1

Henry H. Perritt, Jr.

Attorney at Law

1131 Carol Lane

Glencoe, IL 60022

hperritt@gmail.com

(312) 504-5001

11 May 2015

Hon. Michael Huerta

Administrator

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations from certain parts of the FARs.

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

“Reform Act”) and 14 C.F.R. Part 11, Satellite Technology Systems Inc, an Illinois

corporation (“STS” or the “Petitioner”), hereby applies for a summary exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow it to operate small Unmanned 

Aircraft Systems (“sUAS”) for aerial data collection, under the conditions and 

limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and 

relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited,

(2) predetermined, and (3) would provide safety enhancements to the already safe news 

gathering operations presently using manned helicopters and airplanes. Approval of 

this exemption would thereby enhance safety and fulfill the FAA Administrator’s 

responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act.
2

The name and address of the applicant is:

Satellite Technology Systems, Inc

Attn: Charles Spoto

4702 State Route 176, Unit F

Crystal Lake, Illinois 60014

Correspondence should be directed to:

Henry H. Perritt, Jr.

Attorney at Law

1131 Carol Lane

Glencoe, IL 60022

hperritt@gmail.com

(312) 504-5001

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. § 45.23(b)

14 CFR § 61.3

14 C.F.R. § 91.7 (a)

14 CFR § 91.9 (b) (2)

14 C.F.R. § 91.103

14 C.F.R. § 91.109

14 C.F. R. § 91.119

14 C.F.R. § 91.121

14 CFR § 91.151 (a)

14 CFR § 91.203 (a) & (b)

14 CFR § 91.205(b) 

14 CFR § 91.215 
3

14 CFR § 91.405 (a)

14 CFR § 407 (a) (1)

14 CFR § 409 (a) (2)

14 CFR § 417 (a) & (b)

Appendix 1 describes the FARs from which an exemption is requested and summarizes 

the justification for each requested exemption. 

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the 

Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Administrator must determine which types of UASs do 

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

in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). 

If the Administrator determines that such vehicles “may operate safely in the national 

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

aircraft in the national airspace system.” Id. § 333(c) (emphasis added).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions 

from its regulatory requirements for civil aircraft, a term defined under § 40101 of the 

Act, which includes sUASs. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) or (b) of this section or any 

sections 44702-44716 of the Federal Aviation Act if Administrator finds the exemption 

in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 

CFR §91.203 (a) (1).
4

Satellite Technology Systems, Inc. is an Illinois corporation (Ill. Secretary of State 

registration no. 56177876). It provides hybrid satellite production trucks that connect 

cameras and other audio and video equipment in the field with television and other 

video production and transmission facilities through satellite links. Based in the 

Chicago suburbs, STS has developed premier satellite ku uplink trucks operating 

throughout the Midwest including Detroit, Michigan; Minneapolis, Minnesota; 

Indianapolis, Indiana; St. Louis, Missouri; Peoria and Springfield, Illinois; Davenport 

and Des Moines, Iowa; Madison and Milwaukee, Wisconsin. Its unparalleled service is 

marked by attention to detail that can only be reached with a small satellite truck 

company. Its clients include NFL Films, ABC, BBC, CNN, ESPN, MSNBC, NBC, The 

Golf Channel, Bloomberg, CBS, FOX, Telemundo, Univision USA Network, HBO, and 

The Weather Channel.

Satellite Technology Systems, Inc. is recognized throughout the country for its timely, 

courteous, and professional service standards. Its highly qualified uplink operators are 

a source of tremendous pride. 

Charles Spoto founded STS in 1988 as a commercial satellite communications company. 

He also has experience with some of the most advanced RC aircraft in the world. 

Including flying the RC Twin Jet Turbine, SU 27 Flanker.

