1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETI TION 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. 1022 TABLE OF CONTENTS Page

GLOSSARY OF ABBR EVIATIONS...................................................................................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 SK YWARD LTD SEEKS EXEMPTION.............................................................................................................10

THE EXTENT OF RELIEF SKYW ARD LTD SEEKS AND THE REASON SKYWARD LTD SEEKS THE RELIEF...............................................................14

THE REASONS WHY GRANTING SKYWAR D 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 PUBLISHE D IN THE FEDERAL REGISTER.......36

ANY ADDITIONAL INFORMAT ION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT SKYWARD LTD’s REQUEST.............................................................37

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

APPENDICES.........................................................................................403 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 Landing4 SUMMARY Skyward, Ltd. seeks exemption from the requ irements 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 conduc ting collection of aeri al 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 ha rmful 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 co llected from a variety of sensors that are mounted on small UASs. Skyward provides customer s with expertise in engineering analysis; test & evaluation planning, data collection, and reporting; data s ynthesis and analysis; modeling & simulation; weapon system analysis; and tech nology 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; ballisti c test & evaluation, including Live Fire Test & Ev aluation; vulnerability and sc ientific modeling & simulation,5 including vulnerability analysis, fire analysis, and desi gn 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 engineeri ng and 3D design, includin g the utilization of inhouse scanning equipment; munition/warhead charac terization/lethality; instrumentation; highspeed video; air vehicle performance; and doc umentation and program management support. Recent experience includes Intelligence, Surveill ance, and Reconnaissance (ISR) aircraft, sensor, and primary mission equipment integration; opera tional data collection, pr ocessing, and analysis; Federal Aviation Administration (FAA) and re quirements compliance; mission performance; validation/verification; and expe rimental testing. Our exper tise encompasses ground, sea, and rotary and fixed-wing air vehicl e 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 re sidential 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-dimensiona l modeling and inspection of public and private structures.

• Increase public knowledge of UAS a nd promote safe UAS operations.6 BACKGROUND Unmanned Aerial System s: 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, Identificati on 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 Contro l 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 capabi lity to return to the launching point if the wireless control link is interr upted or if the operator attempts to exceed any of the pre-programmed height, radius, or airs pace limitations. All four UAS platforms will be operated in airspace under 200ft AGL and within Line of Sight, and wi ll 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 Spre ading Wings S1000; DJI Inspire); and the 3DR X8-M in Aerial Precision Survey, Exemption No. 11617, Regulatory Docket No. FAA-7 2015-0549 (as amended 19 May 2015)(3D Robotics X8+) ; and the 3DR Iris+ in Counsel for The Travelers Companies, Inc., Exemption N o. 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 regist ered 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 provision s 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), 9 1.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, a nd limited operating area associated with the unmanned aircraft and its opera tion, 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 fr om Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as th ese sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.8 Skyward submits that the requested relief is proper since an equivalent level of safety will be ensured. Skyward will use experienced person nel or technicians to perform maintenance, alterations, or preventive mainte nance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Mo nthly 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 main tenance 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 cer tificate or valid U.S. driver’s license issued by a state, and who has demonstrated, by mee ting 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 appropr iate 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 cond ition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and9 DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs Instruction Manual), and that the aircraft ar e in a condition for safe flight. Skyward also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the altitude reporti ng 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 Spread ing Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs is provided to the PIC vi a Global Positioning System (GPS) equipment, and a radio communications telemetry data link, which down links from the UAS to the GCS for active monitoring of the flight path. An equivalent le vel 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 combin ed 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 fo r UAS operations in Exemption Nos. 11136 and 11138. Additionally, Skyward seeks an exempti on 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) ther e 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....”10 An exemption is needed because the UAS ha ve a maximum flight time of less than 30

minutes and thus cannot meet the 30-minute reserv e requirement. Given the characteristics of the UAS, including their small size, low weight a nd speed, limited range, ability to land very quickly, operation within visual lin e of sight, restricted operating ar ea, and the fact that they do not carry persons or any explosiv e or flammable materials, grant of the exemption is justified. An equivalent level of safety can be achieve d 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 Spr eading 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, Skywar d 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. Fr om Which Skyward Seeks Exemption.

1. Skyward Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Privat e pilot privileges and lim itations: 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 command11 (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensati on 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 Th e Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airw orthiness, subsecti on (a), states the following: (a) No person may operate a civil airc raft unless it is in an airworthy

condition.

