompliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
vi. Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteratio n to the airframe and currently installed engines, rotors, propellers, and appliances. b) The owner or operator shall retain the following records for the periods prescribed: 1) The records specified in paragraph (a)(1) of this section shall be retained
until th e work is repeated or superseded by other work or for 1 year after the work is performed. 2) The records specified in paragraph (a)(2) of this section shall be retained
and transferred with the aircraft at the time the aircraft is sold. 3) A list of defects furn ished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. d) When a fuel tank is installed within the passenger compartment or a baggage compartmen t pursuant to part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner or operator.Revision 1.0 December 2015 8 Section 91.7, titled: Civil Aircraft Airworthiness , subsection (a) prescribes the following, in relevant part: b) No person m ay operate a civil aircraft unless it is in an airworthy condition.

New Wave Systems, Inc. requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)
, 91.417(b), 91.417(d), and 91.7(a) as these
sections set forth requirements for maintenance which apply to aircraft with an
airworthiness certificate.
The DJI S

- 1000, JR GSR260Z , and D

- Series UAS operating characteristics meet the conditions of the FAA MARA Section 333 for operating speed, gross take

- off weight (GTOW) , size, and scope of area operations based on visual line

- of

- sight (VLOS), and therefore will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. New Wave Systems, Inc. seeks relief from Section 91.7(a), titled : Civil Aircraft
Airworthiness , because the above mentioned UAS do not require airworthiness certificates in accordance with 14 C.F.R. Part 21, Subpart H. As such, New Wave Systems, Inc. will ensure that the above mentioned UAS are in an airworthy condition prior to every flight in accordance with (IAW) UAS manufacturer and New Wave Systems,
Inc. operating documents

. New Wave Systems, Inc. will maintain records on each UAS where applicable to include:
1. Records of the maintenance, preventive maintenance, alterations, 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 will include:

a. A description (or reference to data acceptable to the Adminis trator) of the work performed; and
i. The date of completion of the work performed; and
ii. The signature of the person approving the aircraft for return to
serviceRevision 1.0 December 2015 9 2. Records containing the following information:

a. The total time in service of the airframe and of each engine

b. The current status of life

- limited parts of each airframe and engine

c. The time since last overhaul of all items installed on the aircraft which are required to be overha uled on a specified time basis

d. The current inspection status of the aircra ft, including the time since the last inspection required by the inspection program under which the aircraft and its parts are maintained
3. The owner or operator shall retain the following records for the periods prescribed:

a. The records specified in paragra ph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 ye ar after the work is performed
b. 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

The FAA has previously granted relief from Section 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a), 91.417(b), 91.417(d), and 91.7(a) specific to UAS, in circumstances similar, in all material respects, to tho se presented herein (e.g. Exemption Nos. 11062, 11063, 11064, and 11065).Revision 1.0 December 2015 10 SECTION 45.23 Section 45.23, titled: Display of Marks; General , subsection (b) prescribe the following, in relevant part: b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

New Wave Systems, Inc. seeks relief from the requirements of Section 45.23(b), titled: Displ ay of Marks; General

. The UAV will have no airworthiness certificate and g iven the size of the UAV, two

- inch lettering will be impossible to place on the UAV. The UAV has
no cabin and therefore no entrance to any form of cabin/cockpit/pilot station where t he word “experimental” can be placed. The UAV will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. The UAV will also be marked with “exp erimental” and both markings will be as large as practicable given the size of the
UAS in a location where the PIC/VO/Etc. can see the markings.

The FAA has previously granted relief from Section 45.23 specific to UAS, in
circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, and 11065 ).Revision 1.0 December 2015 11 SECTIONS 61.113(a) & 61.113(b)
Section 61.113: Private Pilot Privileges and Limitations: Pilot in Command , subsections (a) and (b) prescri be the following, in relevant part: a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: 1) The flight is only incident al to that business or employment; and 2) The aircraft does not carry passengers or property for compensation or
hire.

