UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:


### JONATHAN ANDREW PITTS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CON CERNING COMMERCIAL OPERATION OF

DJI PHANTOM 3 UNMANNE D AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on September 4 , 2015

Jonathan Andrew Pitts (owner/operator/pilot)

340 S Lemon Ave #4731 Walnut, CA 91789 USA

Home Tel: ( 469 ) 919

- 5229 Cell: ( 352 ) 221

- 43202 

## TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

................................ ................................ .................. 3

SUMMARY

................................ ................................ ................................ ....................... 4

INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ .... 4

BACKGROUND

................................ ................................ ................................ ......... 4

BASIS FOR PETITION

................................ ................................ .............................. 4

A. Name and Address Of The Petitioner:

................................ .............................. 6

B. The Specific Sections of 14 C.F.R. from which Jonathan Andrew Pitts Seeks Exemption.

................................ ................................ ................................ ............. 6

C. The Extent Of Relief Jonathan Andrew Pitts Seeks And The Reason Jonathan

Andrew Pitts Seeks The Relief.

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

D. The Reasons Why Granting Jonathan Andrew Pitts’ Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

.............. 10

E. The Reasons Why Granting The Exemption Would Not Adversely Affect

Saf ety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which I Seek Exemption.

.......................... 1 3

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

................................ ................................ . 22

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

Jona than Andrew Pitts’ Request.

................................ ................................ ........ 22

CONCLUSION

................................ ................................ ................................ ........ 23

APPENDICES

................................ ................................ ................................ ................ 24

APPENDIX A

................................ ................................ ................................ ........... 25

APPENDIX B

................................ ................................ ................................ ........... 27

APPENDIX C

................................ ................................ ................................ ........... 283 

## 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

................................ ................................ .......................... Ce rtificate 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

PIC

................................ ................................ ................................ ......... Pilot In Command

Section 333

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

S O

................................ ................................ ................................ ............ 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

Jonathan Andrew Pitts seek s exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA

Modernization and Reform A ct of 2012 (FMRA). This exemption will permit me to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for real estate photography and special events over cert ain areas

of the United States of Am erica.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Jonathan Andrew Pitts is a licensed real estate agent in multiples states and provides his clients with expertise in real estate transactions and high quality photographs

to aide in those transactions. Petitioners objective in aerial video and photography is to provide high quality imaging to aide in commercial, residential, or government real estate

transactions.

Petitioner possesses a second class medical certificate and is a commercial pilot

with a irplane single and multiengine land, instrument airplane ratings with approximately 1,700 hours of flight time and over 15 years of experience in aviation. Petitioner also holds a Bachelor of Science Degree from Embry

- Riddle Aeronautical University in Aeronautics with minors in Flight, Air Traffic Control, and Business.

BACKGROUND Unmanned Aircraft Systems: DJI Phantom 3

Jonathan Andrew Pitts seek s an exemption to op erate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maxi mum gross weight of approximately 1280 gram, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 UA is equipped with four main rotors; driven by Lithium Polymer b attery powered electric

motors.

The DJI Phantom 3 UA that will be operated by Jonathan Andrew Pitts 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, Jonathan Andrew Pitts

, 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 Phantom 3 UAS in the National Airspace System (NAS), and for an exemption from the requirem ents of 14 C.F.R5 §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Jonathan Andrew Pitts

, will meet 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, Jonathan Andrew Pitts

, request s 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.

Jonathan Andrew Pitts submit s that the requested relief is proper since an equivalent level of safety will be ensured. Petitioner will use his experience to perform maintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniques, and practices prescribed i n the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Petitioner will

document and maintain all maintenance records for the DJI Phantom 3 UAS

.

Jonathan Andrew Pitts seek s relief from Section 91.7(a) , entitled Civil Aircraft

A irworthiness , because the DJI Phantom 3 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Jonathan Andrew

Pitts will ensure that the UAS is in an airworthy condition, prio r to every flig ht, by determining that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft is in a condition for safe flight.

Jonathan Andrew Pitts also seek s an exemption from the requirements of Section
91.121, entitled Altimeter Settings , as the DJI Phantom 3 UA will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 UA will be provided to the PIC via Global P ositioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with my operation of the

DJI Phantom 3 UAS within visual li ne of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Jonathan Andrew Pitts

, seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Jonathan

Andrew Pitts submit s that safety will not be affected by operation of the DJI Phantom 3

UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, Jonathan Andrew Pitts provides the following information in support of it s petition for exemption:6 A. Name a nd Address Of The Petitioner :

Jonathan Andrew Pitts (owner/operator)

340 S Lemon Ave #4731 Walnut, CA 91789 USA

Tel : (469) 919

- 5229 Fax: (866) 237

- 6383

Email: jon@ticonoc.us

B. The Specific Sections of 14 C.F.R. from w hich Jonathan Andrew Pitts S eeks Exemption.

1

. Jonathan Andrew Pitts Seek s Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil A ircraft A irworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

2

. Jonathan Andrew Pitts Seek s Exemption From The Requirements Of

Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the fo llowing, 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 altimet er 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 statio n; 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.