3. Skyward Seeks Exemption From Th e Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, s ubsection (a), states the following, in part: (a) Each person operating an aircraft sha ll 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, th e 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).12 Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsections (a)(1)(b), st ate the following:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather c onditions) there is enough fuel to fly to the first point of intended l anding and, assuming normal cruising speed— (1) During the day, to fly after t hat 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 c onditions) there is enough fuel to fly to the first point of intended landi ng 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 re paired as prescribed in pa rt 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), st ates the following: (a) No person may operate any aircra ft that has undergone maintenance, preventive maintenance, rebui lding, 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 Re quirements 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 precedi ng 12 calendar months, it has had --13 (1) An annual inspection in accordance w ith 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 certif icate 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) a nd (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, prev entive maintenance, and alteration and records of the 100-hour, annual, pr ogressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, ro tor, and appliance of an aircraft. The records must include-- (i) A description (or reference to da ta 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 serv ice of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life-lim ited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of a ll 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 re quired by the inspection program under which the aircraft and its appliances are maintained.14 (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 cu rrently 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 re gistered 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 Skywar d Seeks And The Reason Sk yward Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113( a) and (b) entitled Private pilot privil eges and limitations:

Pilot in command , is requested to the extent necessary to allow a Pilot in Command (PIC) holding either an airline transport, commercial, priv ate, recreational, or sport pilot certificate, as

well as an airman medical certificate or valid U.S. driver’s li cense issued by a state, and who has met certain flight-hour and currency require ments, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested sin ce 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 any15 business or employment if: (1) The flight is onl y incidental to that bus iness 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 th at 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 th is 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, conducte d 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 Skywar d Seeks And The Reason Sk yward 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 doc uments (i.e., the Skyw ard Aerial Operations Manual, Monthly Maintenance Log, and DJI In spire 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 re quire an airworthin ess certificate in16 accordance with 14 C.F.R. Part 21, Subpart H. Th erefore, 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 ope rating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1, DJI Spreading Wi ngs s1000+, 3DR X8-M, and 3DR Iris+ UASs Instruction Manual) prior to every flight, and further, determine th at the aircraft are in condition for safe flight, as stated in the conditions and li mitations below. 3. Extent Of Relief Skywar d Seeks And The Reason Sk yward 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 Spreadi ng Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs because before each flight, the altitude reporting e quipment 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 contro l station (GCS).

Considering the limited altitude of the pr oposed 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 altime ter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before de parture.” 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 th e operator, pursuant to the Manual, confirming

the altitude of the launch site shown on the GPS altitude indicat or before fli ght. Additionally, Skyward will operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR17 Iris+ UASs within visual line of sight (VLOS), at or below 20 0 feet AGL. The FAA issued an exemption to this regulation for UAS operations in Exemption Nos. 11136 and 11138.

4. Extent Of Relief Skywar d Seeks And The Reason Sk yward 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 allo w 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 ha ve a maximum flight time of less than 30

minutes and thus cannot meet the 30-minute reserv e requirement. Given the characteristics of the UAS, including their small size, low weight a nd speed, limited range, ability to land very quickly, operation within visual lin e of sight, restricted operating ar ea, and the fact that they do not carry persons or any explosiv e or flammable materials, grant of the exemption is justified. An equivalent level of safety can be achieve d by terminating flights at 25% battery power reserve, which will occur before the 22 minute f light duration for the 3DR Iris +, and 18 minute flight duration for the DJI Inspire 1, DJI Spr eading 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 becau se 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 opera tions that Skyward proposes to c onduct pursuant to this Petition. 5. Extent Of Relief Skywar d Seeks And The Reason Sk yward 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 certifica te, Skyward requests relief from these Sections because the DJI Inspire 1, DJI Spreading Wi ngs s1000+, 3DR X8-M, and 3DR Iris+ UASs do not require airworthiness certificates. As set fo rth 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 airworthin ess certificate. Accord ingly, Skyward will use

trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices pr escribed in the UAS operating documents (i.e., the Skyward aerial Operations Manual, Mont hly 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 main tenance 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 th e public interest by allowing Skyward to safely, efficiently, and economi cally operate UASs for the commercial purpose of conducting

collection of aerial data of natural resources, areas surround ing natural resources, and commercial and agricultural areas that connect to, utilize, or a ffect natural resources, for the purpose of detection and monitoring of incidences, materials, and natural occurrences harmful to

natural resources within the geographic boundari es of the United States. Additionally, use of the DJI Inspire 1, DJ I 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 DJI19 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 w ould reduce the amount of manned aircraft in the NAS, reduce noise and air polluti on, 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. Like wise, a reduction of manned airc raft conducting aerial data