New Wave Systems, Inc. seeks r elief from certain requirements of Section 61.113(a) and
61.113 (b), titled : Private P ilot Privileges and Limitations: Pilot in C ommand . New Wave Systems, Inc. seeks to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman third class medical certificate, and who has demonstrated, by me eting flight hour currency requirements as established by New Wave Systems, Inc. , that the PIC is able to safely operate the above mentioned
UAS

. New Wave Systems, Inc. will operate UAS at all times in an unmanned state and requests relief based on this op erating constraint. All UAS flights conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to New Wave Systems, Inc. business; and (2) will not carry passengers or property for compensation or hire. New Wave Systems, Inc. employs prior military UAS pilots, and has established training methods
IAW applicable DOD UAS standards as well as manufacturer documentation

. The current training and granting of a private pilot’s license does not guarantee the eff ective operation
of UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and
structures. New Wave Systems, Inc. believes that the proficiency of our p ilots and the standards implemented based on years of UAS experience enables our UAS pilots toRevision 1.0 December 2015 12 operate at a level of proficiency that exceeds an equivalent level of safety as that of a traditional manned commercial pilot. New Wave Systems, Inc. minimum req uirements for the PIC include:
1. Private Pilot’s license and a Class III medical;
2. A minimum of 100 flight cycles and 50 logged hours of total time as an UAS pilot
3. A minimum of at least 10 hours logged as a UAS pilot with a similar UAS type
make and model of UAS to be utilized for operations under the exemption within the preceding 30 days
4. A minimum of 20 take

- offs and landings in the preceding 30 days
5. Undergone a qualification process as specified in the Flight Operations &
Procedures Manual consisting of a k nowledge & skill test of the UAS to be used

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, and 11 065).Revision 1.0 December 2015 13 SECTION 91.121
Section 91.121: Altimeter Settings , subsections (a) prescribe the following, in relevant part: a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating 1) Below 18,000 feet MSL, to
i. The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;
ii. If there is no station within the area prescribed in paragraph (a)(1)( i) of this section, the current reported altimeter setting of an appropriate available station; or
iii. In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure;

New Wave Systems, Inc. seeks an exemption from the re quirements of Section 91.121,
titled Altimeter Settings , as the above mentioned UAS will not have a traditional aviation style barometric altimeter onboard. To compensate for this
, a ltitude information will be provided to the PIC via the UAS through the radio command and control (C2)
communications telemetry data link . The C2 downlinks from the unmanned aerial vehicle ( UA V) to the ground control station ( GCS ) for active monitoring of the flight path by global position system and micro

- electro

- mechanical (MEM) barometer sensor . This altitude
information in addition to the PIC estimation of height via VLOS ensure s a level of safety equivalent to Section 91.121.

The FAA has previously granted relief fro m Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, and 11065).Revision 1.0 December 2015 14 SECTION 91.151(b) Section 91.151(b): Fuel Requirements for Flight in VFR Conditions
, subsection (b) prescribe the following, in relevant part: b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel /battery
life to fly to any point of intended landing and, assuming normal cruising speed, to fly up to 75% of the anticipated fuel/battery life

.

New Wave Systems, Inc. seeks an exemption from the requirements of Se ction 91.151(b), entitled: Fuel Requirements for Flight in VFR C onditions

. New Wave Systems,
Inc. submits that safety will not be affected by operation of the either the battery powered
DJI S

- 1000 or JR GSR260Z gasoline powered UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR)

. New Wave Systems, In c. DJI S

- 1000 configuration will yield enough battery power to fly
for a n anticipated duration of approximately 25 minutes under ideal flying conditions

. New Wave Systems, Inc. configuration of the S

- 1000 includes power indicators to show an estimation of how much battery power is left, as well as AP fail