3

. Jonathan Andrew Pitts Seek s Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection7 (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is eno ugh fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

4

. Jonathan Andrew Pitts Seek s Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenanc e 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[.]

5

. Jonathan And rew Pitts Seek s 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 aircra ft 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.

6

. Jonathan Andrew Pitts Seek s Exemption From The Requiremen ts 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

--

(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.

7

. Jonathan Andrew Pitts Seek s Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).8 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 sh all 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

(i i) 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 o n 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 a re maintained.

(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 ac tion, 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 ope rator shall retain the following records for the periods prescribed:9 (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 Jonathan Andrew Pitts Seek s And The Reason Jonathan

Andrew Pitts Seek s The Relief.

1 . Extent Of Relief Jonathan Andrew Pitts Seek s And The Reason Jonathan

Andrew Pitts Seek s Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil Aircraft A irworthiness , is requested to the extent required to allow Jonathan Andrew Pitts to determine that the DJI Phantom 3 UAS

is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Operations Manual, Monthly Maintenance Log, and

DJI Phantom 3 Instruction Manual).

Jonathan Andrew Pitts seek s the requested relie f because the DJI Phantom 3 UAS

do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Jonathan Andrew Pitts will ensure that the and DJI Phantom 3 UAS

is in airworthy condition based upon its compliance w ith the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 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.

2 . Exten t Of Relief Jonathan Andrew Pitts

, Seek s And The Reason Jonathan

Andrew Pitts Seek s Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 UA S , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information co ncerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Jonathan Andrew Pitts seek s the requested relief because the DJI Phantom 3 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local ba rometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and10 limitations stated below. As mo re fully set forth herein, an equivalent level of safety will

be maintained since the DJI Phantom 3 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established p rior to each flight, and provides the PIC with altitude

information of the UA on the heads

- up display of the GCS.

3 . Extent Of Relief Jonathan Andrew Pitts Seek s And The Reason Jonathan

Andrew Pitts Seek s Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI

Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rul es (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

Jonathan Andrew Pitts seek s the requested relief because without an exemption from

Section 91 .151(b), the flight time duration of the battery powered DJI Phantom 3 UA will severely constrain the practicality of any aerial video or still photo flight operations that

Jonathan Andrew Pitts proposes to conduct pursuant to this Petition.

Significantl y, as set forth below, the technical specifications of the DJI Phantom 3 UAS, and DJI Phantom 3 operating documents, and petitioner’s proposed operating limitations, ensure that Jonathan Andrew Pitts will safely operate the battery powered DJI

Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, t o fly after that

for at least 5 minutes.

4. Extent Of Relief Jonathan Andrew Pitts Seek s And The Reason Jonathan

Andrew Pitts Seek s Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91. 409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Jonathan Andrew Pitts request s relief from these Sections because the DJI Phantom 3 UAS do es not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meet s the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly

, petitioner will perform maintenance, alterations, or pr e ventive maintenance

on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Operations Manual, Monthly Maintenance Log, and DJI

Phantom 3 Instruction Manual). Furthermore, petitioner will document and ma intain all

maintenance records for the DJI Phantom 3 UAS

.

D. The Reasons Why Granting Jonathan Andrew Pitts’ Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.11 Granting the present Petition will further the public interest by allowing Jonathan

Andrew Pitts t o safely, efficiently, and economically perform aerial video and photography

for real estate photography, and special events over certain areas of the United States. Specifically:

• Petitioner possesses a real estate license in multipl e states and being able to provide aerial photography services to his clients is an economic benefit to the local community.

• Petitioner is an active member of the aviation communit y and will be able to provide a positive impact on the advancement of UAS activity in the local community through increased awareness and education.

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and p rovide significant benefits to the economy. Notably, the benefits of

Jonathan Andrew Pitts’ proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit from Decreased Congestion of The NAS.

The DJI Phantom 3 UA is battery powered and serve s as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acqui sitions, an exemption allowing the use of a DJI Phantom 3 UAS 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 reducin g the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The

DJI Phantom 3 UA do es not require an airport to takeoff or land. Likewise, a reduction of

manned aircraft conduc ting aerial video and photography 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 E fficiency Of The DJI

Phantom 3 UAS

.