collection missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arriva l, 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 pollutio n, and are the most viable environmentally conscious alternative to the fuel-powered aircraft that are typically20 utilized for aerial data collection. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs, while reducin g the carbon footprint of aeria l acquisitions, also eliminate noise pollution, as the UASs are propelled by batte ry powered electric motors, rather than an internal combustion engine. By using the DJI Inspire 1, DJI Spreadi ng Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs to perform aerial data acquisitions, the substa ntial risk to life and pr operty in the air and on the ground, which is usually associat ed with traditional manned airc raft 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, comp ared 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 econom ical alternative to us ing 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 a llow United States based companies, like Skyward, to remain competitive a nd contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Envi ronmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new21 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 great er operational flexibility compared to manned aircraft, but provides such flex ibility without the hi gh operational cost of a traditional manned

aircraft. By operating the DJI Inspire 1, DJI Spreadi ng Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs, companies such as Skyward, can remain competitive and profitable, and therefore, provide greater job stabil ity to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financia l performance of U.S. companies, through commercial use of the DJI Inspire 1, DJI Spr eading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs, provides a stable workforce that increases consumer spending; impr oves local, state, and federal tax revenues; and allows companies to i nvest in research and development in order to remain competitive both in th e 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 Spre ading 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 Whic h 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 opera tion, Skyward’s operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs m eet the conditions of FMRA Section 333, and will not require an airworthine ss certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airwor thiness certification and sets forth requirements for considering whet her a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Spec ifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstanding any other requ irement of this subtitle, and not later than 180 days after the date of enactment of th is Act, the Secretary of Transportation shall determine if certain unmanned aircra ft systems may operate safely in the national airspace system before completi on of the plan and rulemaking required by section 332 of this Act or the guidance re quired by section 334 of this Act. (b) Assessment of Unmanned Aircraft Sy stems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum-- (1) which types of unmanned aircraft syst ems, if any, as a result of their size, weight, speed, operational capability, pr oximity 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, cert ificate of authorizatio n, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircra ft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the S ecretary determines unde r this section that certain unmanned aircraft systems may opera te safely in the national airspace23 system, the Secretary shall establish requirements for th e 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 opera te safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the charac teristics 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 Inspi re 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 th e 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 Insp ire 1 UAS is set forth by the DJI Inspire 1 Specifications and Data Sheet, att ached hereto as Exhibit A. The technical specification of the DJI Spr eading Wings s1000+ UAS is set forth by the DJI Spreading Wings s1000+ Specifications and Da ta 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, att ached hereto as Exhibit C. The technical specification of the 3DR Iris+ UAS is set forth by the 3DR Iris+ Specifications and Data Sheet, att ached 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 f light 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 feat ures 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 re strict 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 at tached hereto as Exhibit E. A complete description of th e flight and navigational modes of the DJI Spreading Wings s1000+ UAS is provided in the user’s ma nual attached hereto as Exhibit F. A complete description of th e flight and navigational mode s of the 3DR X8-M UAS is provided in the user’s manual at tached hereto as Exhibit G. A complete description of th e flight and navigational mode s of the 3DR Iris+ UAS is provided in the user’s manual at tached hereto as Exhibit H. iii. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs Are Designed For Automa tic 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 functi ons of the DJI Inspire 1 UAS is provided in

