August 2 1 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of th e Federal Aviation Regulations

Dear Sir or Madam :

On behalf of Pilot Training System (“ PTS ”) , pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) (“Section 333”), Subsection (f) of 49 U.S.C. §
44701, and 14 C.F.R. Par t 11, we request an exemption from the Federal Aviation

Administration r egulations listed below and discussed in Appendix A to allow PTS to conduct commercial operations with the DJI Phantom 2 Vision+ and Phantom 3 ( these are old and new

models of the same sUAS and will be referred to collectively as “ Phantom”) 1 and the DJI Inspire

1 (“Inspire”) 2 small unmanned aircraft systems (“sUAS”) for aerial photography and videography in connection with homeowne r and private

- property inspections

, 3 and to conduct

rese arch and development operations to explore the use of sUAS to improve catastrophe

response

. 4

Conducting the requested sUAS operations

— building and private property inspection and research and development

— can be done safely in the National Airspace Sy stem (“NAS”) and is in the public interest for several reasons, which are detailed further herein and include: ( 1) removing safety risks associated with requiring people to access and inspect potentially dangerous areas, including slippery or unstable roof s , (2) reducing the risks associated with performing inspections with manned aircraft, (3) reducing time required to complete inspections

, (4 ) improving the efficiency of PTS ’ s business operations.

1 T he Phantom already has been approved for commercial use in similar contexts

. See Exemption Nos. 11138,
11153, 11189, 11191, 11195.

2 The Inspire is similar in form and function to the DJI Phantom but is equipped with more sophi sticated safety features (explained below).

3 The FAA has granted similar exemptions. See Exemption 11175, 11293.

4 The FAA has granted similar exemptions. See Exemption 11188, 11309. Pilot Training System, LLC 4620 Frey St #318 | Madison, WI 53705 | tel 608.620.4315

Chris Johnson, PhD ChrisJohnson@PilotTrainingSystem.comAugu st 2 1 , 2015

Page 2

Applicant Information:

The name of the applicant : Pilot Training System , LLC

The primary contact for this application and company legal address is:

Chris Johnson Pilot Training System, LLC

Founder & CEO 4620 Frey St. #318 4620 Frey St. #318 Madison, WI 53 705 Madison, WI 53705 Phone: ( 608 ) 620

- 4315

Exemptions Requested

PTS requests exemptions from the following regulations:

14 C.F.R. Part 21 , Subpart H ; 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a);

14 C.F.R. 9 1.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) and (2); 14 C.F.R. 91.417(a) and (b).Augu st 2 1 , 2015

Page 3

Airworthiness of the sUAS

Both the Phantom and Inspire are quadcopters with gimbal

- mount ed cameras manufactured by DJI, a market leader in sUAS. The Phantom has been authorized to conduct commercial operations, including property inspections, under several Section 333 exemptions. 5 T he Inspire
is DJI’s more advanced model with enhanced featu res.

Technical specifications for the Phantom and the Inspire are summarized in the table below.

DJI Phantom DJI Inspire

Size ~1 foot x 1 foot ~1 foot x 1 foot Total Weight 1280 g (2.74 lbs) 2935 g (6.47 lbs) Max Ascent Speed 6 m/s (12 knots) 5 m/s (10 knots) Max Descent Speed 3 m/s (4 knots) 4 m/s (8 knots) Max Flight Speed 16 m/s (29 knots) 22 m/s (43 knots) Hover Accuracy:

Vertical / Horizontal .8 m (2.6’) / 2.5 m (8.2’) .5 m (1.6’) / 2.5 m (8.2’)

Controller Frequency (Main Channel) 5.72 5

- 5.825 GHz (FCC Compliant) 5.725

- 5.825 GHz (FCC Compliant) Controller Range 20 00 m (.5 mi) 2 km (1.24 mi)

Communications (Second Channel) 2.4 GHz Wi

- Fi (No Interference) 2.4 GHz Wi

- Fi (No Interference)

DJI provides a comprehensive suite of training manuals, maintenance procedures and user’s guides for the Phantom and Inspire. 6 Collectively, these documents will be referred to as “Operat ing Documents” for each sUAS model. Each pilot in command (PIC) will be required to comply with all maintenance a nd inspection procedures outlined in the Operating Documents.

Operating Conditions

PTS requests an exemption subject to the conditions listed in Appendix B , which are similar to the operating conditions required for the FAA’s previous grants of exempti ons under Section

333

.

