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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

SKYWARD, LTD. 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

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

OPERATION OF THE DJI SPREADING WINGS S1000+, DJI INSPIRE 1, 3DR X8-M, 

AND 3DR IRIS+ UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on June 16, 2015 

Daniel C. Cyphers 

Statutory Agent 

5717 Huberville Ave, Suite 300 

Dayton, OH 45431-1217 

Tel: (937) 252-2710, ext. 102
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TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS...................................................................................3 

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

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

BACKGROUND....................................................................................................................6 

BASIS FOR PETITION.........................................................................................................7 

NAME AND ADDRESS OF PETITIONER.............................................................10 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SKYWARD LTD SEEKS 

EXEMPTION.............................................................................................................10 

THE EXTENT OF RELIEF SKYWARD LTD SEEKS AND THE REASON 

SKYWARD LTD SEEKS THE RELIEF...............................................................14 

THE REASONS WHY GRANTING SKYWARD LTD’s REQUEST WOULD BE IN 

THE PUBLIC INTEREST ......................................................................................18 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY.....................................................................................................21 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......36 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT SKYWARD LTD’s REQUEST.............................................................37 

CONCLUSION.....................................................................................................................37 

APPENDICES.........................................................................................40
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GLOSSARY 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) Section 333 

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 
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SUMMARY

Skyward, Ltd. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(a)(1)(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b), to operate Unmanned Aerial Systems (UASs) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Skyward, Ltd. to 

operate UASs for the commercial purpose of conducting collection of aerial data of natural 

resources, areas surrounding natural resources, and commercial and agricultural areas that 

connect to, utilize, or affect natural resources, for the purpose of detection and monitoring of 

incidences, materials, and natural occurrences harmful to natural resources within the geographic 

boundaries of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Skyward, Ltd. (hereinafter referred to as “Skyward”) is focused on providing customers 

with timely, accurate, and comprehensive data collected from a variety of sensors that are 

mounted on small UASs. Skyward provides customers with expertise in engineering analysis; 

test & evaluation planning, data collection, and reporting; data synthesis and analysis; modeling 

& simulation; weapon system analysis; and technology research and development. Skyward’s 

technical staff is composed almost entirely of engineers with BS degrees at accredited 

universities and 50% of the staff has MS degrees. Skyward’s staff averages over 25 years of 

experience with subject matter experts (SMEs) averaging over 35 years of experience in 

specialized areas. 

Skyward core expertise is survivability/vulnerability; ballistic test & evaluation, 

including Live Fire Test & Evaluation; vulnerability and scientific modeling & simulation, 
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including vulnerability analysis, fire analysis, and design of experiments analysis; weapon 

system vulnerability reduction focusing on fire protection development, including Skyward’s 

patented Enhanced Powder Panel; maintenance, specializing in battle damage assessment and 

repair; combat data analysis; reverse engineering and 3D design, including the utilization of inhouse scanning equipment; munition/warhead characterization/lethality; instrumentation; highspeed video; air vehicle performance; and documentation and program management support. 

Recent experience includes Intelligence, Surveillance, and Reconnaissance (ISR) aircraft, sensor, 

and primary mission equipment integration; operational data collection, processing, and analysis; 

Federal Aviation Administration (FAA) and requirements compliance; mission performance; 

validation/verification; and experimental testing. Our expertise encompasses ground, sea, and 

rotary and fixed-wing air vehicle systems (manned and unmanned). 

The objective of Skward’s aerial data collection operation is to provide high quality data 

for a variety of commercial, public, and residential uses, specifically targeting: 

• Detection and monitoring of incidences, materials, and natural occurrences 

harmful to natural resources. 

• Oil and Gas Pipeline Infrastructure Management. 

• Oil and Gas Incident Response and Hazardous Materials Clean-up. 

• Emergency Response and Wildfire Management Operations. 

• Search and Rescue Operations. 

• Motion Picture Filming. 

• Interior and Exterior three-dimensional modeling and inspection of public and 

private structures. 

• Increase public knowledge of UAS and promote safe UAS operations. 
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BACKGROUND

Unmanned Aerial Systems: DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs 

Skyward seeks an exemption to operate the DJI Inspire 1, DJI Spreading Wings s1000+, 

3DR X8-M, and 3DR Iris+ UASs for compensation or hire within the National Airspace System 

(NAS). All UAS aircraft 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 Marking.