Conducting aerial acquisitions with the DJI Phantom 3 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 UAS produce s no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning a pproximately 20

- 30 gallons per hour of leaded aviation

fuel. The DJI Phantom 3 UA , while reducing the carbon footprint of aerial acquisitions,

also elimin ates noise pollution, as the UA is propelled by battery powered electric motors,

rather than an intern al combustion engine.12 By using the DJI Phantom 3 UAS to perform aerial 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 Phantom

3 UA (weighing only 1280 grams , at maximum gross weights with lengths of 16 inches, widths of 16 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 ga llons).

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 3 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS will allow United States based entities , like

Jonathan Andrew Pitts 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 and alternative technology in orde r to remain competitive. Operating the battery powered DJI Phantom 3 UAS 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 Phantom 3 UAS

, entities such as Jonathan Andrew Pitts 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 Phantom 3 UAS provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows compani es 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, Jonathan And rew Pitts’ proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e., the Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 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. § 91.119.13 E. The Reas ons 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 I Seek Exemption.

1. Reasons Why The DJI Phantom 3 UA Meet s The Conditions Of Th e 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, my operation of the DJI Phantom 3 UAS

meet s 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. Speci fically, 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 sy stem 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 t o 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 req uired 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 s ystem, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Jonathan Andrew Pitts submit s that the DJI Phantom 3

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by:14 (a) the characteristics of the DJI Phantom 3 UAS ; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 UASs Demonstrate Its Safe

Character istics.

The DJI Phantom 3 UAS do es not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 UAS

.

The technical specifications of the DJI Phantom 3 UASs are set forth by the DJI

Phantom 3 Specifications and Data Sheet. Technical specifications can be found in Appendix A.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes

Enable Th e UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI

Phantom 3 UAS is available on

- line DJI Phantom 3 User Manual

.

iii. The DJI Phantom 3 UA s Is Designed For Automatic Return To Home

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UA do es not reacquire

control link data from the GCS, the UA will assume that the Control Link is lost and the

UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS is

available on

- line at DJI Phantom 3 User Manual

.

a. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Jonathan Andrew Pitts propose s to commercially operate the DJI Phantom 3 UA for the purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

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

aircraft descri bed in the operating documents, rotorcraft UASs weighing less15 than 55 pounds maximum gross weight : DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS op erations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued

airman medical certificate.

6. The use of first person view (FPV) by th e 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 verb ally 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 perfor m 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 camer a 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 petit ions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the16 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 inspect ion 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 i ncluded in the preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

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 air craft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the

UAS to service.

15. Each UAS 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 operator may not permit any PIC to operate unless the PIC meets the operator’s qualification cr iteria 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 be17 co nducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonpar ticipants in accordance with 14 C.F.R. § 91.119.

1 8 . 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.

19 . The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current F AA

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

2 0 . The UA may not be operated less than 400 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

2 1 . If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.

2 2 . The PIC must abort the flight in the event o f unpredicted obstacles or emergencies in accordance with the operating documents.

2 3 . 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 in tended landing point and land the UA with 25% battery power remaining.

2 4 . 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. Thi s COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued CO A including class of airspace, altitude level and potential transponder requirements.

2 5 . 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 (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.18 2 6 . Before conducting operations the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communica tions Commission (FCC) or other appropriate government oversight agency requirements.

2 7 . 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. Thes e documents must be made available to the Administrator or any law enf orcement official upon request.

2 8 . The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

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

3 0 . 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:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises wher e nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determi ned 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).

3 1 . All operations shall be conducted over private or contro lled

- 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.

3 2 . Any incident, accident, or flight o peration 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

.19 2 . Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safet y established by Section 91.7(a) will be maintained because prior to every flight, Jonathan Andrew Pitts will ensure that the DJI Phantom 3 UAS is 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 UAS, in circumstan ces 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).

3 . Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the DJI Phantom 3 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with my operation of the DJI Phantom 3 UA within visual line of sight, at or below 400 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 is autom aticall y established by

the UAS 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. 11062, 11063, 11064, 11065, 11066, 110 67, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4 . Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivale nt level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI

Phantom 3 UAS ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. According ly, petitioner will ensure that it will safely operate the battery powered DJI Phantom 3 UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, t o fly after that for at least 5

minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom

3 UAS ; the limitations on the proposed flight operations; and the location of the proposed20 operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS provide s audible and visual warnings to the P IC at the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10 % remaining battery power. At the critically low battery level,

the DJI Phantom 3 UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected whe n 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, th e 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, 1 1110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5 . 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, petitioner 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

pe titioner will use trained technicians to perform maintenance, alterations, or pr eventive

maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Operations Manual, Monthly Maintenance Log, and DJI

Phantom 3 Instruction Manual). Furthermore, I will document and maintain all

maintenance records for the DJI Phantom 3 UAS

.

Likewise, the exemption sought will not adversely affect safety because Jonathan

Andrew Pitts will use my experience to perfo rm maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91 .407, 91.417(a) and 91.417(b), because all maintenance of the

DJI Phantom 3 UAS will be performed by me. Maintenance will be documented and maintained utilizing the monthly maintenance log.

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

th e UAS are considered.21 In consideration of my proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 UAS , I submit that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91 .405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 1106 6, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 201 2 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Jonathan Andrew Pitts request s that the FAA prescribe special conditions for the intended operation of the DJI

Phantom 3 UAS , which contain such safety standards that the Administrator finds

neces sary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe

o peration of the UAs for the limited purpose of conducting aerial video and photography over certain areas 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 user s 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 Phantom 3 UAS , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate sa fety 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 s afety 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 i ssued 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 peti ti oner’s intended operation of the DJI Phantom 3

UAS , 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,22 and 14 C.F.R Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

From Which I Seek Exemption:

Jonathan Andrew Pitts seeks exemption from the requirements of 14 C.F.R

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

A Brief Description Of The Nature Of The Exemption I Seek:

This exemption will permit Jonathan Andrew Pitts to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the Uni ted States.

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

Jonathan Andrew Pitts’ Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Trans portation to determine if certain UAS may operate safely in the NAS. As such, petitioner’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 airworth iness

certification.

As discussed in detail above, petitioner will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.23 CONCLUSION

As set forth herein, petitioner seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate o f the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Jonathan Andrew Pitts to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the

NAS.

WHEREFORE , in accordan ce with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Jonathan Andrew Pitts respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 91.7( a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit petitioner to operate the DJI Phantom 3 UAS commercially for the purpose of conducting aerial video and photography over certain

areas of the United Stat es.

Respectfully submitted,

_________________________

Dated: September 3 , 2015 Jonathan Andrew Pitts (owner/operator)

340 S Lemon Ave #4731 Walnut, CA 91789 USA

Home Tel: ( 469 ) 919

- 5229 Cell: ( 352 ) 221

- 432024 

## APPENDICES

Appendix A

– DJI Phantom 3 Technical Specifications Appendix B

– DJI Phantom 3 Preflight, Flight, and Emergency Check List s Appendix C

– Monthly Maintenance Log25 APPENDIX A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

Petitioner utilizes a safe and reliable UAS . DJI is an industry leader in small UAS production. DJI UASs are programmed with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can a lso be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (sma rt phone/tablet devices)

.26 DJI PHANTOM 3 TECHNICAL SPECIFICATIONS (CONT’D)27 APPENDIX B

DJI Phantom 3 Pre

- Flight Inspection Check List

PREFLIGHT CHECK LIST

1. Visually inspect aircraft for defects

2. Batteries fully charged and checked

– Remote Controller, Intelligent Flight Battery, and

mobile devices

3. Propellers mounted correctly and firmly

4. S D card in serted in camera

5. Lens cap removed

6. Antenna extended

7. Transmitter turned on (press once, release, then press and hold for 3 seconds)

8. Ensure Tr ansmitter is in P Mode

9. UAS turned on (press once, release, then press and hold for 3 seconds)

10. Activate the transformation switch on transmitter up and down 4 times quickly to

convert from travel mode to flight mode or use the appropriate app lication

11. DJI Pi lot application activated

12. Tap bar at top of control application (Safe to Fly GPS) for full status

13. Maps are cached (move the map around, zoom in an out)

14. Minimum return height adjusted (check for tallest object and set accordingly)

15. UAS placed in safe launch and recover position

16. Home point programmed via app

17. Area clear of people / obstructions

18. Obtain weather briefing to ensure conditions are optimal for safe operation

TAKE OFF AND CRUISE CHECK LIST

1. Hover close for 20 seconds. Observe for proper operation.

2. Confirm expected stick operation

3. Monitor battery power

4. Monitor signal strength

5. Maintain line

- of

- sight with UAS

6. Ensure area of intended flight path is clear of other aerial traffic.

7. Ensure area of intended flight path is clear of any electrical/power lines

EMERGENCY LANDING

Select a safe zone to for emergency landing of the UAV/UAS in the event an emergency landing is required

.28 A PPENDIX C

MONTHLY MAINTENANCE LOG

MONTH/YEAR:



### A/C N#: Date Description of

Maintenance Signature

and Name

of

Mechanic
Firmware Updates

Airframe

Engines

Propellers

Camera/Gimbal

Landing Gear

Vibration/Dampening

Other

-

Other

-

Other

-

Other

-