5 See Exemption Nos. 11138, 11153, 11189, 11191, 11195.

6 T he Phanto m Operating Documents are available at http://www.dji.com/product/phantom

- 2

- vision/download and http://www.dji.com/product/pha ntom

- 3/download and the Inspire Operating Documents are available at http://www.dji.com/product/inspire

- 1/download

.Augu st 2 1 , 2015

Page 4

In accordance with the conditions approved in previous exemption grants, PTS is requesting authority to operate the Phantom and Inspire within visual line of sight and below 400 feet AGL

, except as provided by FAA Air Traffic Contro l via COA . These operating conditions, along with those listed in Appendix B, and the sUAS safety features listed below provid e an equivalent level of safety

.

The following safety features are incorporated into both the Phantom and Inspire to ensure pub lic safety and safe integration into the NAS:

 Stability Control with Auto

- Takeoff and Auto

- Land : The automated flight

- control system can take off and land automatically, and the system autocorrects the aircraft’s position to adjust for environment disturb ances such as wind.

 Intelligent Orientation Control (IOC) and Inertial Measurement Unit (IMU) : The built

- in inertial sensor and barometric altimeter measures orientation and altitude, respectively,

and communicates this data back to the controller.

 Live Map and Radar with Failsafe & Battery Warnings : The controller displays a live map and radar to show the aircraft’s recent flight path, heading, bearing and distance from “home” (a predetermined start location within the boundaries of the privately owned property) for complete situation awareness. It also illustrates battery status and low

battery warnings with estimated time to return “home” to alert the PIC and ensure that the aircraft does not power down unexpectedly during use.

 LED Flight Indicators : LED lights are mounted to the four rotor arms of each model to visually indicate aircraft orientation (attitude) and status of the flight control system, alerting the PIC of possible issues.

 Maximum Height and Radius Limits : Before beginning flight, the PIC may set a maximum altitude and distance that prevent the sUAS from exceeding altitude limits and
distance from “home .”

 Flight

- limited Safety Zones : The sUAS flight software comes loaded with a list of

restricted areas that are divided into one of t hree categories: category A

, category B, or no fly . Category A areas include major international airports ; Category B is comprise d of smaller airports; and the no

- fly zones are sensitive national security areas such as the

White House. Each restricted ar ea is comprised of a no

- fly zone in which the sUAS cannot be operated and a warning zone surrounding the no

- fly zone in which the PIC is

alerted to the sUAS’ proximity to a restricted area. Category A areas also include larger

restricted

- altitude zones in which the sUAS will only fly below a certain altitude

.Augu st 2 1 , 2015

Page 5

Additional detail s regarding the safety zones can be found in the Phantom and Inspire manuals, attached as Appendices C and D.

 Loss of link

. The built

- in GPS system that aids in stability control will automatically

return the sUAS to “home” if communication between the controller and aircraft is lost.

The sUAS will enter failsafe mode w hen connection with the controller is lost and will wait 3 seconds before either landing or returning to a home p oint to land, depending on

whether the sUAS is operating in GPS mode. When in non

- GPS mode, the sUAS automatically lands after 3 seconds . In GPS mode, the aircraft automat ically returns to

home and lands. When flying back to home, the aircraft first will ascend to pre

- set
altitude to avoid obstacles . If the aircraft is above the pre

- set altitude when loss of link

occurs , it will fly directly back to the home point.

 Loss of GPS

. If a loss of GPS occurs , the PIC maintain s positive control of the aircraf t and can either land the sUAS, hover in place until GPS is reacquired, or continue the flight

. Additionally, t he sUAS have the ability to abort a flight in the event of unpredicted obstacles or emergencies.

 Sense

- and

- Avoid . An aftermarket, sense

- and

- av oid system such as the eBumper4 (see http://www.panoptesuav.com/ebumper/ ) will be incorporated with the Phantom and the Inspire to allow the sUAS to maintain a safe standoff distance from obstacles, preve nting inadvertent collision and greatly enhancing the safety of operations.

Operator Requirements

As a condition to the grant of the exemptions, PTS will require that the PIC hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a poss ession, or the Federal governmen t. The PIC

will meet the flig ht review requirements specified in 14 CFR § 61.56 in an aircraft in which the

PIC is rated o n his or her pilot certificate.

At the conclusion of the training, the PIC will be able to safely operate the sUAS in a manner

consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and

structures. This training will include the following, to the extent necessary for the operations :

1) Perform an appropriate number of flights with the specific sUAS to be operated to obtain proficiency.Augu st 2 1 , 2015

Page 6

2) Successfully learn and demonstrate all relevant flight maneuvers in the Phantom 2 Vision Pilot Training Guide

. 7

3) Study and be knowledgeable of all relevant se ctions of the model

- specific User’s Manual, Safety Guidelines, Battery Safety Guidelines, and other relevant applicable manuals, updates, alerts, warnings and safety bulletins provided by DJI for the specific sUAS to be operated.

4) Study and be knowledgeabl e of all relevant sections of the Inspire 1 Maintenance Manual

and the Guide to the Phantom 2 Vision & Vision+. 8

5) Understand and demonstrate relevant evasive maneuvers outlined in the “Always be Prepared for the Worst” scenarios outlined in the Guide to t he Phantom 2 Vision & Vision+ (applicable for operators of both the Phantom and the Inspire 1).

T raining flights will be conducted over private or controll ed

- access property

. T raining flights will be logged for each PIC in training in a manner consistent with 14 CFR § 61.51(b).

PTS respectfully submits that the operator qualifications take into account the operating

conditions and characteristics of the sUAS.

Public Interest

PTS respectfully submits that using sUAS to inspect roof tops in lieu of re quiring its employees to visually inspect roofs and to conduct research and development into catastrophe support operations offers a net safety benefit and will achieve an enhanced level of safety, as mandated under Section 333(c) of the Reform Act. Appro val of this application also will benefit the public interest by providing faster and more cost

- efficient insurance claim processing and insurance underwriting

.

Inspection operations over private property and catastrophe areas with c onventional manned

air craft involve very heavy aircraft , transiting to the operational location, carrying significant

7 S ince the maneuvers are universal, the Phantom Training Guide will be us ed for training PICs on both the Inspire

1 and the Phantom.

8 T he Guide to the Phantom 2 Vision & Vision+ contains maintenance information and technical and safety

- related guidelines . T he Guide to the Phantom 2 Vision & Vision+ is available at https://www.dropbox.com/s/mv8d1hohc3mceym/DJI%20Phantom%20Vision%20Summary%20Guide.pdf?dl=0

.Augu st 2 1 , 2015

Page 7

quantities of combustible fuels, and a multi

- person crew in piloting and observation roles. By contrast, the sUAS weigh less than seven pounds , use a battery f or power, are carried to and fr om the area of activity, remove the need for airborne pilots and observers, and pose less risk to people and infrastructure on the ground, as well as other aircraft.

Additionally, no national security issue is raised by the g rant of the requested exemption due to

the sUAS’ small size and load

- c arrying capacity, as well as their operational limitations and lack

of flammable fuel. All PICs will have been screened by the Department of Homeland Security

.

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

Section 333 and 49 U.S.C. § 44701(f)

, 9 the equivalent and enhanced level of safety of the proposed operations, and the significant public benefit, and cost savings to be realized as a result

of the us e of sUAS for aerial inspection s. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Privacy Concerns

The proposed operations will take place only over private or controll ed

- access property and only after obtaining written o r verbal consent from the individual who owns or controls the property or is the property owner’s authorized repres entative before each flight. No privacy issues are raised by this application.

Federal Register Summary

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA

- 2015

-

____ Petitioner: Pilot Training System, LLC

Section of 14 CFR: Part 21, Subpart H, § 61.23(a) and (c), § 61.101(e)(4) and (5), § 61.113(a) and (b), § 61.315(a), § 91.7(a), § 91.119(c), § 91.121, § 91. 151(a), § 91.405(a), § 91.407(a)(1), § 91.409(a)(1) and (2), and § 91.417(a) and (b).

9 Pursuant to 49 U.S.C. § 44701(f) , t he “ Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of this title if the Administrator finds the exemption is in t he public interest. ”Augu st 2 1 , 2015

Page 8

Description of Relief Sought : PTS seek s an exemption to conduct commercial building and private property inspection operations using a small unmanned aircraft (55 pounds or less).

Sincerely,

Chris JohnsonAugu st 2 1 , 2015

Page 9

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWING S UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

PTS requests an exemption from the following regulations as well as any additional regulations

that the FAA deems necessary to the operation of the DJI Phantom Vision 2+ and DJI Inspire 1

sUAS:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

Tile 14, Part 21, Subpart H of the Code of Federal Regulations establishes the procedural requirements for the issuance of airworthiness certificates as required by § 91.203(a)(1). Given

the size and weight of the aircraft, the operating conditions, design safety features, and the proposed conditions and limitations , it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section

333. Section 333 authorize s the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, ope rational capability, and proximity to airports and popula ted areas of the sUAS involved.