The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ are vertical 

takeoff and landing (VTOL) UASs with Ground Control Stations (GCS) also utilizing electronic 

tablet or smart phone systems. All four VTOL UAS platforms weigh less than 25lbs. maximum 

gross takeoff weight and have built-in capability to limit flight elevation and distance from the 

Pilot in Command. All four UAS vehicles also have the built-in capability to return to the 

launching point if the wireless control link is interrupted or if the operator attempts to exceed any 

of the pre-programmed height, radius, or airspace limitations. All four UAS platforms will be 

operated in airspace under 200ft AGL and within Line of Sight, and will not fly within 3 miles of 

a landing strip. 

The FAA has granted section 333 exemptions for the DJI Inspire 1, DJI Spreading Wings 

s1000+ in First Flight Photography, LLC, Exemption No. 11260, Regulatory Docket No. 

FAA−2014−0736 (as amended 14 April 2015) (DJI Spreading Wings S1000; DJI Inspire); and 

the 3DR X8-M in Aerial Precision Survey, Exemption No. 11617, Regulatory Docket No. FAA-
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2015-0549 (as amended 19 May 2015)(3D Robotics X8+); and the 3DR Iris+ in Counsel for The 

Travelers Companies, Inc., Exemption No. 11490, Regulatory Docket No. FAA-2015-0307 (as 

amended 5 May 2015)(3DR IRIS+). 

The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs that 

will be operated by Skyward 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 Marking. 

BASIS FOR PETITION

Petitioner, Skyward, 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 Aircraft Systems, hereby petitions the Administrator to 

commercially operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs in the NAS, and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(a)(1)(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, Skyward’s operation of the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ 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, Skyward 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. 
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Skyward submits that the requested relief is proper since an equivalent level of safety will 

be ensured. Skyward 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 Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs Instruction Manuals). Furthermore, 

Skyward will document and maintain all maintenance records for the DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Skyward to the extent necessary to 

allow a Pilot in Command (PIC) holding either an airline transport, commercial, private, 

recreational, or sport pilot certificate, as well as an airman medical certificate or valid U.S. 

driver’s license issued by a state, and who has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Skyward seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs do not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Skyward 

submits that Skyward will ensure that the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-

M, and 3DR Iris+ UASs 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 
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DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs Instruction 

Manual), and that the aircraft are in a condition for safe flight. 

Skyward also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the altitude reporting equipment of the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs will be set to zero feet above ground level (AGL), 

rather than the local barometric pressure or field altitude, before each flight. The altitude 

information of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ 

UASs is provided to the PIC via Global Positioning System (GPS) equipment, and a radio 

communications telemetry data link, which downlinks from the UAS to the GCS for active 

monitoring of the flight path. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. Additionally, Skyward will operate the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs within visual line of sight (VLOS), at or below 

200 feet AGL. This altitude information combined with Skyward’s operation of the DJI Inspire 

1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs within visual line of sight, at 

or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121. The FAA 

issued an exemption to this regulation for UAS operations in Exemption Nos. 11136 and 11138. 

Additionally, Skyward seeks an exemption from the requirements of Section 

91.151(a)(1)(b), entitled Fuel requirements for flight in VFR conditions. Section 91.151(a)(1)(b) 

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 cruising speed – (1) During the day, to fly after that for 

at least 30 minutes....” 
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An exemption is needed because the UAS have a maximum flight time of less than 30 

minutes and thus cannot meet the 30-minute reserve requirement. Given the characteristics of the 

UAS, including their small size, low weight and speed, limited range, ability to land very 

quickly, operation within visual line of sight, restricted operating area, and the fact that they do 

not carry persons or any explosive or flammable materials, grant of the exemption is justified. 

An equivalent level of safety can be achieved by terminating flights at 25% battery power 

reserve, which will occur before the 22 minute flight duration for the 3DR Iris +, and 18 minute 

flight duration for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M. The FAA issued 

an exemption to this regulation for UAS operations in Exemption Nos. 11062, 10673, 11136 and 

11138. 

In accordance with 14 C.F.R. § 11.81, Skyward provides the following information in 

support of its petition for exemption: 

A. Name and Address Of The Petitioner. 

The name and address of the Petitioner is:

Daniel Cyphers 

Statutory Agent 

Skyward, Ltd.

5717 Huberville Ave, Suite 300

Dayton, OH 45431-1217

B. The Specific Sections Of 14 C.F.R. From Which Skyward Seeks Exemption. 

1. Skyward 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 
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(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

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

connection with any business or employment if— 

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

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

hire. 

2. Skyward Seeks Exemption From The Requirements Of Section 91.7(a). 

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

following: 

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

condition. 

3. Skyward 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 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. 

4. Skyward Seeks Exemption From The Requirements Of Section 

91.151(a)(1)(b). 
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Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsections (a)(1)(b), state the following: 

(a) No person may begin 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 cruising speed— 

(1) During the day, to fly after that for at least 30 minutes; or 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

5. Skyward Seeks Exemption From The Requirement Of Section 91.405(a). 

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

following: Each owner or operator of an aircraft— 

(a) Shall have that 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[.] 

