### September 2, 2015

Exemption No. 12727 Regulatory Docket No. FAA

− 20 15

− 2519

Mr. Craig Fonseca Sparktech Imagery LLC 1500 Beville Road, 606

- 416 Daytona Beach, FL 32114

Dear Mr. Fonseca :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 2, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Sparktech Imagery LLC ( hereinafter petitioner or operator ) for a n exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial

video graphy and photography

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision +, DJI Phantom 3 Professional, and DJI Inspire

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in

### 2

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for pr oducts and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the pe titioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granti ng Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Sparktech Imagery LLC is granted an exemption from

14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 

### Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.

### 3

Conditions and Limitations

In this grant of exemption, Sparktech Imagery LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phanto m 2 Vision +, DJI Phantom 3 Professional, and DJI Inspire when weighing less than

55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of clos ed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 kno t speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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 or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS req uirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and c annot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,

### 4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outli ned 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 or any law enforcement official upon req uest. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exempt ion, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenan ce or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may onl y be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining an d inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all

potent ial discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption m ust comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC m ust operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (V MC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with a n ARP, the center of the airport symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreem ent with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or wit h the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

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

.

### 6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, an d have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating 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 where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensurin g the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property w ith permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that tran sgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTS B) per instructions

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

.

### 7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditi ons and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the f ollowing:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and ser ial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list o f those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

### 8

This exemption termin ates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresUNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

SPARKTECH IMAGERY LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14

OF THE CODE OF FEDERAL REGULATIONS SECTIONS

14 C.F.R §§ 45.23(b) ; Part 21 , Subpart H; 61.23(a); 61.113(a) ; 91.7(a); 91.119(c) ; 91.121 ; 91.151(a );
91.405(a) ; 91.407(a)(1); 91.409(a)(1) & (2); 91.4 17(a)&(b) ;

CONCERNING COMMERCIAL OPERATION OF DJI UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on June 2nd 2015

Craig Fonseca

Sparktech Imagery LLC

1500 Beville Road, 606

- 416

, Daytona Beach, FL, 32114

Tel: 386

- 675

- 4879

support@sparktechima gery.comPetition for Exemption 

# SPARKTECH IMAGERY LLC

page 2

Sparktech Imagery LLC

, formally requests exemption from the requirements of 14 C.F.R §§ 45.23(b) ; Part

21 , Subpart H; 61.23(a); 61.113(a) ; 91.7(a); 91.119(c) ; 91.12 1 ; 91.151(a ); 91.405(a) ; 91.407(a ) (1);
91.409(a)(1) & (2); 91.417(a)&(b) ; to operate an Unmanned Aircraft System pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Sparktech Imagery LLC to

operate its U nmanned A ircraft S ystem (s) (UAS) for the commercial purpose of conducting aerial video

and photography in airspace regulated by the Federal Aviation Administration over various locations,
including landscapes, waterways and oceans within the United States of America.



### Sparktech Imagery LLC’s objective is to capture

, document and archive images and

video using aerial photographic & video technology , thus p roviding its clients low cost, high quality imaging and views from different perspectives.



## THE UNMANNED AIRCRAFT SYSTEMS of SPARKTECH IMAGERY LLC :

(1) DJI Phantom 2 Vis ion +

(2) DJI Phantom 3 Professional

(3) DJI Inspire

The petitioner requests permission to operate the DJI Phantom 2 Vision +

, the DJI Phantom 3 Professional

and the DJI Inspire UAS with in the National Airspace System for hire or compensation. All of the DJI

systems listed above are vertical takeoff and landing, unmanned aircraft with a ground control station
utilizing electronic tablet or smart phone systems. They also have a maximum speed under 50 knots and

weighing less than 7 pounds. No operation will be conducted within 5NM of an airport. Included as the

appendix to this document are the data specifications and links to the user manuals to the UAS. Similar
exemptions utilizing such UAS have been approved and deemed airworthy , not requiring any

airworthiness certification, including exemptions Nos. 11109 Clayco, Inc, 11595 Gary Huett, 11669

Photobird LLC.

In accordance with 14 C.F.R § 11.81, Sparktech Imagery LLC provides the following information in support of its petition for exemption.Petition for Exemption 

# SPARKTECH IMAGERY LLC

page 3



## NAME AND ADDRESS OF PETITIONER:

Sparktech Imagery LLC

Attn: Mr. Craig Fonseca
Mailing address: 1500 Beville Road, 606

- 416, Daytona Beach, FL, 32114

Email: support@sparktechimagery.com

Tel: 386

- 675

- 4879



### Sparktech Imagery LLC submits that proper safety will be ensured and can serve to benefit the general public and pose no threat to national security.

Sparkte ch Imagery LLC will use experienced personnel or technicians to perform maintenance,
alterations, or preventative maintenance on the UAS using the methods, techniques and practices
prescribed in the operating documents. Sparktech Imagery LLC will document and maintain a

maintenance record for its UAS.

Sparktech Imagery LLC will have a Pilot in Command (PIC) that holds either an airline transport,

commercial, private, recreational, or sport pilot certificate and medical certificate or valid US driver’s

lice nse. The PIC will operate the UAS within visual line of sight and use a visual observer at all times. All
operations will be at a maximum of 400ft above ground level. The PIC will conduct pre

- flight inspections

with every flight; in addition a post

- fligh t inspection will also be performed . To ensure further safety, no
PIC will be allowed to operate the UAS unless that PIC has met certain flight

- hour requirements,

demonstrating that the PIC is able to safely operate either of the UAS including e vasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Utilization of the built

- in features in the DJI systems such as flight telemetry and records will be logged

.

Sparktech Imagery LLC’s operatio ns utilizing the UAS will provide a great benefit to the general public
and serve the interest of the public by providing a service that was once only available by hiring a

much larger manned aircraft. In comparison, the UAS will provide a service of quali ty aerial
photographic images and video to many different business and individuals for considerabl y less cost

than that of utilizing a manned aircraft. In addition to saving money, the time required for setup and

flight is also considerably shorter , inclu ding the fac t that you are documenting on site versus taking off
from an airport to then go to the location or site . These UAS have significant safety, noise, emission,

security and environmental benefits

, not availa ble to larger manned aircrafts, by using battery power

and electric motors. They also have numerous safety features such as ‘Failsafe mode’, automatic

landing should the signal between PIC and the UAS be interrupted, GPS based altitude and distance

locks, flight limit functions and low battery warnings.

The use of the UAS will decrease congestion of the National Airspace System and reduce air and noise

pollution. Further, by this reduction it can increase the safety of life and property in the air and on the
ground. Airport congestion will also be reduced as the UAS do not require an airport for takeoff orPetition for Exemption 

# SPARKTECH IMAGERY LLC

page 4

landing, thus aiding to reduce the load on the air traffic control during ground, departure, arrival and
landing phases of flight operations.

Sparktech Imagery LLC proposed commercial operations would not implicate any privacy issues. The

UAS will be operated in compliance with property owners, as well as any local law enforcement

requests or notifications if applicable and in accordance with the Federal Aviation Regulations.



# Specific Sections of 14 C.F.R from which Sparktech Imagery LLC seeks exemption :

1. 45.23(b) Aircraft markings

2. Part 21 , Subpart H Certification procedures; Airworthiness Certificates

3. 61.23(a) Medical Certificate requirements

4. 61.113( a ) Private pilot privileges

5. 91.7(a) Airworthiness certificate

6. 91.119 (c) Minimum safe altitudes

7. 91.121 Altimeter settings

8. 91.151(a ) Fuel requirements for flights in VFR conditions

9. 91.405(a) Maintenance required

10. 91.407(a) (1) Operation after maintenance

11. 91.409(a)(1)and (2) Inspections

12. 91.417(a)&(b) Maintenance records



# Extent of Relief and Reasons Requesting Relief

14 C.F.R. 45.23( B ) : D ISPLAY OF M ARKS ; G ENERAL Sparktech Imagery LLC has Unmanned Aircraft Systems, which , as unmanned, do not have a cabin,

cockpit or pilot station to mark certain words. Furthermore, the two

- inch lettering is also difficult to place

on such a small aircraft . Sparktech Imagery LLC’s UAS will have identification by serial number,
registered in accordance with 14 C.F.R. part, and have i dentification (N

- Number) markings in
accordance with 14 C.F.R. Part 45, Subpart C. Markings will be large as possible. The FAA has previously
issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10700 and 11595.

14 C.F .R. P ART 21

, S UBPART H & 14 C.F.R. 91

– A IRWORTHINESS C ERTIFICATES

, M ANUALS AND OTHER REQ UIREMENTS
Sparktech Imagery LLC uses UAS that when considering their size, weight , speed , and the limited

operating area associated with the airc rafts and their operat ions meet the conditions of Section 333,
and requests relief from the regulation. With regards to the requirements 14 C.F.R 91 .7(a); considering
the exemption of requiring an airworthiness certificate, size and unmanned status of the UAS thePetition for Exemption 

# SPARKTECH IMAGERY LLC

page 5

regulations are inapplicable to this operation. The petitioner will meet all safety requirements and
registrations of the FAA and maintain a safety record and manual for the UAS. To ensure the UAS are
airworthy, proper maintenance will be regularly applied.

14 C.F. R. § 61.23( A ), 61.113 ( A ): M EDICAL CERTIFICATE & P RIVATE P ILOT P RIVILEGES AND L IMITATIONS : O PERATOR

. Sparktech Imagery LLC’s UAS will not carry any persons on board. It will be remotely controlled and
operated by a PIC holding either an airline transport, commercial, private, recreational, or sport pilot

certificate ensuring that the PIC has the skills to safely operate the system in a manner acceptable to

the FAA. In addition all PIC operators will go through guidance

, training and meet certain flight

- hour
requirements, demonstrating that the PIC is able to safely operate either of the UAS including evasive

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

and structures prior to operating any of Sparktech Imagery LLC’s UAS. The PIC will hold either a current

FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia,

Puerto Rico, a territory, a possession, or the Federal Government. All Sparktech Imagery LLC operations

will be controlled and limited . All flights will be coordinated ahead of time ensuring a level of safety that

is in accordance with FAA requirements.

14 C.F.R. § 91.119 : M INIMUM S AFE A LTITUDES
Sparktech Imagery LLC’s UAS will never operate at an altitude greater than 400 feet AGL unless other

altitude limits are forthcoming by the FAA. The petitioner will operate the UAS in a manner protecting

the public and any consenting participants, providing a level of safety at least equivalent to or belo w

those in relation to minimum safe altitudes.

14 C.F.R. § 91.121: A LTIMETER S ETTINGS
Sparktech Imagery LLC ’s UAS h ave no altimeter settings. They, however, utilize electronic global positioning systems with a barometric sensor providing instantaneous telemetry to the PIC as to the altitude (AGL) of the UAS above the takeoff location.

14 C.F.R. § 91.151( A ) F UEL R EQUIREMEN TS FOR F LIGHT IN VFR C ONDITIONS

. Sparktech Imagery LLC believes that an equivalent level of safety can be achieved by following the
UAS manufacturer’s operating documents with regard to battery voltage. In order to achieve or

exceed the level of safety, th e PIC will not begin a flight unless (considering wind and forecast weather

conditions) there is enough power to conduct the intended operation and to operate after that for at

least 5 minutes.Petition for Exemption 

# SPARKTECH IMAGERY LLC

page 6

14 C.F.R. § 91.405( A ); 407 ( A )(1); 409 ( A ) (1)&(2); 417( A ) &( B ): M AINTENANCE INSPECTIO NS Sparktech Imagery LLC operators and PIC will perform preventative and required maintenance on its

UAS as required by the manufacturer and/or FAA safety/service bulletins. If a mechanical event occurs

the UA will land immediate ly. The operator will make sure that the UAS is in an airworthy condition prior
to each flight operation. The operator will perform maintenance on its UAS and will maintain thorough
record keeping of any maintenance performed.

In order to meet or exceed le vel of safety as described in 14 C.F.R operations will include:

Pre

- flight operations: prior to each flight the PIC will conduct and preflight inspection of the UAS and

Grou nd Control Station to ensure they are in such condition safe for flight . All discr epancies found
during the preflight inspection will prohibit flight operations until the necessary maintenance has been
performed and the UAS is found to be in a condition for safe flight. All discrepancies, maintenance,

alterations will be properly docume nted in the aircraft records.

If the UAS has undergone maintenance or alterations that affect the UAS operation or flight
characteristics there will be a functional flight test by the PIC and the PIC will make and entry in the

aircraft records. All mainte nance will follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement and inspection requirements.

Each UAS will comply with all manufacturers ’ s afety b ulletins.

The operator will carry out its maintenance, inspections, and reco rd keeping requirements, in

accordance with the manufacturers operating documents. All m aintenance, inspection, alterations,
and status of replacement/overhaul component parts must be noted in the aircraft records, including

total time in service, descript ion of work accomplished, and the signature of the authorized person
returning the UAS to service.

Authorized persons will make entry in the aircraft record of corrective action taken against
discrepancies discovered between inspections.

STATUTORY AUTH ORITY FOR EXEMPTION

In accordance with the FMRA

, Section 333 & 334 states that the Secretary of Transportation has the

authority to grant which types of unmanned aircraft systems can be used in the national airspace

system and whether a certificate of wai ver, authorization or airworthiness is required for operation.
Furthermore, subject to operating restrictions required by the FAA, facilitate the capability of public
agencies to develop, test and operate unmanned aircraft systems.Petition for Exemption 

# SPARKTECH IMAGERY LLC

page 8



## APPENDI X

DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software

enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can

also 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 monit or (smart phone/table t devices). The following are the
technical specifications of the DJI UAS to be used by Sparktech Imagery LLC:



## DJI Phantom 2 Vision+ Technical Specifications

AIRCRAFT

Supported Battery DJI 5200mAH Li

- Po Battery

Weight (Battery & Propellers Included) Recommended payload Maximum payload 1242g (2lbs 11.8oz)

≤ 1300g

1350 g Hovering Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal 2.5m

Max Yaw Angular Velocity 200o/s

Max Tiltable Angle 35o

Max Ascent/Descent Speed Ascent: 6m/s; Descent: 2m/s

Max Flight Speed 15m/s [29knots] (Not Recommended)

Motor Diagonal Length 350mm

3

- AXIAL STABILIZED GIMBAL

Working current Static: 750mA; Dynamic: 900mA

Control Accuracy ±0.03°

Controllable Range Pitch:

- 90o

- 0o

Maximum Angular Speed Pitch: 90o/s

Max Tiltable Angle 35o

CAMERA

Operating Environment Temperature 0oC

- 40oC

Sensor size 1/2.3”

Effective Pixels 14 Megapixels

Resolution 4384 x 3288

HD Recording 1080p30 / 1080i60

Recording FOV 110o / 85oPetition for Exemption 

# SPARKTECH IMAGERY LLC

page 9

DJI Phantom 2 Vision+ Technical Specifications cont’d

REMOTE CONTROLLER

Operating Frequency 5.728GHz

– 5.85GHz

Communication Distance (open area) CE Compliance: 400m; FCC Compliance: 800m Receiver Sensitivity (1%PER)

- 93dBm

Transmitting Power (EIRP) CE Compliance: 25mW; FCC Compliance: 100mW Working Current / Voltage 120mA@3.7V

Battery 2000mAh rechargeable Li

- Po battery

RANGE EXTENDER

Operating Frequency 2412MHz

– 2462MHz

Communication Distance (open area) 500m

– 700m
Transmitting power 20dBm

Power consumption 2W

The complete user manual for can be found: http://www.dji.com/product/phantom

- 2

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## DJI Phantom 3 Professional Technical Specifications

AIRCRAFT

Weight (Battery & Propellers Included) 12 80 g (2lbs 13.1oz )

Max Ascent/Descent Speed Ascent: 5m/s; Descent: 3m/s

Max Speed 16m/s (ATTI mode, no wind)

Max Flight Altitude 6000m

Max Flight Time Approx. 23minutes

Operating Temperature 0oC

- 40oC

GPS mode GPS/GLONASS

GIMBAL

Controllable Range Pitch:

- 90o to + 3 0oPetition for Exemption 

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page 10

DJI Phantom 3 Professional Technical Specifications cont’d

VISION POSITIONING

Velocity Range < 8m/s (2m above ground)

Altitude Range 30cm

– 300cm
Operating Range 30cm

– 300cm

Operating Environment Brightly lit (lux > 15) pattern surfaces

CAMERA

Sensor Sony EXMOR 1/2.3” Effective pixels:12.4 M
(total pixels: 12.76 M)

Lens FOV 94° 20mm (35mm format equivalent )

f/2.8

ISO Range 100

- 3200(video) 100

- 1600(photo)

Electronic Shutter Speed 8s

- 1/8000s

Image Max size 4000 x 3000

Still Photography Modes Single shot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5

Bracketed frames at 0.7EV

Bias Time

- lapse Supported SD Card Types Micro SD Max. capacity: 64 GB. Class 10 or UHS

- 1 rating required Video Recording Modes UHD : 4096x2160p 24/25, 3840x2160p24/25/30 FHD:1920x1080p 24/25/30/48/50/60 HD:1280x720p 24/25/30/48/50/60 Max. Bitrate Of Video Storage 60 Mbps

Supported File Formats FAT32/exFAT
Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 A VC/H.264) Operating Temperature Range 0°C to 40°CPetition for Exemption 

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page 11

DJI Phantom 3 Professional Technical Specifications cont’d

REMOTE CONTROLLER

Operating Frequency 2.400 GHz

- 2.483 GHz

Transmitting Distance 2000 m (Outdoor And Unobstructed)

Video Output Port USB

Operating Temperature Range 0°C

- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder Tablets and smartphones

Transmitter Power(EIRP) FCC: 20 dbm; CE:16 dbm

Working Voltage 1.2 A @7.4 V

CHARGER

Voltage 17.4 V

Rated Power 100 W

INTELLIGENT FLIGHT BATTERY ( PH3

- 4480 MAH

- 15.2 V )

Capacity 4480 mAh

Voltage 15.2 V
Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Operating Temperature

- 10°C

- 40°C

Max. Charging Power 100 W

The complete user manual for can be found: http://www.dji.com/product/phantom

- 3/downloadPetition for Exemption 

# SPARKTECH IMAGERY LLC

page 12



## DJI Phantom Inspire 1 Technical Specifications

AIRCRAFT

Model T600

Weight (Battery & Propellers Included) 2935 g (approx.6 lbs 8oz )

Hovering Accuracy (P Mode) Vertical: 0.5 m Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent/Descent Speed Ascent: 5m/s; Descent: 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 45 00m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approx. 18 minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by default

Operating Temperature

- 10oC

- 40oC

Diagonal Distance 559 to 581mm

Dimensions 438 x 451 x 301 mm

GIMBAL

Model ZENMUSE X3

Output Power (With Camera) Static: 9 W; In Motion: 11 W

Operating Current Station: 750 mA; Motion: 900 mA

Detachable Angular Vibration Range ±0.03°

Mounting Detachable

Controllable Range Pitch:

- 90o to + 30o

Pan: ± 320o

Mechanical Range Pitch:

- 125° to +45°

Pan: ±330°

Mac Controllable Speed Pitch: 120 ° /s

Pan: 180 ° /sPetition for Exemption 

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page 13

DJI Phantom Inspire 1 Technical Specifications cont’d

CAMERA

Name X3

Model FC350

Total Pixels 12.76M

Effective Pixels 12.4M

Image Max Size 4000 x3000

ISO Range 100

- 3200(video) 100

- 1600(photo)

Electronic Shutter Speed 8s

- 1/8000s

Field of View (FOV) 94o

CMOS Sony EXMOR 1/2.3”

Lens 20mm (35mm format equivalent) f/2.8

focus at ∞ 9 Elements in 9 groups

Anti

- distortion
Still Photography Modes Single shot
Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5

b racketed frames at 0.7EV

Time

- lapse

Video Recording Modes UHD (4K): 4096x2160p 24/25, 3840x2160p24/25/30 FHD:1920x1080p 24/25/30/48/50/60 HD:1280x720p 24/25/30/48/50/60

Max. Bitrate Of Video Storage 60 Mbps

Supported File Formats FAT32/exFAT
Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported SD Card Types Micro SD Max. capacity: 64 GB. Class 10 or UHS

- 1 rating required Operating Temperature Range 0°C to 40°CPetition for Exemption 

# SPARKTECH IMAGERY LLC

page 14

DJI Phantom Inspire 1 Technical Specifications cont’d

REMOTE CONTROLLER

Name C1

Operating Frequency 922.7MHz~927.7 MHz (Japan Only)

5.725~5.825 GHz;2.400~2.483 GHz
Transmitting Distance 2 k m (Outdoor And Unobstructed)

EIRP 10dBM@900m, 13dBm@5.8G,

20dMb@2.4G Video Output Port USB, Mini

- HDMI

Power Supply Built

- in battery

Charging DJI Charger

Dual User Capacity Host

- and

- Slave connection

Mobile Device Holder Tablets or smartphones

Output Power 9W

Operating Temperature Range

- 1 0°C

- 40°C

Storage Temperature Range Less than 3months:

- 20oC

– 45oC

More than 3months: 22oC

– 28oC Charging Temperature Range 0oC

- 40oC

Battery 6000 mAh LiPo 2S

CHARGER

Model A14

- 100P1A

Voltage 26.3 V

Rated Power 100 W

BATTERY (STANDARD)

Name Intelligent Flight Battery

Model TB47

Capaci ty 4 500 mAh

Voltage 22.2 V
Battery Type LiPo 6 S high voltage battery

Energy 99.9 Wh

Net Weight 570 g
Operating Temperature

- 10°C

- 40°C

Storage Temperature Less than 3months:

- 20oC

– 45oC

More than 3months: 22oC

– 28oC Charging Temperature 0oC

- 40oC

Max. Charging Power 18 0 WPetition for Exemption 

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page 15

DJI Phantom Inspire 1 Technical Specifications cont’d

BATTERY (OPTIONAL)

Name Intelligent Flight Battery

Model TB48

Capaci ty 5700 mAh

Voltage 22.8 V
Battery Type LiPo 6 S

Energy 129.96 Wh

Net Weight 6 70 g
Operating Temperature

- 10°C

- 40°C

Storage Temperature Less than 3months:

- 20oC

– 45oC

More than 3months: 22oC

– 28oC Charging Temperature 0oC

- 40oC

Max. Charging Power 18 0 W

VISION POSITIONING

Velocity Range Below 8 m/s (2 m above ground)

Altitude Range 5

- 500 cm

Operating Environment Brightly lit (lux > 15) patterned surfaces

Operating Range 0

- 250 cm

DJI PILOT APP

Mobile Device System Requirements iOS version 7.1 or later;

Android version 4.1.2 or later Supported Mobile Devices * iPhone 6 Plus, iPhone 6, iPhone 5S, iPad
Air 2, iPad Mini 3, iPad Air, iPad Mini 2, iPad 4;* Samsung Note 3, Samsung S5, Sony Z3 EXPERIA; * Note: It is recommended that you use a tablet for the best experience

The complete user manual for can be found: http://www.dji.com/product/inspire

- 1/download