STS customers operate in a highly competitive environment, in which use of the latest 

video capture, digital signal processing, and wireless technologies are crucial for 

success. They recognize that drone-captured video imagery represents a new tool that 

must be added to their capabilities. Live downlink of video imagery and live 

transmission to the customer is a capability much desired. 

Few firms in the industry are as well-equipped as STS to combine drone capability with 

the requisite wireless technologies. When an STS truck is in the field on assignment, for 

example, drone video can be downlinked to the truck through a short-range wireless 

connection from which the truck can feed it into the customer’s infrastructure.

Pending promulgation of the FAA's final rule for small unmanned aircraft systems, STS 

needs to remain competitive by demonstrating to its customers the capabilities of sUAS 

when they are tied into existing production and communication infrastructors. This 

must be done in a real-world commercial setting, in which the drone imagery is 

intended for integration into the finished package. 
5

The Petitioner has been advised by counsel that this is not now permissible unless he 

obtains special permission from the FAA. A top priority for television networks stations 

to find drone operators that understand television workflow and can integrate their 

work product into it. STS is far better positioned than the usual applicant for a section 

333 exemption to meet this need. Working with its customers in a commercial context, 

STS can help the industry refine the specific technology applications that will provide 

the best support for news gathering and dissemination.

STS’s competition comprises not only the many drone operators who have obtained

section 333 exemptions, many of which will engage in aerial photography, and some of 

whom may seek to tap the television market; it also comprises many other operators 

who do not have section 333 exceptions or other approvals. While the FAA has said that 

purchase of imagery captured by amateurs does not put the stations and the networks 

themselves in a position of violating the law, this phenomenon nevertheless will

encourage market entry by individuals and firms operating outside any regulatory 

framework. If STS is shut out of this market because of its commitment to follow the 

law, while this irregular competition flourishes, the result will be bad for both 

journalism and aviation safety.

Petitioner also notes and has read the congressional mandate in sections 332 and 333 of 

the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to 

accommodate the economic and societal benefits that can result from widespread 

deployment of sUAS technology. Accordingly, Petitioner applies for authorization 

under the Federal Aviation Act, and the FARs rules to undertake the following activities 

for commercial purposes. Unless the Petition is granted, Petitioner will be at a 

significant competitive advantage if it, as it prefers, complies with FAA policy.

Vehicles

The Petitioner will fly the following sUAS:

 DJI Spreading Wings S1000-plus

 DJI Inspire-1

 Drone Aviation Corp WATT-200 Tethered Drone

The DJI vehicles have built in capability to limit the height they fly above the ground, to 

limit the radius of the distance the fly from the operator, and to exclude them from class 
6

B, C, and D airspace. The vehicles also have the built-in capability to return to the 

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

exceed any of the height, radius, or airspace limitations programmed into it.

The FAA has granted section 333 exemptions for both of these vehicles, in First Flight 

Photography, LLC, Exemption No. 11260, Regulatory Docket No. FAA−2014−0736 (as 

amended 14 April 2015) (DJI Spreading Wings S1000; DJI Inspire).

Petitioner will equip its free-flight vehicles with redundant recovery parachute systems 

controlled by two different radio links. The recovery chute system will ensure a rate a 

descent of fifteen feet per second in the event of a total drone failure. Touchdown with 

the recovery chute system will provide a soft landing on any surface the vehicle

contacts.

The WATT-200 vehicle is tethered and thus presents none of the risks associated with 

free flight.

Appendix 2 provides specifications for the vehicles.

Flight profiles

The Petitioner will program its aircraft so that they will not fly above 400 feet above 

ground level, or more than 1500 feet away from the operator. The operator will 

carefully preflight the vehicle before each mission to assure that its compass and GPS 

system are properly calibrated and that the return-to-home feature, altitude, and radius 

limitations work.

The operator will operate its vehicles on aerial data collection, aerial photography and 

videography, news gathering, training, and demonstration missions only under the 

following circumstances:

1. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). 