In this case, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness cer tificate. The Phantom and Inspire weigh 2.74 and 6.47 pounds , respectively

. They will not carry a pilot, passenger or flammable fuel. The y will ope rate exclusively within a controlled area pre

disclosed and in compliance with the conditions set forth herein. Unlike other civil manned

aircraft operations , o perations under this exemption will be tightly controlled and monitored by

the PIC and visual o bserver , pursuant to the conditions set forth in Appendix B

, the Operating

Documents

, and local public safety requirements. The FAA will have advance notice of all operations , to the extent required, through the filing of NOTAMs. The lack of flammable fu el

and the fact that the aircraft are carried to the location and not flown there all establish an equivalent level of safety. The sUAS provide at least an equivalent level of safety to that of such operations being conducted with conventional aircraft th at would be orders

- of

- magnitude larger and would be carrying passengers, cargo, and flammable fuel.

14 C.F.R. § 61.23 (a) & (c)

Section 61.23(a) require s a person exercising the privileges of a transport pilot certificate to hold

a first

- class medical certificate, the privileges of a commercial pil ot certificate to hold a second

class medical certificate, and the privileges of a private or recreational pilot certificate to hold aAugu st 2 1 , 2015

Page 10

third

- class medical certificate. Section 61.23(c) requires a person to h old a medical certificate or U.S. driver’s license when exercising the privileges of a sport pilot certificate in a light

- sport aircraft other than a glider or balloon.

The operations proposed herein will provide an equivalent level of safety by complying with the conditions and limitations of this exemption. The FAA has found th at the se conditions and limitations provide an equivalent level of safety in numerous previous exemptions, including but

not limited to Exemption s 11213, 11252, 11275, 11277, and 11278.

14 C.F.R. § 61.101 (e)(4) & (5) : Recreation P ilot Privilege and L imitations ; 14 C.F.R. § 61.315(a): What are the privileges and limits of my sport pilot certificate

Section 61.101(e)(4) prohibits a recreational pilot from acting as pilot in comman d of an aircraft for compensation or hire. Section 61.101(e) (5) prohibits a recreational pilot from acting as pilot in command of an aircraft in furtherance of a business. Section 61.315(a) authorizes persons holding a sport pilot certificate to act as p ilot in command of a light

- sport aircraft

.

As with previous Section 333 exemptions, 10 an equivalent level of safety is established because (1) the aeronautical knowledge requirements that would be applicable to UAS operations for a recreational pilot and sport pilot certificate were substantially similar as those for a private pilot certificate; (2) holders of recreational and sport pilot certificates are subject to security screening by the Department of Homeland Security; and (3) risk was mitigated thro ugh conditions and limitations regarding PIC training.

14 C.F.R. § § 61.113(a) & (b) : Commercial P ilot Privileges

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

- commercial operations. Unlike a conventional aircraft that carries a pilot, passenge rs, and cargo, the UAS are remotely controlled with no passengers or property of others on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in adva nce as set forth in the Operating

Documents . In conju nction with the PIC’s required training, the level of safety provided by the requirements included in the Operat ing Documents meets or exceeds that provided by a single individual holding a commercial pilot certificate operating a conventional aircraft. T he proposed operations will achieve at least an equivalent level of safety.

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

10 See, e.g., Exemption Nos. 11310, 1131 1, 11312, 11313, 11315.Augu st 2 1 , 2015

Page 11

Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an airworthy

condition. No FAA standard exists for determining an aircraft’s airworthiness when an airworthiness certificate is not issued. As the FAA has done with previous exemption grants, 11
airworthiness will be ensured and an equivalent level of safety will be achieved by compliance

with t he O perating D ocuments prior to every flight.

14 C.F.R. § 91.119 (c) : Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Because the aerial photography an d videography work must be accomplished at altitudes less

than 500 feet AGL an exemption is required

.

The equivalent level of safety will be achieved given the sUAS’ size, weight, speed, and proposed operating conditions. sUAS operations will be conduct ed over private or controlled

access property with consent granted by the property owner/controller or authorized representative prior to each operation.

14 C.F.R. § 91. 121: Altimeter Setting

Section 91. 121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.” The Phantom’s and Inspires’ Inertial Measurement

Units have barometric altimete rs, but they cannot be set to the elevation of the departure location. Rather, upon initialization, the sUAS calibrate their positions without user input and transmit a single altitude measurement to the ground station

. Thus, an exemption is required.

An equivalent level of safety will be achieved by the operator, pursuant to the Operat ing

Documents , confirming the altitude of the launch site shown on the a ltitude indicator before flight.

11 Exemption Nos. 11156, 11158, 11159.Augu st 2 1 , 2015

Page 12

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditi ons

This regulation prohibits an individual from beginning “ a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cru ising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. ”

The Phantom and Inspire ba tteries provide approximately 25 and 18 minutes of powered fli ght

, respectively . Without a n exemption from 14 C.F.R. § 91.151, the sUAS flights wou ld not be

allowed. Given the limitations on its proposed operations, allowing the sUAS to operate without

the required reserve fuel is reasonable and is consistent with prior exemptions. 12 A n equival ent level of safety will be achieved because o perating the sUAS without 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the sUAS operate

. In the unlikely event th at a sUAS should run out of battery power

, it would simply land

. Given the sUAS’s weight and construction material, the risks are less than contemplated by the current regulation. PTS will requir e the UAS to return home and land when the battery reaches 30% capacity.

14 C.F.R. § § 91.405(a)

, 91. 407(a)(1)

, 91. 409(a)(2) , and 91. 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 prescrib ed in part 43 of this chapter

. ” Section 91.407 similarly makes refer ence to requirements in Part 43. Section 91.409(a)(2) req uires an annual inspection for the issuance of an air worthiness 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 license d pilots and records of approval of the aircraft for return to service.

An equivalent level of safety will be achieved by complying with the Operating Documents maintenance and inspection requirements because the sUAS will carry no external payload, will operate only in restricted predetermined areas. In addition, the PIC will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any

12 Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)) ; see also Exemptio ns 2689F, 5745, 10673 and 10808

.Augu st 2 1 , 2015

Page 13

maintenance that is performed. Moreover, the PIC is the pe rson most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.August 21, 2015

Page 14

APPENDIX B

PTS OPERATING LIMITATIONS

1) Operations authorized by the grant of exemption are limited to the following aircraft:

DJI Phantom 2 Vision+, Phantom 3 and DJI Inspire 1, which weigh 2.74 , 2.74 and 6.47 pounds, respectively

.

2) The DJI Phantom 2 Vision+ and Phantom 3 shall not be flown at a speed exceeding 16 m/s. The DJJI Inspire 1 shall not be at f lown at a speed exceeding 22 m/s

.

3) The sUAS will not be operate d at an altitude more than 400 feet above

. All altitudes reported to ATC shall be in feet AGL.

4) The sUAS must be operated within visual line of sight (VLOS) of the PIC at all times. This require s 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 PICs have the option to use a visual observer ( VO ), but VOs are not required

. The

sUAS will b e equipped with sense

- and

- avoid technology to mitigate collisions, and

the PIC will maintain VLOS at all times . Furthermore, standard operating procedures will dictate that the PIC remains heads up, maintain continuous eye contact with the

sUAS while the s UAS is in transit, looking down at the controller ONLY while the sUAS is stationary. Given these technological and procedural enhancements, PTS has concluded from a formal safety assessment that full collision avoidance responsibility should reside solely with the PIC who will have the option of including a VO if necessary. The PIC will physically follow the sUAS from the ground level throughout the flight process, maintaining close, lateral quarters without creating a safety hazard or obstructing VLOS. The PIC will have positional priority over a VO at all times , and the responsibility for maintaining the most effective VLOS vantage point r esides with

the PIC to ensure safety and efficiency of operations , rendering a VO useless in most

cases . Therefore, in the unlikely event that VLOS is lost by the PIC, it will likely also be lost for the VO, so PTS opines that including a VO is unnecessary and costly because the PIC is capable of maintaining VLOS at all times. Furthermore, in the unlikely event that the PI C inadvertently loses VLOS with the sUAS at any point during the operation, the PIC can utilize the auto

- flight features that allow the sUAS to

auto

- hover, auto

- land or return “home” automatically depending on the most suitable method required for regainin g VLOS.

6) The operating documents and this grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a conflict exists

between the conditions and limitations in th e exemption and the procedures outl ined inAugust 21, 2015

Page 15

the operating documents, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, PTS must follow the procedures as outlined in its operating documents. PTS may update or revise its operating

documents. It i s PTS ’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. PTS must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption.

7) Prior to each flight the PIC must inspect the sUAS to ensure that it is in a condition for safe flight. The PIC shall not operate the aircraft if the inspection reveals a condition that affects the safe operation of the sUAS until the necessary maintenance has be en performed and the sUAS is found to be in a condition for safe flight. The Ground

Control Station , if utilized, must be included in the preflight inspection. All maintenance and alternations must be properly documented in the aircraft reco rds.

8) Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics (e.g., replacement of a flight critical component) must undergo a functional test flight in accordance with the O perator’s M anual. The

PIC who conducts the functional test flight must make an entry in the a ircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry shall be included in the Operator’s Manual

.

9) The pre

- flight inspection must account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

10) PTS must follow DJI ’s aircraft/component

, maintenance, overhaul, replacement, inspection, and life limit requi rements.

11) PTS must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft re cords, including total time in service, description of work accomplished, and the signature of the person authorized to return the s UAS to service.

12) Each s UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

13) The PIC must hol d either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia,
Puerto Rico, a terri tory, a possession, or the Federal government. The PIC must alsoAugust 21, 2015

Page 16

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

14) PTS may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the s UAS in a

manner consistent with how the s UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehicles and structures. 13 PIC qualification flight hours and currency must be logged in a manner consistent with 14 C

. F

. R

. § 61.51(b). The PIC must ensure that the VO is trained appro priately in order to fulfill his or her duti es. A record of training and qualification must be documented and made available upon request by the Administrator. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building), are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

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

, and the PIC must operate the UA with appropriate distance from nonparticipants in

accordance with these operating conditions

.

15) Operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual mete orological conditions (“VMC”). Flights under special visual flight rules (“SVFR”) are not authorized.

16) The s UA S may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter o f agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by PTS ’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

17) The sU AS 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.

18) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a

pre

- determin ed location within the private or controlled

- access property

.

13 Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement.August 21, 2015

Page 17

19) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the Operator’s Manual.

20) The PIC will be prohibited from beginning a flight unless (considerin g 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 30% battery power remaining in accordance with the operating documents.

21) All operations shall be conducted in ac cordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

22) All aircraft operated in accordance with the requested exemption must be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as practicable.

23) The radio frequency spectrum used for operation and control of the sUAS must comply with Federal Communication (FCC) or other appropriate government oversight agency requirements.

24) The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Stat ion of the sUAS any time the aircraft is operating. These documents shall be made available to the Administrator or any law enforcement official upon request.

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

and activit ies at all times.

26) The sUAS may not be operated from any moving device or vehicle.

27) The sUAS may not be operated over congested or densely populated areas.

28) Flight operation s must be conducted at a safe distance from all nonparticipating persons, vessels, v ehicles, structures, and public access roads. The metrics involved with calculating a safe distance will vary from operation to operation given the state of the environment (e.g., wind direction and strength) and the task requirements ( e.g., the dimensions of the pr operty being analyzed). The refore, th e responsibility for

determin ing a safe distance from all nonparticipating persons, vessels, v ehicles,

structures, and public access roads wi ll res ide with the PIC

.

Following review of previous summary grants in which the FAA has required a 500

- foot di stance from nonp articipating persons, vessels, v ehicles, structures, and publicAugust 21, 2015

Page 18

access roads , PTS opines that a 500

- foot stand

- off distance is too restrictive for the type of sUAS to be flown. Most operations will be below 50 feet, so maintaining a

500

- foot horizontal distance from all other people or property is unreasonable and far

too restrictive to be maintained. Our PICs are trained to detect conflict situations in which a potential collision could occur, and they will cease operations immediately.

Furth ermore, given the sense

- and

- avoid technology, the stabilization technology and the standard operating procedures detailed in #5 above, PTS opines that is it perfectly reasonable to place this judgement on a licensed pilot who has a vested interest in the

s afety of by standers and their personal property.

29) Operations nearer than 500 feet to the PIC, VO, operator trainees or essential persons as defined in the operating documents are permitted if those operations do not present an undue hazard to those person s per § 91.119(a) as determined by the PIC.

30) All operations must be conducted over private or controlled

- access property.

31) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA shall be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

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

.August 21, 2015

Page 19