6. Skyward Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless-- 

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

43.7 of this chapter[.] 

7. Skyward 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 unless, within the preceding 12 calendar months, it has had -- 
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(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. Skyward Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (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: 

(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. 

(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, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 
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(v) The current status of applicable airworthiness directives (AD) and 

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

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

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

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

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

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

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

the work is performed. 

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

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

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

of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

C. The Extent Of Relief Skyward Seeks And The Reason Skyward Seeks The Relief. 

1. Extent Of Relief Skyward Seeks And The Reason Skyward 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 Pilot in Command (PIC) 

holding either an airline transport, commercial, private, recreational, or sport pilot certificate, as 

well as an airman medical certificate or valid U.S. driver’s license issued by a state, and who has 

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

operations for compensation or hire. 

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

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 
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business or employment if: (1) The flight is only incidental to that business or employment; and 

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

As set forth more fully below, Skyward submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate the DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs in a manner consistent with the 

operations specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Further, Skyward submits that all flights of the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to Skyward’s business; and (2) will not carry passengers or 

property for compensation or hire. 

2. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From 

Section 91.7(a). 

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

required to allow Skyward to determine that the DJI Inspire 1, DJI Spreading Wings s1000+, 

3DR X8-M, and 3DR Iris+ UASs are in airworthy condition prior to every flight by ensuring that 

the UAS is in compliance with the operating documents (i.e., the Skyward Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-

M, and 3DR Iris+ UASs Instruction Manual). 

Skyward seeks the requested relief because the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs do not require an airworthiness certificate in 
16

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Skyward will ensure that the DJI 

Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs are in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly Maintenance 

Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs 

Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition 

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

3. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From 

Section 91.121. 

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

operations of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs 

because before each flight, the altitude reporting equipment will be set on the ground to zero feet 

AGL, rather than the local barometric pressure or field altitude. The DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs utilize GPS equipment and radio 

communications telemetry data links to downlink altitude information from the UAS to the PIC 

at the ground control station (GCS). 

Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. 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.” An exemption may be needed because 

the UAS do not have a barometric altimeter, but instead have a GPS altitude read-out. An 

equivalent level of safety will be achieved by the operator, pursuant to the Manual, confirming 

the altitude of the launch site shown on the GPS altitude indicator before flight. Additionally, 

Skyward will operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 
17

Iris+ UASs within visual line of sight (VLOS), at or below 200 feet AGL. The FAA issued an 

exemption to this regulation for UAS operations in Exemption Nos. 11136 and 11138. 

4. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From 

Section 91.151(a)(1)(b). 

Relief from Section 91.151(a)(1)(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 

1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR),. 

An exemption is needed because the UAS have a maximum flight time of less than 30 

minutes and thus cannot meet the 30-minute reserve requirement. Given the characteristics of the 

UAS, including their small size, low weight and speed, limited range, ability to land very 

quickly, operation within visual line of sight, restricted operating area, and the fact that they do 

not carry persons or any explosive or flammable materials, grant of the exemption is justified. 

An equivalent level of safety can be achieved by terminating flights at 25% battery power 

reserve, which will occur before the 22 minute flight duration for the 3DR Iris +, and 18 minute 

flight duration for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M. The FAA issued 

an exemption to this regulation for UAS operations in Exemption Nos. 11062, 10673, 11136 and 

11138. 

Skyward seeks the requested relief because without an exemption from Section 

91.151(a)(1)(b), the flight time duration of the battery powered DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs will severely constrain the practicality of any 

aerial data collection flight operations that Skyward proposes to conduct pursuant to this Petition. 

5. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 
18

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, Skyward requests relief from these Sections 

because the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs do 

not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, Skyward will use 

trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., 

the Skyward aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs Instruction Manual). Furthermore, 

Skyward will document and maintain all maintenance records for the DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs. 

D. The Reasons Why Granting Skyward’s Request Would Be In The Public Interest; That 

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

Granting the present Petition will further the public interest by allowing Skyward to 

safely, efficiently, and economically operate UASs for the commercial purpose of conducting 

collection of aerial data of natural resources, areas surrounding natural resources, and 

commercial and agricultural areas that connect to, utilize, or affect natural resources, for the 

purpose of detection and monitoring of incidences, materials, and natural occurrences harmful to 

natural resources within the geographic boundaries of the United States. 

Additionally, use of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 

3DR Iris+ UASs will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Skyward’s proposed operation of the DJI 
19

Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs will be realized 

without implicating any privacy issues. 