In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

2. The UA will be operated at an altitude of no more than 400 feet above ground 

level (AGL). Altitude will be reported in feet AGL.

3. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. 

The PIC will use human vision unaided by any device other than corrective 
7

lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. 

driver’s license.

4. All operations will utilize a visual observer (VO). The UA will 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 requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC will be able to communicate orally 

at all times; electronic messaging or texting will not occur during flight 

operations. The PIC will be designated before the flight and will not transfer his 

or her designation for the duration of the flight. The PIC will ensure that the VO 

can perform the duties required of the VO.

5. The requested exemption and all documents needed to operate the UAS and 

conduct its operations in accordance with the conditions and limitations of the 

requested grant of exemption, are hereinafter referred to as the operating 

documents. The operating documents will be accessible during UAS operations 

and will be 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, the conditions and limitations 

will take precedence and be followed. Otherwise, the operator will follow the 

procedures as outlined in its operating documents. The operator may update or 

revise its operating documents, and track such revisions and present updated 

and revised documents to the Administrator or any law enforcement official 

upon request. 

6. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted the requested exemption, the operator will petition 

for an amendment to its grant of exemption. 

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

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

will undergo a functional test flight prior to conducting further operations under 

the requested exemption. Functional test flights will only be conducted by a PIC 

with a VO and will remain at least 500 feet from other people. The functional test 

flight will be conducted in such a manner so as not to pose an undue hazard to 

persons and property.

8. The operator is will maintain and inspect the UAS to ensure that it is in a 

condition for safe operation.
8

9. Prior to each flight, the PIC will conduct a pre-flight inspection and determine 

the UAS is in a condition for safe flight. The pre-flight inspection will account for 

all potential discrepancies, e.g. inoperable components, items, or equipment. If 

the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft will not be operated until the necessary maintenance has been performed 

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

10. The operator will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

11. Each UAS operated under the requested exemption will comply with all 

manufacturer safety bulletins.

12. All PICs will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will also hold a current FAA airman medical 

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

Columbia, Puerto Rico, a territory, a possession, or the Federal government. The 

PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate.

13. The operator will not permit any PIC to operate unless the PIC demonstrates the 

ability to operate the UAS safely 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 will be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC’s ability safely to operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption will occur under the 

terms of the requested exemption. Training operations will only be conducted 

during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC will operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

14. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

Flights under special visual flight rules (SVFR) are not authorized.
9

15. The UA will 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 an ARP, the center of the airport symbol 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 agreement with the airport management 

will be made available to the Administrator or any law enforcement official upon 

request.

16. The UA will 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.

17. If the UAS loses communications or loses its GPS signal, the operator will cause 

the UA to return to a predetermined location within the private or controlledaccess property.

18. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies.

19. The PIC will not begin 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 with the reserve 

power recommended by the manufacturer if greater.

20. All operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder will apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the COA attached to the 

requested exemption.

21. All aircraft operated in accordance with this exemption will be identified by 

serial number, registered in accordance with 14 CFR part 47, and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart 

C. Markings will be as large as practicable.

22. 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 will be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating.

23. These documents will be made available to the Administrator or any law 

enforcement official upon request.
10

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

activities at all times.

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

26. All Flight operations will be conducted at least 500 feet from all nonparticipating 

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 will 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 will cease 

immediately in a manner ensuring 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.

27. The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under the requested exemption.

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

boundaries of the operational area as defined by the applicable COA will be 

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

Accidents will be reported to the National Transportation Safety Board (NTSB) 

according to instructions contained on the NTSB Web site: www.ntsb.gov. 

29. Further to protect the interests of the operators of other aircraft and of persons 

and property on the ground, Petitioner will maintain liability insurance coverage 

for all of its sUAS operations.

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the 

Reform Act relating to size, weight, speed, operating capabilities, proximity to airports 

and populated areas and operation within visual line of sight and national security. The 

Petition justifies grant of the requested exemptions allow the Petitioner to obtain aerial 

photography with its sUAS.