- safe conditions that will
auto land the UAV at the closest user defined pre
- programmed GPS waypoint (WP) upon

a user d efined low battery powered condition. New Wave Systems, Inc. JR GSR260Z configuration yield s anticipated flight duration s of up to approximately 75 minutes under ideal flying conditions and depending upon fuel
load . New Wave Systems, Inc. configuration of the JR GSR260Z includes power
indicators to show an estimation of how much fuel is lef t, as well as AP fail

- safe conditions
that will auto land the UAV at the closest user defined pre
- programmed GPS waypoint (WP) upon a user defined low fuel condition. New Wave Systems, Inc. D

- Series (D800

- X4, D800

- X8, D800

- V6, D1100

- V8) configuration will yield enough battery power to fly for an anticipated duration of approximately 45 minutes under ideal flying conditions. New Wave Systems, Inc. configuration of the D

- Series includes power indicators to show an estimation of how much battery power is left, as well as AP fail

- safe conditions that will auto land the UAVRevision 1.0 December 2015 15 at the closest user defined pre

- programmed GPS waypoint (WP) upon a user defined low battery powered condition.

The FAA has previously granted relief from Section 91.151 specific to UAS, in

c ircumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, and 11065).Revision 1.0 December 2015 16 OPERATIONAL CONSIDERATIONS New Wave Systems, Inc. utilizes the commercial Pixhawk AP with New Wave Systems, Inc. firmware and GCS software. Safety features that are utilized in the AP and its
associated software include:
1. Auto descent/landing failsafe conditions:

a. If C2 telemetry signal were to be severed or severely degraded the UAV wil l have the capability to return to the launch point and land given that it does not violate the battery/fuel level condition
b. If battery/fuel levels were to drop below a user defined value
2. In case of GPS failure, t he UAV has the capability to use secondary measurement systems, such as the compass and barometer to return to the launch point area where the PIC can assume control
3. The GCS displays pilot flight display (PFD) and system health information, to include battery/fuel levels, GPS health, and UAV relative position and heading
to the PIC
4. A geo

- fence can be established by the user to prevent the UAV from flying above 400’ AGL and flying beyond VLOS distances for specific UAV

New Wave Systems, Inc. flight crew personnel and duties will include:
1. Visua l observes (VO)/spotters

a. VOs/PICs will utilize radio spectrum analysis to detect possible interference on the C2 frequencies utilized for UAV
b. The VO will assist the PIC in maintaining VLOS of the UAV where necessary and watching the GCS for safety of fligh t and health of the UAV

c. The vehicle will always remain in direct VLOS to the PIC/VO
2. PIC

a. The PIC will be the sole operator of the UAV from take

- off through landing
b. A briefing will be conducted by the PIC in regard to the planned UAS operations prior to each day’s activities. The PIC will ensure that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefingRevision 1.0 December 2015 17 c. The PIC will obtain the consent of all persons involved in the UAS operations and will ensure that only consenting persons will be allowed within 100 feet of the flight operations area
d. Prior to each flight the PIC must inspect (pre

- flight) the UAS IAW
established documentation to ensure it is in a safe

- for

- flight condition

e. The documents required u nder 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the GCS of the UAS any time the UAV is operating
i. These documents must be made available to the Administrator or any law enforcement official upon request
3. PIC/VO

a. PIC/VO will at all times be able to communicate by voice
b. The PIC and/or VO will get written permission from the relevant property holders where flight operations will be conducted
4. General Personnel

a. Any person(s) who conduct any form of maintenance on the UAS will:
i. Log all maintenance actions
ii. Sign all maintenance actions
iii. Make available to all flight crew personnel maintenance logs

Physical Operation Limitations
1. The UAV will weigh less than 55 pounds GTOW
2. The UAV will not fly at a ground/airspeed exceeding 100mph, whichever is
lesser
3. Fl ights will be operated at an altitude of no more than 400 feet above ground level (AGL)

a. A geo

- fence will be established at 400 feet AGL
4. The UA V will be operated within VLOS of the PIC /VO at all times

a. This requires the PIC /VO to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued
medical certificateRevision 1.0 December 2015 18 b. The PIC will establish a geo