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

The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs are 

battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft 

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

perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs would reduce the amount of manned aircraft in 

the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the 

air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

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

Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial data 

collection missions would result in fewer aircraft that must be handled by air traffic control 

during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1, 

DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs. 

Conducting aerial data acquisitions with the DJI Inspire 1, DJI Spreading Wings s1000+, 

3DR X8-M, and 3DR Iris+ UASs, instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated during traditional aerial data 

collection flight operations. By using battery power and electric motors, the DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs produce no air pollution, and are the 

most viable environmentally conscious alternative to the fuel-powered aircraft that are typically 
20

utilized for aerial data collection. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, 

and 3DR Iris+ UASs, while reducing the carbon footprint of aerial acquisitions, also eliminate 

noise pollution, as the UASs are propelled by battery powered electric motors, rather than an 

internal combustion engine. 

By using the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ 

UASs to perform aerial data acquisitions, the substantial risk to life and property in the air 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 Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 

3DR Iris+ UASs (weighing under 25lbs. at maximum gross takeoff weight, under three feet in 

diameter, and carrying no fuel on board) have 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 lbs with a wingspan of approximately 

42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Data Collection Operations With The DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs Will Benefit The 

Economy. 

In addition to being safe and efficient, the DJI Inspire 1, DJI Spreading Wings s1000+, 

3DR X8-M, and 3DR Iris+ UASs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs will allow United States based companies, like 

Skyward, to remain competitive and contribute to growth of the U.S. economy. Specifically, with 

the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory 

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new 
21

and alternative technology in order to remain competitive. Operating the battery powered DJI 

Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs is one such 

technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional manned 

aircraft. 

By operating the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ 

UASs, companies such as Skyward, 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 Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ 

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 United States and abroad. 

4. There Are No Privacy Issues. 

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

decades, Skyward’s proposed operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR 

X8-M, and 3DR Iris+ UASs will not implicate any privacy issues. Specifically, the DJI Inspire 1, 

DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs will be operated only in 

compliance with operating documents (i.e., the Skyward Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ 

UASs Instruction Manual) which requires property owner 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. 
22

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 Skyward Seeks Exemption. 

1. Reasons Why The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 

3DR Iris+ UASs Meet The Conditions Of The FAA Modernization and Reform 

Act of 2012 (FMRA) Section 333. 

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

unmanned aircraft and its operation, Skyward’s operation of the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs meet the conditions of FMRA Section 333, and 

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

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

shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

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

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

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

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

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

security; and 

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

certification under section 44704 of title 49, United States Code, is required 

for the operation of unmanned aircraft systems 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 
23

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

In seeking this exemption, Skyward submits that the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs; (b) the pilot certification requirement; and (c) 

the specific operating limitations. 

a. The Specifications Of The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR 

X8-M, and 3DR Iris+ UASs Demonstrate Safe Characteristics. 

The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs do 

not create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security considering the size, weight, speed, and operational capability of each. 

i. Technical Specifications Of The DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs. 

The technical specification of the DJI Inspire 1 UAS is set forth by the DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Exhibit A. 

The technical specification of the DJI Spreading Wings s1000+ UAS is set forth by the 

DJI Spreading Wings s1000+ Specifications and Data Sheet, attached hereto as Exhibit B. 

The technical specification of the 3DR X8-M UAS is set forth by the 3DR X8-M 

Specifications and Data Sheet, attached hereto as Exhibit C. 

The technical specification of the 3DR Iris+ UAS is set forth by the 3DR Iris+ 

Specifications and Data Sheet, attached hereto as Exhibit D. 

ii. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs Autonomous Flight And Navigation Modes Enable The UASs 

To Remain Within A Defined Operational Area. 
24

The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs may 

be operated in both manual and fully autonomous flight modes. The DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs may be operated in both semi and fully 

autonomous flight modes. The autonomous features include the following: a GPS Position and 

Altitude Hold when initiated by the GCS; Return To Home (RTH) functions; and Flight Limits 

(i.e., pre-set limitations that restrict the distance and height of UAS flight operations). 

A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is 

provided in the user’s manual attached hereto as Exhibit E. 

A complete description of the flight and navigational modes of the DJI Spreading Wings 

s1000+ UAS is provided in the user’s manual attached hereto as Exhibit F. 

A complete description of the flight and navigational modes of the 3DR X8-M UAS is 

provided in the user’s manual attached hereto as Exhibit G. 

A complete description of the flight and navigational modes of the 3DR Iris+ UAS is 

provided in the user’s manual attached hereto as Exhibit H. 

iii. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs Are Designed For Automatic Return To Home Point Or 

Hover Or Auto-Land In The Event Of Loss Of The Control Link Or 

Navigation. 

A complete description of the failsafe functions of the DJI Inspire 1 UAS is provided in 

the user’s manual attached hereto as Exhibit E. 

A complete description of the failsafe functions of the DJI Spreading Wings s1000+ UAS 

is provided in the user’s manual attached hereto as Exhibit F. 

A complete description of the failsafe functions of the 3DR X8-M UAS is provided in the 

user’s manual attached hereto as Exhibit G. 
25

A complete description of the failsafe functions of the 3DR Iris+ UAS is provided in the 

user’s manual attached hereto as Exhibit H. 

b. Flight Operations Of DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, 

and 3DR Iris+ UASs Are Limited To The Line Of Sight Of A Certificated Pilot 

in Command With A Safety Observer. 

Skyward will only utilize pilots who meet FAA certification requirements to act as a pilot 

in command (PIC) of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs. Additionally, a safety observer will assist all pilots during flight time, and all flights 

will remain within line of site of the PIC. Skyward’s Pilot in Command (PIC) will hold either an 

airline transport, commercial, private, recreational, or sport pilot certificate, as well as an airman 

medical certificate or valid U.S. driver’s license issued by a state, and will demonstrate, by 

meeting minimum flight-hour and currency requirements, the ability to safely operate the DJI 

Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs in a manner 

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

appropriate distances from people, vessels, vehicles and structures. 

c. Flights Of DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Skyward proposes to commercially operate DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs for the special purpose of 

conducting aerial data collection within the geographical boundaries of the United States, 

pursuant to the following specific operating limitations:

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

aircraft described in the operating documents, UASs weighing less than 55 pounds 

maximum gross weight: Rotocraft DJI Inspire 1, DJI Spreading Wings s1000+, and 

3DR X8-M, and 3DR Iris+ UASs. Proposed operations of any other aircraft will 

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

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

purpose of aerial data collection. 
26

3. The UASs may not be flown at an indicated airspeed exceeding 49 knots. 

4. The UASs must be operated at an altitude of no more than 200 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 UASs must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

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

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

PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating 

documents. 

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

avoiding other air traffic and other ground based obstacles/obstructions 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 Administrator upon request. If a discrepancy 

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

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

contained in the grant of exemption take precedence and must be followed. Otherwise, 

the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to the grant of exemption. If the 

operator determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the operator must petition for amendment to its grant 

of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

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

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

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

been performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records. 
27

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

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

must undergo a functional test flight. The PIC who conducts the functional test flight 

must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

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

overhaul, replacement, inspection, and life limit requirements. 

14. The operator 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 records, including total time in service, description of work accomplished, 

and the signature of the authorized person 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 aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must meet all FAA pilot certification requirements. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

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 operator’s PICs are permitted under the terms of the 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 UAS with appropriate distance from nonparticipants in accordance 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 office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

20. The UAS 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 conducted in 
28

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

agreement with the airport management must be made available to the Administrator 

upon request. 

21. The UAS 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 UAS loses communications or loses its GPS signal, it must return to a predetermined 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 unpredicted obstacles or emergencies in 

accordance with the operating documents. 

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

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

intended landing point and land the UAS with 20% battery power remaining. 

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

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

exemption. This COA will also require the operator to request a NOTAM not more 

than 72 hours in advance, but not less than 48 hours prior to the operation. All 

operations shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential transponder 

requirements. 

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable. 

27. The radio frequency spectrum used for operation and control of the UAS must 

comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements before conducting operations. 

28. The documents required 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 UAS must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

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

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

vessels, vehicles, and structures unless: 
29

a. Barriers or structures are present that sufficiently protect nonparticipating 

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

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UAS, flight operations must cease immediately and/or; 

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

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

and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with 

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

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

flight to be conducted. 

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

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

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

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

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

(b) Would Not Adversely Affect Safety. 

Skyward 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 Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs unless that PIC has demonstrated, 

by meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering Skyward’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 
30

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary 

to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ 

UASs, Skyward submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for Skyward’s 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, 11110, 11112, 11136, 11138, 11150, 

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

Skyward will not allow any PIC to operate the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-

M, and 3DR Iris+ UASs training and currency requirements, that the PIC is able to safely operate 

the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs in a manner 

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

appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS pilot (with a minimum 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 currency 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 
31

during Skyward’s proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe 

operations, 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 

multi-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 FAA 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 addition 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 proficiency 

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, proficiency, and 

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

accomplish the required flight time. During training, proficiency, and experiencebuilding flights the PIC is required to operate the UA with appropriate distances in 

accordance with 14 C.F.R 91.119.” 

See Exemption No. 11138 at page 15. 

