1 

## Henry H. Perritt, Jr. Attorney at Law

1131 Carol Lane Glencoe, IL 60022 hperritt@gmail.com (312) 504

- 5001

1 1 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 H uerta :

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 li sted Federal Aviation Regulations (“FARs”) to allow it to opera te small Unmanned Aircraft Sy stem s (“sUAS”) for aerial data collection

, under the conditions and
limitations set forth in this Petition.

T he 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 helicopter s and a irplanes . 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 Refor m 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 § 91.2153

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.

Th e Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the
Reform Act , which directs the Secretary of T ransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required unde r Section 332 of the Reform Act. In making this determination, the Administrator m ust 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 proximi ty to airports and populated areas; and

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

Reform Act § 333 (a).

I f the Administrator determines that such vehicles “may operate safely in the national airspace system, the Secretary shall e stablish 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 th e 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 th e 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 Te chnology 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 prod uction and transmission facilities through satellite links . Based in the Chicago suburbs, STS has developed premier satellite ku uplink truck s 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 includ e 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 prof essional 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, an d 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 down link of video imagery and live transmission to the customer is a capability much desi red.

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 downlink ed to the truck through a sho rt

- 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 system s, 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
obtain s 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 position ed than the usual app licant for a section 333 exemption to meet this ne ed. Working with its customers i n a commercial context, STS can help the industry refine the specific technology applications that will provide the best support for news gathering a nd dissemination.

STS’s competition comprises not only the many drone operators who have obtained section 333 exemption s, many of which will engage in aeria l photography, and some of whom may se ek to tap the television market; i t also comprises many other operators
who do not have section 3 33 exceptions or other approvals. While the FAA has said that purchase of imagery captured by amateur s does not put the st ations and the net works
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 rea d the congressional mandate in section s 332 and 333 of
the FA A Revitalization and Reform Act of 2012 that the FA A move quickly to
accommodate the economic and societal benefits that can result from widespread deployment of sUAS technology. A ccordingly, Pet itioner applies for authorization
under the Federal Aviation Act , and the FAR s 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 prefe rs, complies with FAA policy.



### Vehicle s
The Petitioner will fly the following sUAS:

 DJI Spreading Wings S1000

- plus

 DJI Inspire

- 1

 Drone Aviation Corp WATT

- 200 Tethered Drone

T he DJI vehicle s 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 class6

B, C, and D airspace. T he vehicle s also have the built

- in capability to return to the launching point if the wireless control link is interrupted or if t he 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, Regulato ry 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 wil l e nsure a rate a
descent of fifteen feet per second in the e vent 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 abo ve 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 c ompass 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 b e 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 corrective7

lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S.
driver’s license.

4. All operation s 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 wil l 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 en sure 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 hereinafte r 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 th e 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 operatin g 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,

wi ll 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 insp ection 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 o f 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 l ife 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 c onsistent 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 UA S 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 experience

building flights, all persons not ess ential 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.
A ll 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 pre determined location within the private or con trolled

access 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 accordanc e 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 r equired 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 un der 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/controlle r 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 th e requested exemption.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by t he 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 op erations 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 in to 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 c reation, 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. Interne t 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 to12

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 d emonstrate 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 copyrig ht statute’s protection of visual art and audiovisual works embod y 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 art istic 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 p art 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 outpu t 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

co llection 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 advanc es 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 techn ologies, 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 technolog y . 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 recogni zes 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 determin ation 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 Petition er 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 h as 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 Petiti on 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 ope rations.

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, th e 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 approv ed 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. FA A−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, r ather 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 g ranting 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

- s helf 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 requi rements 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 instrument s No one aboard to read17 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 sUAS18 

## 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 X319 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: 1920x1080p24/25/30/48/50/6020 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 V21 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 W22

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 + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, and iPad mini 3 Wi

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. * Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini *Support for additional Android devices available as testing and develo pment continues



## 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 Voltage23 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 Kevl ar armored tether

 Ground support equipment with uninterrupted power24

 Tension Control Winch System

 Armored tether

 O n

- board redundant power

- banks

 O n

- board battery back

- up

 A utomatic telemetry alerts

 A uto recovery/retrieve functionality

 Simplified Ground Control Station software

 Fault

- tolerant and redundant safety systems