Granting the petition would be in the public interest because:
11

1. The Congress of the United States has determined that early accommodation of 

sUAS into the National Airspace System advances the public interest. The 

Committee Report leading the House to adopted H.R. 658 said: 

"The successful integration of unmanned aircraft systems (UAS) into the 

National Airspace System (NAS) can support more than 23,000 high-paying jobs 

in the United States. . . . The absence of a plan to integrate UASs into the NAS is a 

barrier to such job creation . . . ."1

Granting the Petition represents a step toward such integration, in the absence of 

a comprehensive regulatory regime for sUAS, and thus would serve the 

Congressional goal and the public interest.

2. Granting the Petition would facilitate the creation, display, and public 

distribution of art, long recognized as advancing the public interest. They are at 

the core of the activities that the First Amendment to the United States 

Constitution seeks to promote and to protect from governmental restrictions.

Creative photography and video art fall well within the First Amendment’s 

protections. "Entertainment, as well as political and ideological speech, is 

protected; motion pictures, programs broadcast by radio and television, and live 

entertainment, such as musical and dramatic works fall within the First 

Amendment guarantee. "2

 

1

 H. R. Rep. 112-29 on H.R. 658, 112th Cong., 1st Sess. at 116. The House-Senate

Conference Committee on the FAA Modernization and Reform Act of 2012 

recommended amendments to H.R. 658 in lieu of amendments adopted by the Senate. 

Conference Report to Accompany H.R. 658, H.R. Rep. 112-381, 112th Cong., 2d Sess., at 

p. 1 (Feb. 1, 2012).

2

 Schad v. Borough of Mount Ephraim, 452 U.S. 61, 65 (1981); White v. City of Sparks, 

500 F.3d 953, 956 (9th Cir. 2007) (holding that self-expression through painting is 

protected by the First Amendment; rejecting city's argument that protection requires a 

political message); Hoffman v. Capital Cities/ABC, Inc., 255 F.3d 1180 (9th Cir. 2001) 

(reversing judgment for plaintiff; use of photograph of actor as part of fashion article 

was protected by First Amendment despite commercial purpose); Edme v. Internet 

Brands, Inc., 968 F. Supp.2d 519, 529-530 (E.D. N.Y. 2013) (denying summary judgment 

on statutory right of publicity claim; "newsworthy" broadly construed to allow public to 
12

3. Granting the Petition would enable new forms of news coverage, enabling the 

public to know about and to understand newsworthy events, an activity

similarly within the core of First Amendment protections. 3

4. Granting the petition would enable Petitioner to demonstrate the commercial 

viability of creating art and gathering news with new aeronautical technology 

Commercial creative art is protected as well as non-commercial art.4 The Patents 

and Copyrights Clause of the United States Constitution and the copyright 

statute’s protection of visual art and audiovisual works embody the proposition 

that more creative effort with respect to these kinds of work will be exerted when 

the creators are allowed to be paid for their works, thus increasing the 

production of artistic works. 

Granting the petition will allow the petitioner to respond to economic incentives 

to increase its creative production. The result will be an increase in the stock of 

artistic photography, including video for public enjoyment. 

A significant part of the Petitioner’s activities involve capturing and 

disseminating visual representations of newsworthy events. Receiving 

compensation for these newsgathering activities using traditional technologies 

incentivizes Petitioner, resulting in greater output of news. The new technologies 

embodied in sUAS enable different perspectives on the news not easily 

obtainable by traditional means. Allowing Petitioner to be compensated for 

using the new technologies will provide an incentive for it to intensify its

collection and dissemination efforts.

 

benefit from visual images); Hill v. Public Advocate of the United States, ___ F. Supp.2d 

___ , Civil Action No. 12–cv–02550–WYD–KMT, 2014 WL 1293524 (D. Colo. Mar. 31, 

2014) (holding that photograph of gay marriage was within First Amendment 

protection despite its use for political purposes; discussing how access to photograph 

advances the public interest).

3

 Glik v. Cunniffe, 655 F.3d 78, 83-84 (1st Cir. 2011) (citing cases holding that news 

photography is will with First Amendment protection and that protection extends to 

ordinary citizens as well as reporters; affirming denial of immunity to police officers in 

section 1983 suit by citizen who was arrested for using cellphone camera to photograph 

arrest).

4

 White, 500 F.3d at 956-957.
13

The rules from which Petitioner seeks exemption artificially and irrationally limit 

the effective use of new technologies to enhance news gathering, thereby 

subverting the public interest.

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging 

new aviation technologies advances the public interest. The FAA itself has 

recognized the public interest in its role of "Encouraging and developing civil 

aeronautics, including new aviation technology."5 Granting the Petition will 

enhance FAA fulfillment of that commitment, thereby serving the public interest. 

Air commerce flourishes in the United States because of the rapid pace of 

innovation in aeronautical and associated technologies, followed by their 

commercialization and their introduction of the marketplace. The drone 

technology that the Petitioner uses exemplifies the latest innovative leap forward 

in aeronautical technology. Preventing it from using this in air commerce 

subverts achievement of the goal.

6. Granting the Petition will fulfill the Congressional determination that integrating 

sUAS technology into the NAS serves the public interest. Section 330 of the FAA 

Modernization and Reform Act of 2012, specifically recognizes the advantages to 

air commerce obtainable from the deployment of sUAS technologies. It 

mandated several steps by the FAA to accelerate the availability of these 

technologies in the National Airspace System, thereby representing a 

congressional determination that the public interest is served by making these 

technologies more widely available at the earliest practicable date. The Petition 

represents a way for the FAA to move incrementally, while still satisfying its 

congressional mandate and meeting its obligation to enhance the public interest 

by making new technologies available by allowing the use of sUAS technologies 

in a manner that protects the public and the rest of the aviation community from 

significant risk.

The commercial activities by Petitioner proposed in the Petition represent 

contributions to new forms of air commerce, thereby fulfilling the FAA’s 

statutory mandate under the 2012 Act.

 

5

 FAA, Safety: The Foundation of Everything We Do, 

http://www.faa.gov/about/safety_efficiency/.
14

7. Granting the Petition will enhance aviation safety, thereby advancing the public 

interest. The Petitioner has committed itself in the Petition to safety practices that 

reduce or eliminate hazards to aircraft in the National Airspace System and to 

persons and property on the ground. Many others are flying sUAS without 

regard to these hazards. Granting the Petition will offer the Petitioner up as an 

example of how the FAA is willing to accommodate the new technology when it 

is constrained by appropriate limitations to enhance safety. It will also allow the 

Petitioner to be a role model for safe commercial sUAS operations.

Users of the National Airspace System are confronted by mushrooming threats 

from sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some 

flexibility to accommodate lawful and safe operation of sUAS for legitimate 

commercial purposes, the level of defiance will increase, intensifying the hazards 

to manned aircraft and to persons and property on the ground.

The Petition to use a UAS for aerial data collection and its proposed limitations are

similar in all material respects to those approved by the FAA in Grants of Exemption 

Nos. 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), 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642) and 

11310 to Colin Hinkle (see Docket No. FAA-2014-0608). In those grants the FAA found 

that the enhanced safety achieved using an unmanned aircraft (UA) with the 

specifications described by the Petitioner 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.

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, 

and 11310 also apply to the situation presented by this Petition.

Respectfully submitted,
15

Henry H. Perritt, Jr.