the user’s manual attached hereto as Exhibit E. A complete description of th e failsafe functions of the DJ I Spreading Wings s1000+ UAS is provided in the user’s manual attached hereto as Exhibit F. A complete description of the failsafe functi ons 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 functi ons 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 Li ne Of Sight Of A Certificated Pilot in Command With A Safety Observer. Skyward will only utilize pilots who meet FAA certification re quirements 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 ob server will assist all pilots during flight time, and all flights will remain within line of site of the PIC. Skyw ard’s Pilot in Command (P IC) will hold either an airline transport, commercial, privat e, recreational, or sport pilot ce rtificate, 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 abil ity to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3D R X8-M, and 3DR Iris+ UASs in a manner consistent with this exemption, including evas ive and emergency maneuvers and maintaining appropriate distances fr om people, vessels, vehi cles 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 3D R Iris+ UASs for the special purpose of conducting aerial data collection within the ge ographical 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 th e operating documents, UASs weighing less than 55 pounds maximum gross weight: Rotocraft DJI In spire 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 peti tion to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial da ta collection.26 3. The UASs may not be flown at an i ndicated 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 sp ecified in the operating documents unless a special request is made and approved by AT C. All altitudes reported to ATC must be in feet AGL. 5. The UASs must be operated within visual lin e 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 PI C 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 alwa ys 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 operati ons. The PIC must be designated before the flight and cannot transfer his or her designation for th e 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 dutie s 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 availabl e to the Administrator upon re quest. If a discrepancy exists between the conditions and limitations contained in the gr ant 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 opera ting documents. It is the operator’s responsibility to track such revisions and present updated a nd revised documents to the Administrator upon request. The operator mu st also present updated and revised documents if it petitions for extension or am endment to the grant of exemption. If the operator determines that any update or revi sion 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 Integrati on Office (AFS-80) may be contacted if questions arise regarding updates or re visions to the operating documents. 10. Prior to each flight the PIC mu st inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condi tion 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 docum ented in the aircraft records.27 11. Any UAS that has undergone maintenan ce or alterations that affect the UAS operation or flight characteri stics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the func tional 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 manufact urer’s aircraft/component, maintenance, overhaul, replacement, inspecti on, and life limit requirements. 14. The operator must carry out its mainte nance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of re placement/overhaul component pa rts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized pe rson returning the UAS to service. 15. Each UASs operated under this exemption mu st comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entr y in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must meet all FAA p ilot certification requirements. 18. The operator may not permit any PIC to ope rate 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 ma intaining 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 e xperience-building flight s, all persons not essential for flight operations are consid ered nonparticipants, and the PIC must operate the UAS with appropriate distan ce from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted durin g 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 spec ial 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 aeronautic al chart unless a letter of agreement with that airport’s management is obt ained, and the operation is conducted in28 accordance with a NOTAM as required by th e 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 le ss 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 communicatio ns or loses its GPS signal, it must return to a predetermined location within the planned ope rating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a fli ght 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 accordan ce 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 th e 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 requirem ents 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 Contro l Station of the UAS any time the UAS is operating. These documents must be made availa ble to the Administ rator 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 activitie s at all times. 30. The UAS may not be operated by the PI C 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 train ees 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 pers ons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight ope rations must cease immediately and/or; b. The aircraft is operated near vessel s, vehicles or st ructures 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 do es not present an undue hazard, and; c. Operations nearer to the PIC, SO, ope rator trainees or es sential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over pr ivate 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 Sa fety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 2. Reasons Why An Exemption From Th e 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 requi rements, 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, incl uding evasive and emergency maneuvers and maintaining appropriate dist ances from people, vessels, vehicles and structures. Considering Skyward’s proposed area of ope rations, and the operating limitations set forth-above; the parallel nature of private pilo t aeronautical knowledge requirements to those of30 commercial pilot requirements (See Exemption N o. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1, DJI Sp reading Wings s1000+, 3D R X8-M, and 3DR Iris+ UASs, Skyward submits that the additional manned airmanship experience of a commercially certificated pilot would not correl ate to the airmanship skills n ecessary 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 pres ented 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 requirem ents, 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 evas ive and emergency maneuvers and maintaining appropriate distances fr om people, vessels, vehi cles 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, pr ior documented flight experience that was obtained in compliance with ap plicable regulations will ensure an equivalent level of safety31 during Skyward’s proposed operations. The Administ rator 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 si milar operations), the PIC must have accumulated and logged, in a manner consiste nt 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 opera tions under the exemption. For clarification, the FAA considers these minimum hour requireme nts to be inclusive rather than additive; i.e. 5 hours make and model time may be includ ed 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 accomplis h 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 approp riate to practice and build proficiency in the skills necessary to safely conduc t the petitioner’s proposed operations. The FAA also finds that prior documente d 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. Duri ng training, proficiency, and experiencebuilding flights the PIC is re quired to operate the UA w ith appropriate distances in accordance with 14 C.F.R 91.119.”

See Exemption No. 11138 at page 15. Accordingly, Skyward will ensure safe opera tions by not allowing any PIC to operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3D R 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 ev asive and emergency maneuvers and maintaining appropr iate distances from people, ve ssels, 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 ba sed upon the UAS’s compliance with its operating documents and as st ated 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 materi al 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 Th e Requirements Of Section 91.121 Would Not Adversely Affect Safety. An equivalent level of safety will be ach ieved by the operator, pursuant to the 91.121, confirming the altitude of the launch site show n on the GPS altitude indicator before flight. Additionally, Skyward will operate the DJI Insp ire 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 ra dio 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 In spire 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 ai rcraft. Prior to each flight, a zero altitude initiation point will be establis hed 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 speci fications of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3D R Iris+ UASs; (2) the limitations on the proposed flight operations; and (3 ) the location of the proposed f light 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 ru les (VFR), with enough battery power for the DJI Inspire 1, DJI Spread ing Wings s1000+, 3DR X8-M UASs to fly for a

total duration of 13 minutes to the first point of intende d landing and, assuming normal cruising speed, to fly after that for at l east 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 Exem ption No. 11260, the technical specifications of the DJI Inspire 1 and DJI Spreading Wings s100 0+ 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, sa fety will be ensured as the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8 -M, and 3DR Iris+ UASs provide audible and visual warnings34 to the PIC at the GCS when the UASs experiences low battery voltage. At the critically low battery level, the DJI Inspire 1, DJI Spread ing 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 th e technical characteristic s and operating limitations

of the UAS are considered. Relief has been granted for manned aircra ft 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 re lief 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 th at the equivalent level of safety with regard to the regulatory maintenance and al teration requirements es tablished by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), an d 91.417(a) & (b) will be met because all maintenance, alterations, or preventive maintena nce 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, Maintenan ce Procedures, Training Documentation, and Justification of Airworthiness and Safety A ssessments). Furthermore, only the Original Equipment Manufacturer (OEM) or qualified OE M maintainers will perform higher-level35 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 Wi ngs s1000+, 3DR X8-M, and 3DR Iris+ UASs will be inspected as prescribed by the opera ting 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 Ma intenance Logs are attached hereto as

Exhibit I.

Significantly, previous exemptions grante d by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b) estab lish that safety is not adversely affected when the technical characteristics and op erating limitations of the UASs are considered.

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

In accordance with Section 333 of the F AA 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 opera tion 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 geographic36 boundaries of the United States for compensati on 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 certifica tion 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 airworthine ss regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design feat ures of the aircraft. Section 21.16, entitled Special Conditions , states the following:

If the FAA finds that the airw orthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft e ngine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendm ents 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 Sec tion 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Skyward’s in tended 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 Fe deral 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, Skyw ard’s request for exemption may be granted pursuant to the authority of FM RA Section 333 and 14 C.F.R. Pa rt 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 ot herwise pose a threat to national security; and further, provides the authority for such UAS to operate without airw orthiness certification. As discussed in detail above, Skyward will operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs safe ly in the NAS, without creating a hazard to users of the NAS, or the public, or otherw ise 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 Spreadi ng Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs commercially, without an airwor thiness certificat e, for the limited purpose of conducting aerial38 data acquisitions within the NAS. By granting this Petition, the FAA Ad ministrator 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, Sectio n 333, Skyward respectfully requests that the Administrator grant this Petition for an exemp tion 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 S kyward to operate the DJI In spire 1, DJI Spreading Wings s1000+, 3DR X8-M, and 3DR Iris+ UASs commerci ally 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 Include d): 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: 300 0 /s; Yaw: 150 0 /s 1.1.1.1.5. Max Tilt Angle: 35 0 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: 14 0 F to 104 0 F (-10 0 C to 40 0 C) 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: ±0.03 0 1.1.2.1.5. Mounting: Detachable 1.1.2.1.6. Controllable Range: Pitch: -90 0 to +30 0 ; Pan: ±320 0 1.1.2.1.7. Mechanical Range: Pitch: -125 0 to 45 0 ; Pan: ±330 0 1.1.2.1.8. Max Controllable Speed: Pitch: 120 0 /s; Pan: 180 0 /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: 4000x300041 1.1.3.1.6. ISO Range: 100-3200 1.1.3.1.7. Field of View: 94 0 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: 32 0 F - 104 0 F (0 0 C - 40 0 C) 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: 14 0 F to 104 0 F (-10 0 C to 40 0 C) 1.1.4.1.6. Battery: 600mAh LiPo 2S42 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 Mo tor, ESC, Propeller): 325g 1.1.4. Center Frame Diameter: 337.5mm 1.1.5. Center Frame Weight (With Landing G ear 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 perfor mance 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 Temper ature: -10 °C ~ +40 °C 1.6. Gain Value Settings 1.6.1. For A2 Flight Controller Basic: Ro ll 120%, Pitch 120%, Yaw 120%; Attitude: Roll 170%, Pitch 170%, Vertical 120% 1.6.2. For WooKong-M Flight Controller Ba sic: 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 Compa ss (LEA-6H module, 5 Hz update) 1.2.3. Telemetry radio: 3DR Radi o 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 fli ght): 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: Pix4Dma pper 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 Compa ss (LEA-6H module, 5 Hz update) 1.2.3. Telemetry radio: 3DR Radio Te lemetry 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: