US DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

IN THE MATTER OF THE PETITION FOR SECTION 333 EXEMPTION OF:

STRATOSFOTO

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF

THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING

COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS PURSUANT TO

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on August 6, 2015

Stratosfoto

25 Ripplewood Lane

Palm Coast, FL 32164

www.stratosfoto.com

386.793.4251

Sole Proprietor: Charles C. Smith
TABLE OF CONTENTS

Glossary of Abbreviations 2

Summary 3

Introduction and Interests of the Petitioner 3

Background 3

Basis for Petition 3

Name and Address of Petitioner 5

The Specific Sections of 14 C.F.R. from which Stratosfoto Seeks Exemption 5

The Extent of Relief Stratosfoto Seeks and the Reason Stratosfoto Seeks the Relief 7

The Reason Why Granting the Stratosfoto Exemption Request is in the Public Interest 9

The Reasons Why Granting the Exemption Would Not Adversely Affect Safety 11

Summary that can be Published in the Federal Register 19

Additional View or Arguments to Support the Stratosfoto Exemption Request 20

Conclusion 20

Attachments 21

Pre­Flight Checklist 21

Flight Check List 21

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GLOSSARY OF ABBREVIATIONS

(AGL) Above Ground Level

(AOI) Area of Interest

(ATC) Air Traffic Control

(ATO) Air Traffic Organization

(AV) Aerial Vehicle

(CFR) Code of Federal Regulations

(COA) Certificate of Authorization

(FAA) Federal Aviation Administration

(FAR) Federal Aviation Regulation

(GCS) Ground Control Station

(GPS) Global Positioning System

(LOL) Loss of Link

(NAS) National Airspace System

(PIC) Pilot In Command

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

(VO) Visual Observer

(SOP) Standard Operating Procedures

(UA) Unmanned Aircraft

(UAS) Unmanned Aircraft System

(VFR) Visual Flight Rules

(VLOS) Visual Line of Site

(VMC) Visual Meteorological Conditions

(VTOL) Vertical Takeoff and Landing

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SUMMARY

My sole proprietorship, Stratosfoto, seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit me to operate an

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and

photography for hire.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Stratosfoto, a Sole Proprietorship, provide clients with expertise and knowledge in aerial

technologies and solutions to increase efficiency, productivity and effectiveness. I also provide

clients with the highest quality digital content for use in their commercial, personal, and

non­profit multimedia projects. I have over 3 years of experience flying and building advanced

aerial imaging systems and am an active student pilot with 38 hours in A Cessna 172 with 2

completed solos. I have also already taken, and passed, the written exams for Private, and

Sport, Pilot. My objective in aerial video and photography operations is to provide high quality

aerial imaging for a variety of commercial, public, and residential uses, specifically targeting:

● Aerial Real Estate Promotion

● Aerial Construction Monitoring

● Aerial Damage Assessment and Disaster Recovery Support

● Aerial Property Inspections for Forensic Engineers

● Utility & Infrastructure Inspections

BACKGROUND

Stratosfoto seeks a FAR Section 333 exemption to operate the 3DR SOLO, DJI 450 and Tarot

680Pro systems for compensation or hire within the NAS. All three UAS weigh under 10

pounds and are classified as vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with

a Ground Control Station (GCS) utilizing electronic tablet. The DJI Phantom 3 has a maximum

gross weight of approximately 1280 gram, while having a length of 16 inches width of 16

inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom

3 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric

motors. The DJI Phantom 3 UAs that will be operated by me will be registered in accordance

with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration

Marking.

BASIS FOR PETITION

Petitioner, Charles C. Smith from Stratosfoto, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the

Administrator to commercially operate the DJI Phantom 3 UASs in the National Airspace

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System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b),

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

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

unmanned aircraft and its operation, I will meet the conditions of FMRA Section 333 and

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. Accordingly, Stratosfoto requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate. I submit that the

requested relief is proper since an equivalent level of safety will be ensured. I will use my

experience to perform maintenance, alterations, or preventive maintenance on the UASs using

the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and Instruction Manuals). Furthermore, I will document and maintain all

maintenance records for all 3 UAS, as well as maintain a cloud­based flight log system to

document all flights and their duration.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command , is requested by me to the extent necessary to allow a Pilot

in Command (PIC) by meeting minimum flight hour and currency requirements, that the PIC is

able to safely operate the SOLO, DJI 450 and Tarot 680Pro consistent with this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

I seek relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the

3 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. As such, I submit that I will ensure that the 3 UASs are in an airworthy condition,

prior to every flight, by determining that the UASs are in compliance with the operating

documents (i.e., Monthly Maintenance Log, and Instruction Manuals), and that the aircraft are

in a condition for safe flight.

I also seek an exemption from the requirements of Section 91.121, entitled Altimeter Settings,

as the UASs will not have a typical barometric altimeter onboard. However, altitude information

of all 3 UAS will be provided in real­time to the PIC via Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlinks from the UA to the

GCS for active monitoring of the flight path. This altitude information, combined with my

operation of the 3DR Solo, DJI 450 and Tarot 680Pro UAS within visual line of sight (VLOS), at

or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, I seek an exemption from the requirements of Section 91.151(b), entitled Fuel

requirements for flight in VFR conditions . I submit that safety will not be affected by operation

of the UAS during daylight hours in visual meteorological conditions (VMC) under visual flight

rules (VFR), with enough battery power to fly for a total duration of approximately 15 minutes to

the first point of intended landing and, assuming normal cruising speed, to fly after that for at

least 4.5 minutes.

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In accordance with 14 C.F.R. § 11.81, Stratosfoto provides the following

information in support of its petition for exemption:

Name And Address Of The Petitioner

The name and address of the Petitioner and point of contact is:

Charles C. Smith, Owner/ Operator

Stratosfoto

25 Ripplewood Lane

Palm Coast, FL 32164

(386) 793­4251

stratosfoto@cfl.rr.com

The Specific Sections Of 14 C.F.R. from Which Stratosfoto Seeks Exemption

1. Stratosfoto Seeks Exemption From The Requirements Of Section 61.113(a) And (b).5

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections

(a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an

aircraft that is carrying passengers or property for compensation or hire; nor may that person,

for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if—

1. The flight is only incidental to that business or employment; and

2. The aircraft does not carry passengers or property for compensation or hire.

2. Stratosfoto Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Stratosfoto Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating below 18,000 feet MSL, to:

1. The current reported altimeter setting of a station along the route and within 100

nautical miles of the aircraft;

2. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station; or

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3. In the case of an aircraft not equipped with a radio, the elevation of the departure airport

or an appropriate altimeter setting available before departure.

4. Stratosfoto Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Stratosfoto Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405,

entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

Shall have that aircraft inspected as prescribed in subpart E of this part and shall between

required inspections, except as provided in paragraph (c) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter.

6. Stratosfoto Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section

91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration,

subsection (a)(1), states the following:

No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless it has been approved for return to service by a

person authorized under §43.7 of this chapter.

7. Stratosfoto Seeks Exemption From The Requirements Of Sections 91.409(a)(1) and

91.409(a)(2).Section 91.409, entitled Inspections, subsection (a), states the following:

Except as provided in paragraph (c) of this section, no person may operate an aircraft unless,

within the preceding 12 calendar months, it has had:

1. An annual inspection in accordance with part 43 of this chapter and has been approved

for return to service by a person authorized by § 43.7 of this chapter; or

2. An inspection for the issuance of an airworthiness certificate in accordance with part 21

of this chapter.

8. I Seek Exemption From The Requirements Of Sections 91.417(a) And

91.417(b) Section 91.417, entitled Maintenance records , subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered

owner or operator shall keep the following records for the periods specified in paragraph (b) of

this section:

1. Records of the maintenance, preventive maintenance, and alteration and

2. Records of the 100 hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and each engine,

propeller, rotor, and appliance of an aircraft. The records must include:

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a. A description (or reference to data acceptable to the Administrator) of the work

performed; and

b. The date of completion of the work performed; and

c. The signature, and certificate number of the person approving the aircraft for

return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life limited parts of each airframe, engine, propeller, rotor, and

appliance

(iii) The time since last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection

required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives

including, for each, the method of compliance, the AD or safety directive number and revision

date. If the AD or safety directive involves recurring action, the time and date when the next

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the

airframe and currently installed engines, rotors, propellers, and appliances.

The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after the

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter

shall be retained until the defects are repaired and the aircraft is approved for return to service.

The Extent Of Relief I Seek And The Reason I Seek The Relief.

1. Extent Of Relief Stratosfoto Seeks And The Reason Stratosfoto Seeks Relief From Section

61.113(a) And (b) Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations:

Pilot in command, is requested to the extent necessary to allow a PIC holding a

private pilot license or higher level certificate, as well as a current and valid airman medical

certificate, and who has met certain flight hour and currency requirements, to conduct the

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if:

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(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, I submit that an equivalent level of safety will be maintained

because no PIC will be allowed to operate the UAS except for Charles C. Smith.

Further, I submit that all flights of the 3DR Solo and Tarot 680Pro UASs, conducted by the PIC

pursuant to the grant of this Petition:

(1) will be incidental to Stratosfoto and

(2) will not carry passengers or property for compensation or hire.

2. Extent Of I Seek And The Reason I Seek Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow Stratosfoto to determine that the UASs are in airworthy condition prior to

every flight by ensuring that the UAS is in compliance with the operating documents (i.e.,

Operations Manual, Monthly Maintenance Log, and Instruction Manual).

I seek the requested relief because the 3DR Solo and Tarot 680Pro UASs do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, I will

ensure that the UASs are in airworthy condition based upon its compliance with the operating

documents (i.e., Monthly Maintenance Log, and Instruction Manual) prior to every flight, and

further, determine that the aircraft are in condition for safe flight, as stated in the conditions and

limitations below.

3. Extent Of Relief I Seek And The Reason I Seek Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the UASs, which utilize a barometric pressure sensor, GPS equipment, and a

radio communications telemetry data link to downlink altitude information from the UA to the

PIC at the ground control station (GCS). Since the FAA requires that any altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), I seek the requested relief because the 3DR Solo and Tarot 680Pro altimeters may be

set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude,

before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is

sought to the extent necessary to comply with the applicable conditions and limitations stated

below. As more fully set forth herein, an equivalent level of safety will be maintained since the

UASs are equipped with a barometric pressure sensor and GPS equipment, which

automatically ensures that a ground level pressure setting will be established prior to each

flight, and provides the PIC with altitude information of the UA on the heads­up display of the

GCS.

4. Extent Of Relief I Seek And The Reason I Seek Relief From Section 91.151(b).

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Relief from Section 91.151(b) entitled Fuel Requirements for Flight in VFR Conditions, is

requested to the extent required to allow flights of the battery powered UAVs during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total

duration of 15 minutes to the first point of intended landing and, assuming normal cruising

speed, to fly after that for at least 4.5 minutes. I seek the requested relief because without an

exemption from Section 91.151(b), the flight time duration of the battery powered UAVs will

severely constrain the practicality of any aerial video or still photo flight operations that I

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the UASs, the operating

documents, and my proposed operating limitations, ensure that I will safely operate the battery

powered UAVs during daylight hours in visual meteorological conditions (VMC), under visual

flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the

first point of intended landing and, assuming normal cruising speed, to fly after that for at least

4.5 minutes.

5. Extent Of Relief I Seek And The Reason I Seek Relief From Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to

aircraft with an airworthiness certificate, I request relief from these Sections because the UASs

do not require airworthiness certificates. As set forth more fully below, the 3DR Solo and Tarot

680Pro meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly I will perform maintenance, alterations, or preventive maintenance on

the UASs using the methods, techniques, and practices prescribed in the UAS operating

documents (i.e., the Operations Manual, Monthly Maintenance Log, and Instruction Manual).

Furthermore, I will document and maintain all maintenance records for the UASs.

The Reasons Why Granting Stratosfoto’s Exemption Request Is In The Public

Interest; That Is, How It Would Benefit The Public As A Whole:

Granting the present Petition will further the public interest by allowing Stratosfoto to safely,

efficiently, and economically perform aerial video and photography for real estate

professionals, construction sites, insurance and utility companies over certain areas of the

United States.

Additionally, use of UASs will decrease congestion of the NAS, reduce pollution, and provide

significant benefits to the economy. Notably, the benefits of my proposed operation of the

UASs will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The UAVs are battery powered and serve as a safe, efficient, and economical alternative to the

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3DR

and Tarot 680Pro UAS would reduce the amount of manned aircraft in the NAS, reduce noise

and air pollution, as well as increase the safety of life and property in the air and on the ground.

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Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing aircraft will be reduced. The UASs do not

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial

video and photography missions would result in fewer aircraft that must be handled by air traffic

control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The UASs.

Conducting aerial acquisitions with the 3DR Solo and Tarot 680Pro UASs, instead of manned

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerial video and still photography flight operations. By using battery

power and electric motors, the UASs produce no air pollution, and is the most viable

environmentally conscious alternative to the cabin class, six cylinder internal combustion

engine aircraft that are typically utilized for aerial video and photography, while burning

approximately 2030 gallons per hour of leaded aviation fuel.

Additionally, the UASs, while reducing the carbon footprint of aerial acquisitions, also eliminate

noise pollution, as they are propelled by battery powered electric motors rather than an internal

combustion engine. By using the UASs to perform aerial acquisitions, the substantial risk to life

and property in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the UASs (weighing approximately 5

pounds, and with no fuel on board), has less physical potential for collateral damage to life and

property on the ground, and in the air, compared to the manned aircraft that typically conduct

similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42

feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With Proposed UASs Will Benefit The

Economy.

In addition to being safe and efficient, the 3DR Solo and Tarot 680Pro UASs are also an

economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the UASs will allow US­based companies, like mine, to remain competitive and

contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and

the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation

fuels, U.S. owned and operated companies must adopt new and alternative technology in order

to remain competitive. Operating the battery powered UASs is one such technology that not

only allows companies greater operational flexibility compared to manned aircraft, but provides

such flexibility without the high operational cost of a traditional manned aircraft.

By operating the UASs, companies such as Stratosfoto, can remain competitive and profitable,

and therefore, one day provide greater job stability to employees and contractors, which will

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S.

companies, through commercial use of UASs, provides a stable workforce that increases

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consumer spending; improves local, state, and federal tax revenues; and allows companies to

invest in research and development in order to remain competitive both in the United States

and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, I proposed operation of the UASs will not implicate any privacy issues. Specifically,

the UASs will be operated only in compliance with operating documents (i.e., the Operations

Manual, Monthly Maintenance Log, and Instruction Manuals) which requires property owner

involvement as well as local law enforcement notification, and in accordance with the Federal

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, or How

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By

The Rule From Which Stratosfoto Seeks Exemption.

1. Reasons Why The DJI Phantom 3 UAs Meet The Conditions Of The FAA

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

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

unmanned aircraft and its operation, my operation of the DJI Phantom 3 UASs meet the

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without

airworthiness certification and sets forth requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security. Specifically, FMRA Section 333 states the following, in part:

(a) In General and Notwithstanding any other requirement of this subtitle, and not later than

180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine if certain unmanned aircraft systems may operate safely in the national airspace

system before completion of the plan and rulemaking required by section 332 of this Act or the

guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.In making the determination under

subsection (a), the Secretary shall determine, at a minimum:

● Which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and populated areas, and

operation within visual line of sight do not create a hazard to users of the national airspace

system or the public or pose a threat to national security; and

● Whether a certificate of waiver, certificate of authorization, or airworthiness certification

under section 44704 of title 49, United States Code, is required for the operation of

unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

If the Secretary determines under this section that certain unmanned aircraft systems may

operate safely in the national airspace system, the Secretary shall establish requirements for

the safe operation of such aircraft systems in the national airspace system.

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In seeking this exemption, I submit that the 3DR Solol and Tarot 680Pro UASs can operate

safely in the NAS pursuant to FMRA Section 333, as demonstrated by:

(a) The characteristics of the UASs;

(b) The pilot certification requirement; and

(c) The specific operating limitations of the UASs.

The Specifications Of The 3DR Solo and Tarot 680Pro Demonstrate Its Safe Characteristics.

The UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat

to national security considering its size, weight, speed, and operational capability.

The technical specifications of the UASs are set forth in the Specifications and Data Sheet and

include:

● Autonomous Flight And Navigation Modes that Enable The UASs To Remain Within A

Defined Operational Area.

● UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of

Loss Of The Control Link or Navigation.

When the Control Link is lost, the UAs will remain stationary, in­flight, for 3 seconds or more. If,

after 3 seconds, the UAs do not reacquire control link data from the GCS, the UAs will assume

that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via

GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the the 3DR Solo flight controller (Pixhawk)

and Tarot 680Pro flight controller (Naza V2) can be found in the User Manuals.

Flights of the UASs Will Be Conducted Pursuant To Specific Operating Limitations

In seeking this exemption, I propose to commercially operate the UASs for the purpose of

conducting aerial video and photography over certain areas of United States, pursuant to the

following specific operating limitations:

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

described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum

gross weight: 3DR Solo and Tarot 680Pro Aerial Imaging Multirotor UAS. Proposed operations

of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose

of aerial video and photography.

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

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

as indicated by the procedures specified in the operating documents unless a special request

is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by a device other than corrective

lenses.

6. The use of first person view (FPV) by the PIC or Visual Observer (VO) is not

permitted.

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7. All operations must utilize a safety observer (SO). The VO may be used to satisfy the VLOS

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be

able to communicate verbally at all times. Electronic messaging or texting is not permitted

during flight operations. The PIC must be designated before the flight and cannot transfer his or

her designation for the duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to

operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS

operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the procedures

outlined in the operating documents, the conditions and limitations contained in the grant of

exemption take precedence and must be followed. Otherwise, the operator must follow the

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

operating documents. It is the operator’s responsibility to track such revisions and present

updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for extension or

amendment to the grant of exemption. If the operator determines that any update or revision

would affect the basis upon which the FAA granted the exemption, then the operator must

petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS80)

may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe

flight. If the 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. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly documented in the

aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional

test flight. The PIC who conducts the functional test flight must make an entry in the aircraft

records.

12. The preflight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the operating

documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the aircraft

records, including total time in service, description of work accomplished, and the signature of

the authorized person returning the UAS to service.

13
15. Each UASs operated under this exemption must comply with all manufacture

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

17. The PIC must possess at least a sport pilot certificate and valid driver’s license.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles

and structures. PIC qualification flight hours must be logged in a manner consistent with 14

C.F.R.§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under

the terms of the exemption. However, training operations may only be conducted during

dedicated training sessions. During training, proficiency, and experience building flights, all

persons not essential for flight operations are considered nonparticipants, and the PIC must

operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §. All

operations must be conducted under visual meteorological conditions (VMC). If flight at night is

required, a special request will be made at the FAA office closest to proposed area of

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

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

a current FAA­published aeronautical sectional chart unless a letter of agreement with that

airport’s management is obtained, and the operation is conducted in accordance with a

NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.

21. The UA may not be operated less than 400 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined

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

operating documents.

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

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough power to fly at normal cruising speed to the intended landing point

and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations under the grant of exemption. This

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72

hours in advance, but not less than 48 hours prior to the operation. All operations shall be

conducted in accordance with airspace requirements in the ATO issued COA including class of

airspace, altitude level and potential transponder requirements.

14
26. All aircraft operated in accordance with the exemption must be identified by serial number,

registered in accordance with 14 C.F.R. part 47, and have identification (N Number) markings

in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control

of the UA must comply with the Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents

must be made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and

activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles,

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons

leave such protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of

such vessels, vehicles or structures has granted permission and the PIC has made a safety

assessment of the risk of operating closer to those objects and determined that it does not

present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an

undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled access property with permission

from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to be conducted.

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

of the operational area as defined by the applicable COA must be reported to the FAA's UAS

Integration Office (AFS80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

I submit that the equivalent level of safety established by Section 61.113(a) and (b) will be

maintained because no PIC will be allowed to operate the 3DR Solo and Tarot 680Pro except

Charles C. Smith, and that PIC has demonstrated, by meeting minimum flight hour and

currency requirements, that the PIC is able to safely operate the UAS in a manner consistent

with the exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

15
Considering my proposed area of operations, and the operating limitations set

forth above; the parallel nature of private pilot aeronautical knowledge requirements to

those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills

necessary to safely operate the 3DR Solo and Tarot 680Pro UAS, I submit that the additional

manned airmanship experience of a commercially certificated pilot would not correlate to the

airmanship skills necessary for my specific proposed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all

material respects, to those presented herein (e.g. Exemption No’s. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156,

11158, 11159, 11160, 11161).

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of

those hours as a UAS pilot operating the same make and model of UAS to be used for

operations under the exemption). In addition to the hour requirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in

Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of safety

during my proposed operations. The Administrator has held that prior documented flight

experience that was obtained in compliance with applicable regulations would ensure safe

operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose

of motion picture filming (or similar operations), the PIC must have accumulated and logged, in

a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot

including at least 10 hours logged as a UAS pilot with a multirotor UAS. Prior to operations

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption.

For clarification, the FAA considers these minimum hour requirements to be inclusive rather

than additive; i.e. 5 hours make and model time may be included in the 10 hours of multirotor

time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition

to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90

days (for currency purposes). The FAA finds that at a minimum, the flight hour

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the

skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that

prior documented flight experience that was obtained in compliance with applicable regulations

would satisfy this requirement. Training, proficiency, and experience building flights can also be

conducted under the grant of exemption to accomplish the required flight time. During training,

proficiency, and experience building flights the PIC is required to operate the UA with

appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

16
Accordingly, Stratosfoto will ensure safe operations by not allowing any PIC to operate the

UASs unless that PIC has demonstrated, by meeting minimum flight hour and currency

requirements, that the PIC is able to safely operate the UASs in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior

to every flight, I will ensure that the DJI Phantom 3 UAS is in an airworthy condition based

upon the UAS’s compliance with its operating documents and as stated in the conditions and

limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a)

specific to UAS, in circumstances similar, in all material respects, to those presented herein

(e.g. Exemption No’s. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not

Adversely Affect Safety.

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

altitude information of the DJI Phantom 3 UAs will be provided to the PIC via GPS equipment

and a radio communications telemetry data link, which downlinks from the UA to the GCS for

active monitoring of the flight path and altitude. This altitude information, combined with my

operation of the DJI Phantom 3 UAs within visual line of sight, at or below 400 feet AGL, will

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated

by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation

point is automatically established by the UAS at ground level. The FAA has previously granted

relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to

those presented herein (e.g. Exemption No’s. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160,

11161).

Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the 3DR Solo and Tarot

680Pro UASs; (2) the limitations on the proposed flight operations; and (3) the location of the

proposed flight operations. Accordingly, Stratosfoto will ensure that it will safely operate the

battery powered UASs during daylight hours in VFR conditions, with enough battery power to

fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 4.5 minutes. Here, the technical specifications of the

UASs; the limitations on the proposed flight operations; and the location of the proposed

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b). Furthermore, safety will be ensured as both UASs provide redundant audible

17
warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first

warning occurring at approximately 33% remaining battery power, and again at approximately

10% remaining battery power. At the critically low battery level, the UASs will descend and land

automatically either in the position is was at, or returning to home base.

Previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not

adversely affected when the technical characteristics and operating limitations of the UAS are

considered. Relief has been granted for manned aircraft to operate at less than the minimums

prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the

FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808,

10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, I submit that the equivalent level of safety with regard to the

regulatory maintenance and alteration requirements established by Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Stratosfoto will

use trained technicians to perform maintenance, alterations, or preventive maintenance on the

UASs using the methods, techniques, and practices prescribed in the operating documents

(i.e., the Operations Manual, Monthly Maintenance Log, and Instruction Manuals).

Furthermore, I Stratosfoto will document and maintain all maintenance records for the UASs.

Likewise, the exemption sought will not adversely affect safety because I will use my building

experience to perform maintenance, alterations or preventive maintenance on the UAS using

the methods, techniques, and practices prescribed by the operating documents. Furthermore,

the exemption sought would maintain an equivalent level of safety established by Sections

91.407, 91.417(a) and 91.417(b), because all maintenance of the UASs will be performed by

Charles C. Smith. Maintenance will be documented and maintained utilizing the monthly

maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not

adversely affected when the technical characteristics and operating limitations of the UAS are

considered.

In consideration of my proposed operating limitations, the operating documents, and the

technical aspects of the DJI Phantom 3 UASs, I submit that safety will not be adversely

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2),

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption No’s.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, I request that the FAA prescribe special

conditions for the intended operation of the 3DR Solo and Tarot 680Pro UASs, which contain

such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) &

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

(b). Such special conditions will permit safe operation of the UAs for the limited purpose of

conducting aerial video and photography over certain areas of the United States for

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to

national security; and further, provides the authority for such UAS to operate without

airworthiness certification in accordance with any requirements that must be established for the

safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for

operation of the DJI Phantom 3 UASs, since the airworthiness regulations of 14 C.F.R. Part 21

do not contain adequate or appropriate safety standards, due to the novel or unusual design

features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special

conditions and amendments thereto for the product. The special conditions are issued in

accordance with Part 11 of this chapter and contain such safety standards for the aircraft,

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent

to that established in the regulations. See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Stratosfoto’s intended operation of the 3DR Solo and Tarot

680Pro UASs, which contain such safety standards that the Administrator finds necessary to

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and

14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Summary That Can Be Published In The Federal Register, stating: The Rules Which

Stratosfoto Seeks Exemption:

Stratosfoto, or Charles C. Smith, seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b).

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A Brief Description Of The Nature Of The Exemption Stratosfoto Seeks:

This exemption will permit Stratosfoto to commercially operate an Unmanned Aircraft System

(UAS) for the purpose of conducting aerial video and photography over certain areas of the

United States.

Additional Information, Views, Or Arguments Available To Support the Stratosfoto

Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA)

Section 333, which directs the Secretary of Transportation to determine if certain UAS may

operate safely in the NAS. As such, Stratosfoto’s request for exemption may be granted

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Charles C. Smith, the PIC, will operate the UASs safely in the

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to

national security.

Conclusion

As set forth herein, Stratosfoto seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe

operation of the 3DR Solo and Tarot 680Pro UASs commercially, without an airworthiness

certificate, for the limited purpose of conducting aerial video and photography over certain

areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing Stratosfoto to safely, efficiently, and

economically operate the 3DR Solo and Tarot 680Pro UASs commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Stratosfoto respectfully requests that the

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), and permit operation of the 3DR Solo and Tarot 680Pro UAS commercially for

the purpose of conducting aerial video and photography over certain areas of the United

States.

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Dated: June 17, 2015

Respectfully submitted,

Charles C. Smith, Owner/Operator

Stratosfoto

25 Ripplewood Lane

Palm Coast, FL

(386) 793­4251

stratosfoto@cfl.rr.com

Attachments:

● Attachment 1­ 3DR Solo User Manual

● Attachment 2­ NAZA Flight Controller Manual for Tarot 680Pro

PreFlight Check­List

ο Visual inspection for defects

ο Batteries fully charged and checked Transmitter, UAS, tablet, approved/compatible device

ο Props tightened and locked

ο SD card in camera

ο Lens cap removed

ο Antennae up and parallel

ο Transmitter turned on

ο UAS turned on

ο Flick the appropriate 3­way switch on transmitter up and down 7 times quickly to

convert to calibration mode then calibrate accordingly to ensure stable flight

ο UAS placed in safe launch and recover position

ο Home point reprogrammed via app

ο Area clear of people / obstructions

Flight Check List

ο Hover close for 20 seconds. Look / Listen for defects

ο Confirm expected stick operation

ο Monitor battery power

ο Monitor signal strength

ο Keep visual line­of­sight with UAS

o Ensure area/zone of intended flight path is clear of other aerial traffic

o Ensure area/zone of intended flight path is clear of any electrical/power lines

o Ensure atmospheric conditions are optimal for safe operation of UAV/UAS

o Select a safe zone to “ditch” the UAV/UAS in the event an emergency landing is required

21