Accordingly, Skyward will ensure safe operations by not allowing any PIC to operate the 

DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs in a manner consistent with the exemption, including evasive and emergency 

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

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

Not Adversely Affect Safety. 
32

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Skyward will ensure that the DJI Inspire 1, DJI Spreading Wings s1000+, 

3DR X8-M, and 3DR Iris+ UASs are in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

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

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

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 

11171, 11172, 11174, 11177, 11178, 11185, 11188). 

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

Not Adversely Affect Safety. 

An equivalent level of safety will be achieved by the operator, pursuant to the 91.121, 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

Additionally, Skyward will operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, 

and 3DR Iris+ UASs within visual line of sight (VLOS), at or below 200 feet AGL, and will be 

provided to the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This 

altitude information combined with Skyward’s operation of the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs within visual line of sight, at or below 200 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

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

initiation point will be established for the UASs at ground level. 

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

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 
33

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11174, 11176, 11177, 

11178, 11185, 11188). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(a)(1)(b) 

Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(a)(1)(b) as a result of (1) the technical specifications of the DJI Inspire 1, 

DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, 

Skyward will ensure that it will safely operate the battery powered UASs only during daylight 

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough 

battery power for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M UASs to fly for a 

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

speed, to fly after that for at least 5 minutes, and for the 3DR Iris+ UAS to fly for a total duration 

of 18 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 5 minutes. 

Here, as established by previous Grants of Exemption concerning the DJI Inspire 1 and 

DJI Spreading Wings s1000+ UASs; as in Exemption No. 11260, the technical specifications of 

the DJI Inspire 1 and DJI Spreading Wings s1000+ UASs; and Grants of Exemption concerning 

the 3DR X8-M UAS, as in Exemption No. 11617, the technical specifications of the 3DR X8-M; 

and the 3DR Iris+ as in Exemption No. 11490, the technical specifications of the 3DR Iris+; and 

the location of the proposed operations, will ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(a)(1)(b). Furthermore, safety will be ensured as the DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs provide audible and visual warnings 
34

to the PIC at the GCS when the UASs experiences low battery voltage. At the critically low 

battery level, the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ will 

descend and land automatically. 

Likewise, previous exemptions granted by the FAA concerning Section 91.151 establish 

that safety is not adversely affected when the technical characteristics and operating limitations 

of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

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

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

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 

11171, 11172, 11174, 11176, 11177, 11178, 11185, 11188). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not 

Adversely Affect Safety. 

In seeking this exemption, Skyward submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because all 

maintenance, alterations, or preventive maintenance of the UAS performed by Skyward will be 

in accordance with the methods, techniques, and practices prescribed in the operating documents 

(i.e., the Extended User Manual, Maintenance Procedures, Training Documentation, and 

Justification of Airworthiness and Safety Assessments). Furthermore, only the Original 

Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher-level 
35

inspections and maintenance per the operating documents and OEM standards. Skyward will 

document and maintain all maintenance records for the UAS. 

Since the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs 

will be inspected as prescribed by the operating documents, Skyward will maintain the 

equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 

Copies of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs user 

manuals are attached hereto as Exhibit E, F, G, and H; copies of the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs Maintenance Logs are attached hereto as 

Exhibit I. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UASs are considered. 

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Skyward requests that the FAA 

prescribe special conditions for the intended operation of the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs, which contain such safety standards that the 

administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(a)(1)(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will 

permit safe operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs for the limited purpose of conducting aerial data collection over the geographic 
36

boundaries of the United States for compensation or hire. FMRA Section 333 sets forth the 

requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security; and further, provides the authority for such 

UAS to operate without airworthiness certification in accordance with any requirements that 

must be established for the safe operation of the UAS in the NAS. 

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

§ 21.16, for operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR 

Iris+ UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 

21.16, entitled Special Conditions, states the following: 

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

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

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. 

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

prescribe special conditions for Skyward’s intended operation of the DJI Inspire 1, DJI 

Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to that established 

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

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

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which Skyward Seeks Exemption: 
37

Skyward, Ltd. seeks exemption from the requirements of 14 C.F.R Sections 

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

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

A Brief Description Of The Nature Of The Exemption Skyward Seeks: 

This exemption will permit Skyward, Ltd. to commercially operate Unmanned Aircraft 

Systems (UASs) for the purpose of conducting aerial data collection within the National 

Airpspace System (NAS). 

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

Request. 

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

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, Skyward’s request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

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

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

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

As discussed in detail above, Skyward will operate the DJI Inspire 1, DJI Spreading 

Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs safely in the NAS, without creating a hazard to 

users of the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, Skyward, Ltd. 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 Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs 

commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 
38

data acquisitions within the NAS. 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 public interests, by allowing Skyward to safely, efficiently, and economically 

operate UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Skyward 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(a)(1)(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), and permit Skyward to operate the DJI Inspire 1, DJI Spreading Wings 

s1000+, 3DR X8-M, and 3DR Iris+ UASs commercially for the purpose of conducting aerial 

data collection within the NAS. 