Counsel for 

Satellite Technology Systems, Inc.
16

Appendix 1

FAR section Subject Justification

14 CFR § 45.23(b) Requirement to display 

registration number on 

vehicle

Insufficient space on 

vehicle

14 CFR Part 21 Aircraft certification 

requirements and 

procedures

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 61.3 Requirement for pilot 

certificate

Part 61 requirements 

designed for manned 

aircraft, not sUAS; 

petition describes 

training for sUAS 

operator

14 CFR § 91.7 (a) Airworthiness 

requirement

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual 

to be available in the 

cockpit

No one aboard to read 

manual

14 CFR § 91.103(b) Requirement for crew 

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction

No one aboard to 

operate controls

14 CFR § 91.119 Minimum altitudes for 

safe flight

Safety requires 

operation below these 

altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use 

fuel

14 CFR § 91.203 (a) & (b) Requirement for 

registration and 

airworthiness 

certificates to be 

onboard

No one aboard to read 

certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 
17

requirement instruments

14 CFR § 91.215 Transponder 

requirement

Vehicle has insufficient 

useful load; will be 

operated below ATC 

radar coverage

14 CFR § 91.405 (a) Inspection requirements Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.407(a) (1) Inspection approval 

requirements

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.409 (a) (2) Airworthiness 

inspection

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.417 (a) & (b) Maintenance records 

requirements

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS
18

Appendix 2

Vehicle specifications

DJI Inspire 1

Aircraft

Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Gimbal

Model

ZENMUSE X3
19

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

FOV (Field Of View)

94°

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 shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60
20

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

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° to 40° C

Remote Controller

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Charger

Model

A14-100P1A

Voltage

26.3 V
21

Rated Power

100 W

Battery (Standard)

Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range -10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional)

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range -10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W
22

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 8.0 or later

Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + C

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iP

* Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3

*Support for additional Android devices available as testing and development cont

DJI Spreading Wings S1000

Frame

Diagonal Wheelbase

1045mm

Frame Arm Length

386mm

Frame Arm Weight

(Including Motor, ESC, Propeller )

325g

Center Frame Diameter

337.5mm

Center Frame Weight (With Landing Gear Mounting Base, Servos)

1330g

Landing Gear Size

460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm)

Motor

Stator Size

41×14mm

KV

400rpm/V

Max Power

500W

Weight(With Cooling Fan)

158g

ESC

Working Current

40A

Working Voltage
23

6S LiPo

Signal Frequency

30Hz ~ 450Hz

Drive PWM Frequency

8KHz

Weight(With Radiators)

35g

Foldable Propeller (1552/1552R)

Material

High strength performance engineered plastics

Size

15×5.2inch

Weight

13g

Flight Parameters

Takeoff Weight

6.0Kg ~ 11.0Kg

Total Weight

4.2Kg

Power Battery

LiPo (6S、10000mAh~20000mAh、15C(Min))

Max Power Consumption

4000W

Hover Power Consumption

1500W (@9.5Kg Takeoff Weight)

Hover Time

15min (@15000mAh & 9.5Kg Takeoff Weight)

Working Environment Temperature

-10 °C ~ +40 °C

Gain Value Settings

For A2 Flight Controller

Basic: Roll 120%, Pitch 120%, Yaw 120%

Attitude: Roll 170%, Pitch 170%, Vertical 120%

For WooKong-M Flight Controller

Basic: Roll 180%, Pitch 180%, Yaw 120%

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

Drone Aviation Corp. WATT-200 Tethered Drone

 Multi-rotor Octo-X Configuration

 All Electric Propulsion

 10 pound payload up to 300 feet

 8+ hours flight time from ground power

 Standard 150 ft. / 50 meter operating altitude AGL

 Optional 300 ft. / 150 meter operating altitude

 Power, data and telemetry over Kevlar armored tether

 Ground support equipment with uninterrupted power
24

 Tension Control Winch System

 Armored tether

 On-board redundant power-banks

 On-board battery back-up

 Automatic telemetry alerts

 Auto recovery/retrieve functionality 

 Simplified Ground Control Station software

 Fault-tolerant and redundant safety systems