- fence VLOS distance suitable for the type of UAS being operated
5. All UAS operations will utilize a VO
6. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics will undergo a functional check flight (FCF) in accordance with the operator’s manual

a. The PIC who conducts the FCF must make an entry in the UAS aircraft
records o f the flight
b. The FCF will be conducted at least 500 horizontal feet away from any persons not directly involved with the FCF
7. All flight crew personnel will be current and proficient as outlined by appropriate
documentation
8. The UAV will remain clear and yie ld the right of way to all other manned operations and activities at all times
9. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1

a. All operations must be conducted under visual meteorological conditions (VMC)
b. Flights under special visual flight rules (SVFR) are not authorized
10. The UAS will not be operated by the PIC from any moving device or vehicle
11. The UAV will 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
12. The UAV will not operate in Class B, C, or D airspace without written approval
from the FAA
13. The UA may not operate within 5 nautical miles of the geographic center of a

non
- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA

a. The letter of agreement with the airport management must be made
availab le to the Administrator upon request.Revision 1.0 December 2015 19 14. Any incident and/or accident which occurs within the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours.
15. Any incident and/or accident which o ccurs within the operational area as defined by the applicable COA will be reported to the National Transportation Safety Board (NTSB ) within 24 hours

. 16. The operator must obtain an Air Traffic Organization (ATO) issued Certificate
of Waiver or Authorization (COA) prior to conducting any operations un der this petition of exemption.

a. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.
17. At least three d ays before scheduled infrastructure inspection, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed infrastructure inspection. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights
b. Name and phone number of the operator for the UAS infrastructure inspection operations conducted u nder this petition of exemption

c. Name and phone number of the person responsible for th e on
- scene operation of the UAS
d. Make, model, and seria l or N

- number of UAS to be used

e. Name and certificate number of UAS PICs involved in the infrastructure inspection event
f. A statement that t he operator has obtained permission from property owners and/or local officials to conduct the infrastructure inspection event; the list of those who gave permission must be made availabl e to the inspector upon request
g. Signature of exemption

- holder or repr esentative; andRevision 1.0 December 2015 20 h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which infrastructure inspection will be conducted and the altitudes essential to accomplish the operation.Revision 1.0 December 2015 21 GLOSSARY OF ABBREVIATIONS
AGL Above Ground Level
AP Auto

- Pilot
ATC Air Traffic Control
ATO Air Traffic Organization
CFR Code of Federal Regulations
COA Certificate of Authorization
C2 Command & Control
DOD Department of Defense
FAA Federal A viation Administration
GCS Ground Control Station
GPS Global Positioning System
MEM Micro

- Electrical

- Mechanical
NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot In Command
MARA Moder nization and Reform Act of 2012
SO Sa fety Observer
SOP Standard Operating Procedures
UAV Unmanned Aerial Vehicle
UAS Unmanned Aerial System
US United States
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VO Visual Observer
WP W aypointRevision 1.0 December 2015 22 Appendix A

– DJI S1000

See Attached Manual : DJI S1000 User Manual V1.10 Supplemental ManualRevision 1.0 December 2015 23 Appendix B

– JR GSR260Z

See Attached Manual : JR GSR260Z Supplemental ManualRevision 1.0 December 2015 24 Appendix C

– D Series (D800

- X4, D800

- X8, D800

- V6, D1100

- V8)

See Attached Manual :
GD

- X8 & GD

- 6

- V2 Supplemental Manual The D Series UAVs are similar to the Gryphon Dynamics 800 and 1100 series UAVs, with the exception of the landing struts. The D Series UAVs do not have associated manuals and as such we have supplied the Gryphon Dynamics Manuals for review.Revision 1.0 December 2015 25 Appendix D

– Pixhawk Autopilot

See attached Manual:
3D Rob otics PixHawk Manual Revision 7 Supplemental Manual