40

APPENDIX – A 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

1.1. DJI Inspire 1 

1.1.1. Aircraft 

1.1.1.1.1. Model: T600 

1.1.1.1.2. Weight (Battery Included): 6lbs 7.5291oz (2935g) 

1.1.1.1.3. Hovering Accuracy (GPS Mode): Vertical: 0.5m; Horizontal: 2.5m 

1.1.1.1.4. Max Angular Velocity: Pitch: 3000/s; Yaw: 1500/s 

1.1.1.1.5. Max Tilt Angle: 350

1.1.1.1.6. Max Ascent Speed: 5m/s 

1.1.1.1.7. Max Descent Speed: 4m/s 

1.1.1.1.8. Max Speed: 22m/s (ATTI mode, no wind – NOT 

RECOMMENDED) 

1.1.1.1.9. Max Flight Altitude: 4500m 

1.1.1.1.10. Max Wind Resistance: 10m/s 

1.1.1.1.11. Max Flight Time: Approximately 18 minutes 

1.1.1.1.12. Motor Model: DJI 3510 

1.1.1.1.13. Propeller Model: DJI 1345 

1.1.1.1.14. Operating Temperature Range: 140F to 1040F (-100C to 400C) 

1.1.1.1.15. Dimensions: 17 1⁄4” x 17 3⁄4” x 12” 

1.1.2. Gimbal 

1.1.2.1.1. Model: ZENMUSE X3 

1.1.2.1.2. Output Power (with camera): Static: 9W; In Motion: 11W 

1.1.2.1.3. Operating Current: Static: 750mA; In Motion: 900mA 

1.1.2.1.4. Angular Vibration Range: ±0.030

1.1.2.1.5. Mounting: Detachable 

1.1.2.1.6. Controllable Range: Pitch: -900 to +300; Pan: ±3200

1.1.2.1.7. Mechanical Range: Pitch: -1250 to 450; Pan: ±3300

1.1.2.1.8. Max Controllable Speed: Pitch: 1200/s; Pan: 1800/s 

1.1.3. Camera 

1.1.3.1.1. Name: X3 

1.1.3.1.2. Model: FC350 

1.1.3.1.3. Total Pixels: 12.76M 

1.1.3.1.4. Effective Pixels: 12.4M 

1.1.3.1.5. Image Max Size: 4000x3000 
41

1.1.3.1.6. ISO Range: 100-3200 

1.1.3.1.7. Field of View: 940

1.1.3.1.8. CMOS: Sony EXMOR 1/2.3” 

1.1.3.1.9. HD Video Recording: UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 

1280x720p24/25/30/48/50/60 

1.1.3.1.10. Operating Temperature Range: 320F - 1040F (00C - 400C) 

1.1.4. Transmitter 

1.1.4.1.1. Name: C1 

1.1.4.1.2. Operating Frequency: 5.728-5.850GHz; 2.400-2.483GHz 

1.1.4.1.3. Communicating Distance (unobstructed): 2000m 

1.1.4.1.4. Output Power: 9W 

1.1.4.1.5. Operating Temperature Range: 140F to 1040F (-100C to 400C) 

1.1.4.1.6. Battery: 600mAh LiPo 2S
42

APPENDIX – B 

DJI SPREADING WINGS S1000+ TECHNICAL SPECIFICATIONS 

1. DJI Spreading Wings s1000+ 

1.1. Frame 

1.1.1. Diagonal Wheelbase: 1045mm 

1.1.2. Frame Arm Length: 386mm 

1.1.3. Frame Arm Weight (Including Motor, ESC, Propeller): 325g 

1.1.4. Center Frame Diameter: 337.5mm 

1.1.5. Center Frame Weight (With Landing Gear Mounting Base, Servos): 1330g 

1.1.6. Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top 

width: 155 mm) 

1.2. Motor 

1.2.1. Stator Size: 41×14mm 

1.2.2. KV: 400rpm/V 

1.2.3. Max Power: 500W 

1.2.4. Weight(With Cooling Fan): 158g 

1.3. ESC 

1.3.1. Working Current: 40A 

1.3.2. Working Voltage: 6S LiPo 

1.3.3. Signal Frequency 30Hz ~ 450Hz 

1.3.4. Drive PWM Frequency: 8KHz 

1.3.5. Weight(With Radiators): 35g 

1.4. Foldable Propeller (1552/1552R) 

1.4.1. Material: High strength performance engineered plastics 

1.4.2. Size: 15×5.2inch 

1.4.3. Weight: 13g 

1.5. Flight Parameters 

1.5.1. Takeoff Weight: 6.0Kg ~ 11.0Kg 

1.5.2. Total Weight: 4.2Kg 

1.5.3. Power Battery: LiPo (6S、10000mAh~20000mAh、15C(Min)) 

1.5.4. Max Power Consumption: 4000W 

1.5.5. Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight) 

1.5.6. Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight) 

1.5.7. Working Environment Temperature: -10 °C ~ +40 °C 

1.6. Gain Value Settings 

1.6.1. For A2 Flight Controller Basic: Roll 120%, Pitch 120%, Yaw 120%; Attitude: 

Roll 170%, Pitch 170%, Vertical 120% 

1.6.2. For WooKong-M Flight Controller Basic: Roll 180%, Pitch 180%, Yaw 120%; 

Attitude: Roll 180%, Pitch 180%, Vertical 120% 
43

APPENDIX – C 

3D ROBOTICS (3DR) X8-M TECHNICAL SPECIFICATIONS 

1. 3DR X8-M 

1.1. Software 

1.1.1. Autopilot: 3DR Pixhawk V2.4.5 

1.2. Airframe 

1.2.1. Firmware: ArduCopter 3.2 

1.2.2. GPS: 3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update) 

1.2.3. Telemetry radio: 3DR Radio v2 (915 mHz or 433 mHz) 

1.2.4. Motors: SunnySky V2216-12 800 kV II 

1.2.5. Frame: X 

1.2.6. Propellers: APC 11X4.7 SFP (4), APC 11X4.7 SF (4) 

1.2.7. Aircraft weight (with battery): 7.7 lbs (3.5 kg) 

1.2.8. Aircraft dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm) 

1.2.9. Payload capacity: .4 lbs (200 g) 

1.2.10. Radio range: .6 miles* (1 km) 

1.2.11. Flight time: 14 min* 

1.2.12. Maximum operational wind speed: 25 mph (11 m/s) 

1.2.13. Landing accuracy: 8.2 ft (2.5 m) 

1.2.14. Recommended flight speed: 11 mph (5 m/s) 

1.3. Battery 

1.3.1. Battery: 4S 10000 mAh 10C lithium polymer 

1.4. Camera 

1.4.1. Camera: Canon SX260 12.1 megapixel 

1.4.2. Camera software: 3DR EAI 1.0 

1.4.3. Area coverage (single flight): 25 acres* (0.1 km2) 

1.4.4. Orthomosaic accuracy: 3-16 ft (1-5 m) 

1.4.5. Ground sampling distance: .7 inches per pixel* (2 cm per pixel) 

1.4.6. Image processing software: Pix4Dmapper LT 3DR Edition (Windows only) 
44

APPENDIX – D 

 3DR IRIS+ TECHNICAL SPECIFICATIONS 

1. 3DR Iris+ 

1.1. Software 

1.1.1. Autopilot: Pixhawk v2.4.5 

1.2. Airframe 

1.2.1. Firmware: ArduCopter 3.2 

1.2.2. GPS: 3DR uBlox GPS with Compass (LEA-6H module, 5 Hz update) 

1.2.3. Telemetry radio: 3DR Radio Telemetry v2 (915 mHz or 433 mHz) 

1.2.4. Motors: 920 kV 

1.2.5. Frame type: V 

1.2.6. Propellers: 9.5 x 4.5 T-Motor multirotor self-tightening counterclockwise (2) 

1.2.7. 9.5 x 4.5 T-Motor multirotor self-tightening clockwise (2) 

1.2.8. Radio range: up to 1 km (.6 miles) 

1.2.9. Flight time: 16-22 minutes, depending on payload 

1.3. Battery: 3S 5.1 Ah 8C lithium polymer 

1.3.1. Low battery voltage: 10.5 V 

1.3.2. Maximum voltage: 12.6 V 

1.3.3. Battery cell limit: 3S (IRIS is compatible with 3S lithium polymer batteries only. 

1.3.4. Using a 4S battery can cause permanent damage to the gimbal electronics and 

will void the warranty.) 

1.3.5. Payload capacity: 400 g (.8 lbs) 
45

APPENDIX – E 

SKYWARD MONTHLY MAINTENANCE LOG 

Year: ______  /  Month: _______

UAS Type & Tail #: _____________________________________________________________________

Date Issue

Discovered

Date Issue

Addressed Issue Description & Type Maintenance Conducted Maintenance Performed

By: (Print & Sign)

Software (Updates)

    

Airframe

    

Engines

    

Propellers

    

Camera / Gimbal

    

Landing Gear

    

Vibration (Dampening)

    

Other: