October 15, 2014

U.S. Department of Transportation

Docket Management System 

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 

333 of the FAA Reform Act and

Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14

C.F.R. Part 11, Commonwealth Edison Company (“ComEd”), a northern Illinois-based electric utility 

that delivers reliable electricity for 3.8 million customers throughout more than 400 municipalities and 

25 counties, seeks exemptions from the Federal Aviation Regulations (“FARs”) so that it may test utility 

system monitoring by small Unmanned Aircraft Systems (sUASs) in a remote area of Cook and Will 

Counties, Illinois. ComEd’s limited proposed use of sUASs does not create a hazard to users of the 

national air space (NAS) or the public or threaten national security due to their small size, low weight 

and speed, safety features, and operating distance from airports and populated areas. As detailed in 

Appendix A, ComEd’s proposed use of sUASs thoroughly addresses all of the safety criteria found in

the FAA’s grants of exemption to Astraeus Aerial, Aerial MOB, LLC, Pictorvision Inc., HeliVideo 

Productions LLC, Snaproll Media LLC, and RC Pro Production Consulting LLC dba Vortex Aerial 

(the “Production Companies”).

The requested exemptions would permit ComEd and the Illinois Institute of Technology (IIT) to conduct 

trial operations of the DJI Innovations S900 (“the DJI S900” or the “sUAS”) for the limited purposes of 

electric transmission and distribution utility system (“ComEd System”) monitoring and university 

research. In particular, the requested exemption would authorize operation of the DJI S900 to gather 

information on the condition of the ComEd System in hard-to-access areas, including the assessment of 

storm damage. sUAS technology has the potential to enhance ComEd’s ability to assess the condition of 

the ComEd System safely and efficiently. It would allow ComEd to survey more territory faster, safer, 

and more fuel efficiently than it can using existing methods on foot or using helicopters or other low 

flying aircraft, resulting in improved reliability of electrical services for our customers. IIT, as part of 

their Engineering Department’s Robotics Lab, seeks to evaluate the performance of this technology in real 

world conditions. 

As described more fully within this petition, the DJI S900’s operations under the exemption will be 

subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to 

currently authorized operations using manned aircraft and under conditions as may be modified by the 

FAA as required by Section 333. The DJI S900 will be operated under controlled conditions by qualified 

operators. It will be flown at low altitudes in airspace that is limited in scope, as described more fully 

herein, and detailed in the Certificate of Authorization application. DJI S900 operations will not be 

conducted in a way that violates reasonable expectations of privacy. 

1
CHARACTERISTICS OF THE DJI INNOVATIONS S900

The DJI S900 consists of a graphical, touch-screen control station, an aerial vehicle, and a radio repeater 

station. The aerial vehicle consists of a small hexrotor, a type of rotorcraft, which is lifted and propelled 

by six rotors. It is electrically powered by lithium polymer batteries and therefore presents no fuel spill 

risk. To further increase safety, IIT researchers have designed a cage structure that encloses the aerial 

vehicle, allowing it to roll on the ground to prevent damaging crashes. Previous experiments with other 

similar systems indicate that the cage structure has no detrimental impact on the flight capabilities of the 

system. 

The radio repeater station is used to extend the control station’s transmission range. The radio repeater 

station and control station comply with all FCC requirements. The aerial vehicle itself performs all 

actions necessary to hold a fixed position or to travel to a destination. All system components monitor 

their own “health” and battery capacity. A fail safe system takes appropriate, pre-programmed actions 

when error conditions are detected, including hovering in place for ten seconds and returning to the takeoff point. For further details regarding the DJI Innovations S900 see Appendix B. 

ComEd respectfully submits that because this small, unmanned aircraft system will be used in lieu of 

comparatively hazardous operations now conducted with conventional rotary aircraft and inspections on 

foot in areas with downed power lines, the FAA can have confidence that the proposed operations will 

achieve at least an equivalent or greater level of safety. Additionally, ComEd employs many procedures 

that demonstrate a commitment to the safety of employees and the public. Many of these procedures

relate to overhead work, including an extensive safety rule book and protocols preventing ‘line of fire 

from above’ events. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to 

“establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant is as follows: 

Commonwealth Edison Company

Attn: Linda G. Rhodes, CSP (Certified Safety Professional)

Ph: 630-576-7623

Fax: 630-652-6857

Email: linda.rhodes@comed.com

Address: 2 Lincoln Centre

Oakbrook Terrace, IL 60181

2
EXEMPTIONS SOUGHT

The regulations from which the exemption is requested are as follows (see Appendix C for exemption 

request reasons and equivalent level of safety): 

14 CFR Part 21, specifically Subpart H (Certification procedures for products and parts; Airworthiness 

Certificates)

14CFR 43.7

14 CFR 43.11

14 CFR 45.11

14 CFR 45.23(b)

14 CFR 45.25

14 CFR 45.29

14 CFR 47.3(b)(2)

14 CFR 47.31(c)

14 CFR 91.9(b)(2)

14 CFR 91.9 c

14 CFR 91.103(b)(2)

14 CFR 91.105

14 CFR 91.109

14 CFR 91.113(b)

14 CFR 91.115

14 CFR 91.119(b)(c)

14 CFR 91.121

14 CFR 91.151

14 CFR 91.203(a)(1)

14 CFR 91.203(a)(2)

14 CFR 91.215

14CFR 91.319(a)(1)

14 CFR 91.403

14 CFR 91.405

14 CFR 91.407

14 CFR 91.409

14 CFR 91.417

3
THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

ComEd submits that grant of this exemption application for use of the DJI S900 in Utility System 

inspections and damage assessments will advance the Congressional mandate in Section 333 of the 

Reform Act to accelerate the introduction of sUASs into the national airspace system (NAS) if it can be 

accomplished safely. This law directs the Secretary of Transportation to consider whether certain 

sUASs may operate safely in the NAS before completion of the rulemaking required under Section 332 

of the Reform Act. In making this determination, the Secretary is required to determine which types of 

sUASs 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 sUAS’ size, weight, speed, and operational capability;

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

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

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the 

Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections or any of sections 44702-

44716 of this title if the Administrator finds the exemption is in the public interest.

Applicant submits that this provision places a duty on the Administrator to not only process 

applications for exemptions under Section 333, but for the Administrator, if he deems the conditions 

proposed herein require modification in order to allow approval, to supply conditions for the safe 

operation of the sUAS. ComEd welcomes the opportunity to consult with FAA staff in order to address 

any issues or concerns that this proposal may raise that they believe may require modification.

The grant of the requested exemption is in the public interest based on the clear direction in Section 

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to sUASs for inspections and 

research. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption 

without delay.

4
MANDATORY OPERATING REQUIREMENTS

Grant of the exemptions to ComEd will be subject to the following mandatory conditions, which provide 

at least an equivalent or higher level of safety than under the current operations.

1. The sUAS must weigh less than 18 pounds, including energy source(s) and equipment. 

Operations authorized by the grant will be limited to the following aircraft as described in the 

operator’s manual: the DJI Innovations S900. Proposed operations of any other aircraft will 

require a new petition or a petition to amend. 

2. The sUAS may not be flown at a ground speed exceeding 50 knots. 

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operator’s manual. All altitudes reported to ATC 

must be in feet AGL.

4. The UA (Unmanned Aircraft) must be operated within visual line of sight (VLOS) of the PIC 

(Pilot in Command) at all times. This requires the PIC to be able to use human vision unaided by 

any device other than corrective lenses, as specified on the PIC’s FAA-issued medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

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

be able to communicate verbally at all times.

6. The operator’s manual and this grant of exemption must be maintained and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations in this 

exemption and the procedures outlined in the operator’s manual, the conditions and limitations 

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

as outlined in its operator’s manual. The operator may update or revise its operator’s manual. 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. If the operator determines that any update or revision 

would affect the basis for which the FAA granted this exemption, then the operator must petition 

for amendment to their exemption. The FAA’s s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operator’s manual.

7. Prior to each flight, the DJI S900 must perform automatic pre-flight checks as outlined in the 

operator’s manual and failure of any check must prevent take-off. In addition, prior to each flight 

the PIC must inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals 

a condition that affects the safe operation of the sUAS, the aircraft is prohibited from operating 

until the necessary maintenance has been performed and the sUAS is found to be in a condition for 

safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. 

All maintenance and alterations must be properly documented in the aircraft records.

8. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight 

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

flight in accordance with the operator’s manual. The PIC who conducts the functional test flight 

must make an entry in the sUAS aircraft records of the flight. The requirements and procedures for 

a functional test flight and aircraft record entry must be added to the operator’s manual.

9. The operator must follow the manufacturer’s sUAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be 

established and identified in the operator’s manual. At a minimum, requirements for the following 

must be included in the operator’s manual: Actuators / Servos; Transmission (single rotor); 

Powerplant (motors); Propellers; Electronic speed controller; Batteries; Mechanical dynamic 

components (single rotor);Remote command and control; Ground control station (if used); and any 

other components as determined by the operator.

5
10. The Pilot In Command (PIC) must possess at least an FAA approved private pilot’s license and 

current third-class medical certificate and flight review. Currency requirements are not relevant to 

sUASs because they do not carry passengers. 

11. Prior to operations, the PIC must successfully complete a DJI factory certified pilot training 

program, designed for proficient operation and maintenance of the DJI S900.

12. Prior to Utility System monitoring operations (or similar operations), a flight demonstration, 

administered by an operator-approved and -qualified pilot must be successfully completed and 

documented. This documentation must be available for review upon request by the Administrator. 

Because the knowledge and airmanship test qualifications have been developed by the operator, 

and there are no established practical test standards that support a jurisdictional FAA FSDO 

evaluation and approval of company designated examiners, the petitioner will conduct these tests 

in accordance with the operator’s manual. 

13. The sUAS may not be operated directly over any person, except authorized and consenting utility 

personnel, below an altitude that is hazardous to persons or property on the surface in the event of 

an sUAS failure or emergency.

14. Regarding the distance from participating persons, the operator’s manual has safety mitigations for 

authorized and consenting personnel. At all times, those persons must be essential to the utility 

operations and wear hardhats. Because these procedures are specific to participating persons, no 

further FSDO or aviation safety inspector approval is necessary for reductions to the distances 

specified in the petitioner’s manuals. 

15. The pre-job brief will verify control of the flight area and further ensure the safety of test 

participants following guidance provided in Appendix D (Job Briefing and Job Turnover). Note 

that one requirement of the briefing process is to make sure proper personal protective equipment 

is worn by all participants. As required in the “Personal Protective Equipment” program attached 

in Appendix E, decisions about equipment required will be based on exposure risks (such as head 

protection, foot protection and eye protection).

16. All operations must be conducted over property that is owned or controlled by ComEd or is utility

right-of-way. The pre-job brief must verify control of the flight area, including the absence of 

members of the public in the flight area. Operations must be stopped if unauthorized persons enter 

the flight area, consistent with the “Time Out for Safety Process” detailed in Appendix F. Work 

performed on the ComEd System is governed by rigorous operational safety procedures, including 

protocols to protect the public from ‘line-of-fire from above’ events. 

17. If the sUAS loses communications or loses the GPS signal, the sUAS will hover in place for 10 

seconds and then must return to the take-off point or be recovered in accordance with the operator’s 

manual.

18. The sUAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the operator’s manual.

19. Each sUAS operation must be completed within 30 minutes flight time or with 20% battery power 

remaining, whichever occurs first. The fail-safe and countdown timer on the sUAS will be used to 

alert the operator when 20% of the battery power is remaining so a controlled landing can be 

facilitated. The fail-safe feature results in a first level warning light. A second level warning 

follows with flashing lights. The countdown timer acts as a third level warning with an audible 

alarm, alerting the operator so they have adequate time to return to base.

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

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

21. ComEd must fulfill any reasonable request by the FAA related to the identification and 

registration marking of the sUAS.

22. The operator must develop procedures to document and maintain a record of the sUAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the sUAS. These procedures must be added to the operator’s 

manual.

6
23. Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins.

24. The operator must develop sUAS technician qualification criteria. These criteria must be added to 

the operator’s manual.

25. The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable 

components, items, or equipment, not covered in the relevant preflight inspection sections of the 

operator’s manual.

26. 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.

27. The following agencies/departments will be notified in advance about all sUAS flights: Within 

Municipalities (so municipality officials can proactively communicate sUAS operations to 

residents and respond to public inquiries): Mayor’s Office, Illinois Department of Transportation, 

Sheriff’s Office/Police Department. Within ComEd (so department leaders can proactively 

communicate sUAS operations to the public and respond to public inquiries): Communications, 

External Affairs, Customer Care Center (Customer Service Agents), EChannels (Social Media 

Department), Corporate Relations, and Public Relations. Notifications will include the following 

information: Dates and times for all flights, Name and phone number of the person responsible for 

the onsite operation of the sUAS, Make, model and serial number of the sUAS to be used, Name 

and certificate number of the sUAS person-in-charge, signature of exemption holder or 

representative, and a description of the flight activity, including maps or diagrams of any area over 

which inspections will be conducted and the altitudes essential to accomplish the operation.

28. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the sUAS any time the aircraft 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 other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing 

activities, hang gliders, etc.).

30. sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized.

31. The sUAS may not be operated by the PIC from any moving device or vehicle.

32. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

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

33. The sUAS may not operate in Class B, C, or D airspace without written approval from the FAA. 

The sUAS may not operate within five nautical miles of the geographic center of a non-towered 

airport unless a letter of agreement with that airport’s management is obtained. When reasonable 

and practical, ComEd will initiate a NOTAM. However, in the event of an emergency, such as a 

power outage caused by a storm, it is not practicable for ComEd to initiate a NOTAM because of 

the advanced notification requirement. ComEd will follow any reasonable and practicable notice 

requirements mandated by the FAA. 

34. 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 sUAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

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

www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided.

7
35. The sUASs must operate at a safe distance from power lines. Operation of the sUAS to be 

allowed by trained pilots using approved protocols only. The pre-job brief will communicate 

approved clearances and operation of the sUAS will be closely monitored. The job will be 

stopped if clearances are breached. The DJI S900 must be equipped with a digital zoom lens 

camera that will be used to increase visibility of components being inspected so there will be no 

operational need to fly close enough to lines to risk electromagnetic interference. sUAS operating 

rules establish minimum power line spacing for each voltage. Operators will evaluate how to 

safely fly around power lines without bridging phases before each flight (for example, power line 

spacing must be confirmed as greater than the minimum before the sUAS would be allowed to fly 

between power lines). Also, flying between lines must be avoided when possible.

36. The sUASs must provide visual warnings to the pilot for all systems, alarm condition and out-ofrange sensor values.

37. Consistent with other ComEd jobs performed in the field, compliance with a briefing process will 

be required before, during and after operations of the sUAS for increased safety (see Appendix G

for the ComEd sUAS Aerial Inspections Flight Briefing Sheet).

38. sUAS operations will not be conducted in a way that violates reasonable expectations of privacy. 

Operations will follow the Association for Unmanned Vehicle Systems International Code of 

Conduct for Unmanned Aircraft System Operations and affected municipalities will be notified in 

advance about sUAS flights.

CONCLUSION

The planned used of the DJI S900 satisfies the criteria set forth in Section 333 of the Reform Act. 

ComEd’s proposed sUAS operations, subject to the conditions listed above, do not create a hazard to 

users of the national air space (NAS) or the public or threaten national security due to its small size, low 

weight and speed, safety features, and operating distance from airports and populated areas. 

The operation of the sUAS for inspections and research in accordance with the strict conditions 

outlined herein will provide more than an equivalent level of safety, supporting the grant of the 

exemptions requested. Approval of the exemption allowing operations of the DJI S900 for inspections 

and research will enhance safety by reducing the risks inherent in ComEd’s present operations. Current

aerial inspection operations of the ComEd System using conventional rotary aircraft, present risks 

associated with vehicles that often weigh in excess of 5,000 to 7,000 lbs. and carry large quantities of 

fuel, passengers, and cargo. Such aircraft must fly to and from the inspection locations, often over 

residential properties. The DJI S900 will operate at similar speeds and altitudes of conventional 

aircraft, but only weighs approximately 18 lbs. (less than half the weight approved for sUAS use by the 

Production Companies), is powered by batteries, and will be carried to the inspection location. The DJI 

S900 will not fly over residences like conventional aircraft. Further, the DJI S900 will carry no 

passengers or crew and, therefore, will not expose any individuals to the risks associated with manned 

aircraft flights. All of these factors greatly reduce the risks associated with conventional operations. 

Given its size, speed, load capacity, and lack of fuel spill risk, the DJI S900 poses no threat to national 

security. Further, the operating capabilities, lack of proximity to airports and populated areas, 

avoidance of airspace used by other aircraft, operation within visual line of sight, and use of licensed 

pilots provide more than adequate justification to grant the requested exemptions.

Yours in Safety,

Linda G. Rhodes, CSP (Certified Safety Professional)

Commonwealth Edison

8
APPENDIX A

Exelon Section 333 Exemption Application Compared with Granted Applications

ComEd Petition Conditions resulting from 6 identical 

approved applications--Film Producers

1 The sUAS must weigh less than 18 pounds, 

including energy source(s) and equipment. 

Operations authorized by the grant will be 

limited to the following aircraft as described in 

the operator’s manual: the DJI Innovations S900. 

Proposed operations of any other aircraft will 

require a new petition or a petition to amend. 

The unmanned aircraft (UA) must weigh less 

than 55 pounds (25 Kg), including energy 

source(s) and equipment. Operations authorized 

by this grant of exemption are limited to the 

following aircraft described in the operator’s 

manual: Astraeus Aerial Cinema System 

V.3CS UAS aircraft variant, serial #001 onward 

(V.3). Proposed operations of any other aircraft 

will require a new petition or a petition to amend 

this grant.

2 The sUAS may not be flown at a ground speed 

exceeding 50 knots . 

Same parameters

3 Flights must be operated at an altitude of no 

more than 400 feet above ground level (AGL), 

as indicated by the procedures specified in the 

operator’s manual. All altitudes reported to 

ATC must be in feet AGL.

Same parameters

4 The UA must be operated within visual line of 

sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision 

unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued 

medical certificate.

Same parameters

5 All operations must utilize a visual observer 

(VO). The VO may be used to satisfy the VLOS 

requirement as long as the VO and PIC always 

maintains VLOS capability. The VO and PIC 

must be able to communicate verbally at all 

times.

Same parameters

6. The operator’s manual and this grant of 

exemption must be maintained and made 

available to the Administrator upon request. If a 

discrepancy exists between the conditions and 

limitations in this exemption and the procedures 

outlined in the operator’s manual, the conditions 

and limitations herein take precedence and must 

be followed. Otherwise, the operator must follow 

the procedures as outlined in its operator’s 

manual.

The operator may update or revise its operator’s 

manual. It is the operator’s responsibility to track 

Same parameters

9
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. If the operator determines that any 

update or revision would affect the basis for 

which the FAA granted this exemption, then the 

operator must petition for amendment to their 

exemption. The FAA’s sUAS Integration Office 

(AFS-80) may be contacted if questions arise 

regarding updates or revisions to the operator’s 

manual.

7 Prior to each flight, the DJI S900 must perform 

automatic pre-flight checks as outlined in the 

operators manual and failure of any check must 

prevent take-off. In addition, prior to each flight 

the PIC must inspect the sUAS to ensure it is in 

a condition for safe flight. If the inspection 

reveals a condition that affects the safe operation 

of the sUAS, the aircraft is prohibited from 

operating until the necessary maintenance has 

been performed and the sUAS is found to be in a 

condition for safe flight. The Ground Control 

Station, if utilized, must be included in the 

preflight inspection. All maintenance and 

alterations must be properly documented in the 

aircraft records.

Prior to each flight the PIC must inspect the 

UAS to ensure 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, if utilized, must be 

included in the preflight inspection. All 

maintenance and alterations must be properly 

documented in the aircraft records.

8 Any sUAS that has undergone maintenance or 

alterations that affect the sUAS operation or 

flight characteristics, e.g. replacement of a flight 

critical component, must undergo a functional 

test flight in accordance with the operator’s 

manual. The PIC who conducts the functional 

test flight must make an entry in the sUAS 

aircraft records of the flight. The requirements 

and procedures for a functional test flight and 

aircraft record entry must be added to the 

operator’s manual.

Same parameters

9 The operator must follow the manufacturer’s 

sUAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit 

requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, 

and inspection/maintenance requirements must 

be established and identified in the operator’s 

manual. At a minimum, requirements for the 

following must be included in the operator’s 

manual: Actuators / Servos; Transmission 

(single rotor); Powerplant (motors); Propellers; 

Electronic speed controller; Batteries; 

Mechanical dynamic components (single rotor);

The operator must follow the manufacturer’s 

UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit 

requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, 

and inspection/maintenance requirements must 

be established and identified in the operator’s 

manual. At a minimum, requirements for the 

following must be included in the operator’s 

manual: Actuators / Servos; Transmission 

(single rotor); Powerplant (motors); Propellers; 

Electronic speed controller; Batteries; Same 

parameters

10
Remote command and control; Ground control 

station (if used); and any other components as 

determined by the operator.

10 The Pilot In Command (PIC) must possess at 

least an FAA approved private pilot’s license 

and current third-class medical certificate and 

flight review. Currency requirements are not 

relevant to sUASs because they do not carry 

passengers. 

The Pilot In Command (PIC) must possess at 

least a private pilot certificate and at least a 

current third-class medical certificate. The PIC 

must 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.

11 Prior to flight operations, the PIC must 

successfully complete a DJI factory certified pilot 

training program, designed for proficient 

operation and maintenance of the DJI S900.

The PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), a 

minimum of twelve hours as a sUAS pilot 

operating the DJI S900 to be used for operations 

under the exemption: three hours of flight over an 

open area, three hours inspecting distribution 

structures, three hours inspecting transmission 

structures, and three hours inspecting substations.

The twelve hour operating time may be satisfied 

by training using the DJI Operating Manual as a 

training guide. The training must also include 

three take-offs, three landings, and emergency 

procedures – all conducted under this grant of 

exemption.

Training will take place at a ComEd training 

facility (such as the Rockford Training Facility, 

Rockford, IL, where there’s 85,000 square feet of 

secure outdoor training space). 

Prior to operations conducted 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), a 

minimum of 200 flight cycles and 25 hours of 

total time as a UAS rotorcraft pilot and at least 

ten hours logged as a UAS pilot with a similar 

UAS type (single blade or multirotor). Prior 

documented flight experience that was obtained 

in compliance with applicable regulations may 

satisfy this requirement. Training, proficiency, 

and experience-building flights can also be 

conducted under this grant of exemption to 

accomplish the required flight cycles and flight 

time. 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 CFR § 

91.119.

12 Prior to flight operations, the PIC must 

successfully complete a DJI factory certified pilot 

training program, designed for proficient 

operation and maintenance of the DJI S900.

The PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), a 

minimum of twelve hours as a sUAS pilot 

operating the DJI S900 to be used for operations 

under the exemption: three hours of flight over an 

open area, three hours inspecting distribution 

structures, three hours inspecting transmission 

structures, and three hours inspecting substations.

The twelve hour operating time may be satisfied 

by training using the DJI Operating Manual as a 

Prior to operations conducted for the purpose of 

motion picture filming (or similar operations), 

the PIC must have accumulated and logged, in a 

manner consistent with14 CFR § 61.51(b), a 

minimum of five hours as UAS pilot operating 

the make and model of UAS to be utilized for 

operations under the exemption and three takeoffs and three landings in the preceding 90 days. 

Training, proficiency, experience-building, and 

take-off and landing currency flights can be 

conducted under this grant of exemption to 

accomplish the required flight time and 90 day 

currency. During training, proficiency, 

experience-building, and take-off and landing 

currency flights all persons not essential for 

flight operations are considered nonparticipants, 

11
training guide The training must also include 

three take-offs, three landings, and emergency 

procedures – all conducted under this grant of 

exemption.

Training will take place at a ComEd training 

facility (such as the Rockford Training Facility, 

Rockford, IL, where there’s 85,000 square feet of 

secure outdoor training space). 

and the PIC must operate the UA with 

appropriate distance from nonparticipants in 

accordance with 14 CFR §91.119.

13 Prior to any flight operations by this grant of 

exemption, the PIC and VO must have 

successfully completed a qualification process. 

The test must be developed and implemented by 

a qualified person designated at the sole 

discretion of the operator and must include 

training, proficiency and experience-building

flights. 

The DJI S900 Operating Manual must be used as 

the foundation for a qualification process guide. 

The qualification process must include take-offs, 

landings, and emergency procedures – all 

conducted under this grant of exemption.

A record of completion of this qualification 

process must be documented and made available 

to the Administrator upon request.

Prior to any flight operations authorized by this 

grant of exemption, the PIC and VO must have 

successfully completed a qualification process, 

as outlined in the operator’s manual. As this is a 

requirement stipulated by the operator, the test 

must be developed and implemented by a 

qualified person designated at the sole discretion 

of the operator. A record of completion of this 

qualification process must be documented and 

made available to the Administrator upon 

request.

14 Prior to ComEd System monitoring operations 

(or similar operations), a flight demonstration, 

administered by an operator-approved and -

qualified pilot must be successfully completed 

and documented. This documentation must be 

available for review upon request by the 

Administrator. Because the knowledge and 

airmanship test qualifications have been 

developed by the operator, and there are no 

established practical test standards that support a 

jurisdictional FAA FSDO evaluation and 

approval of company designated examiners, the 

petitioner will conduct these tests in accordance 

with the operator’s manual.

Same parameters

15 The sUAS may not be operated directly over any 

person, except authorized and consenting utility 

personnel, below an altitude that is hazardous to 

persons or property on the surface in the event of 

an sUAS failure or emergency.

Same parameters

12
16 Regarding the distance from participating 

persons, the operator’s manual has safety 

mitigations for authorized and consenting 

personnel. At all times, those persons must be 

essential to the utility operations and wear 

hardhats. Because these procedures are specific

to participating persons, no further FSDO or 

aviation safety inspector approval is necessary 

for reductions to the distances specified in the 

petitioner’s manuals. 

Regarding the distance from participating 

persons, the operator’s manual has safety 

mitigations for authorized and consenting 

production personnel. At all times, those persons 

must be essential to the closed-set film 

operations. Because these procedures are 

specific to participating persons, no further 

FSDO or aviation safety inspector approval is 

necessary for reductions to the distances 

specified in the petitioner’s manuals. This is 

consistent with the manned aircraft procedures 

described in FAA Order 8900.1, V3, C8, S1 

Issue a Certificate of Waiver for Motion Picture 

and Television Filming.

17 All operations must be conducted over property 

that is owned or controlled by ComEd or is utility 

right-of-way. The pre-job brief must verify 

control of the flight area, including the absence 

of members of the public in the flight area. 

Operations must be stopped if unauthorized 

persons enter the flight area, consistent with the 

“Time Out for Safety Process” detailed in 

Appendix F. Work performed on ComEd’s 

system is governed by rigorous protocols, 

including the extensive work performed 

overhead. Work Area Protection protocols, for 

example, include protecting the public from 

work being performed and from the associated 

conditions.

Regarding distance from nonparticipating 

persons, the operator must ensure that no persons 

are allowed within 500 feet of the area except 

those consenting to be involved and necessary 

for the filming production. This provision may 

be reduced to no less than 200 feet if it would 

not adversely affect safety and the Administrator 

has approved it. For example, an equivalent level 

of safety may be determined by an aviation 

safety inspector’s evaluation of the filming 

production area to note terrain features, 

obstructions, buildings, safety barriers, etc. Such 

barriers may protect nonparticipating persons 

(observers, the public, news media, etc.) from 

debris in the event of an accident. This is also 

consistent with the same FAA Order 8900.1, V3,

C8, S1.

18 If the sUAS loses communications or loses the 

GPS signal, the sUAS will hover in place for 10 

seconds and then must return to the take-off point 

or in accordance with the operator’s manual.

If the UAS loses communications or loses GPS 

signal, the UA must return to a pre-determined 

location within the security perimeter and land 

or be recovered in accordance with the 

operator’s manual.

19 The sUAS must abort the flight in the event of 

unpredicted obstacles or emergencies in 

accordance with the operator’s manual.

Same parameters

20 Each sUAS operation must be completed within 

30 minutes flight time or with 20% battery 

power remaining, whichever occurs first. The 

fail-safe and countdown timer on the sUAS will 

be used to alert the operator when 20% of the 

battery power is remaining so a controlled 

landing can be facilitated. The fail-safe feature 

results in a first level warning light. A second 

level warning follows with flashing lights. The 

countdown timer acts as a third level warning 

Each UAS operation must be completed within 

30 minutes flight time or with 25% battery 

power remaining, whichever occurs first.

13
with an audible alarm, alerting the operator so 

they have adequate time to return to base.

21 The operator must obtain an Air Traffic 

Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any 

operations under this grant of exemption.

The operator must obtain an Air Traffic 

Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any 

operations under this 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.

22 ComEd must fulfill any reasonable request by 

the FAA related to the identification and 

registration marking of the sUAS.

All aircraft must be identified by serial number,

registered in accordance with 14 CFR part 47, 

and have identification (N-Number) markings in 

accordance with 14 CFR part 45, subpart C. 

Markings must be as large as practicable.

23 The operator must develop procedures to 

document and maintain a record of the sUAS 

maintenance, preventative maintenance, 

alterations, status of replacement/overhaul 

component parts, and the total time in service of 

the sUAS. These procedures must be added to 

the operator’s manual.

Same parameters

24 The sUAS operated under this exemption must 

comply with all manufacturer Safety Bulletins.

Same parameters

25 The operator must develop UAS technician 

qualification criteria. These criteria must be 

added to the operator’s manual.

Same parameters

26 The preflight inspection section in the operator’s

manual must be amended to include the 

following requirement: The preflight inspection 

must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not 

covered in the relevant preflight inspection 

sections of the operator’s manual.

Same parameters

27 Before conducting operations, the radio 

frequency spectrum used for operation and 

control of the UA must comply with the Federal 

Same parameters

14
Communications Commission (FCC) or other 

appropriate government oversight agency 

requirements.

28 The following agencies/departments will be 

notified in advance about all sUAS flights: 

Within Municipalities (so municipality officials 

can proactively communicate sUAS operations 

to residents and respond to public inquiries)

Mayor’s Office 

Illinois Department of Transportation

Sheriff’s Office/Police Department

Within ComEd (so department leaders can 

proactively communicate sUAS operations to the 

public and respond to public inquiries)

Communications

External Affairs

Customer Care Center (Customer Service 

Agents)

EChannels (Social Media Department)

Corporate Relations

Public Relations

Notifications will include the following 

information:

1) Dates and times for all flights.

2) Name and phone number of the person 

responsible for the onsite operation of the 

sUAS.

3) Make, model and serial number of the 

sUAS to be used.

4) Name and certificate number of the 

sUAS person-in-charge.

5) Signature of exemption holder or 

representative.

6) A description of the flight activity, 

including maps or diagrams of any area 

over which inspections will be conducted 

and the altitudes essential to accomplish 

the operation.

Must submit a written Plan of Activities to the 

local FSDO including at least the following:

a. Dates and times for all flights

b. Name and phone number of the operator for 

the UAS filming production conducted 

under this grant of exemption

c. Name and phone number of the person 

responsible for the on-scene operation of the 

UAS

d. Make, model, and serial or N-number of UAS 

to be used

e. Name and certificate number of UAS PICs 

involved in the filming production event

f. A statement that the operator has obtained 

permission from property owners and/or local 

officials to conduct the filming production event; 

the list of those who gave permission must be 

made available to the inspector upon request.

g. Signature of exemption-holder or 

representative

h. A description of the flight activity, including 

maps or diagrams of any area, city, town, 

county, and/or state over which filming will be 

conducted and the altitudes essential to 

accomplish the operation;

29 The documents required under 14 CFR §§ 91.9 

and 91.203 must be available to the PIC at the 

Ground Control Station of the sUAS any time 

the aircraft is operating. These documents must 

be made available to the Administrator or any 

law enforcement official upon request.

Same parameters

30 The UA must remain clear and yield the right of 

way to all other manned operations and activities 

at all times (including, but not limited to, 

ultralight vehicles, parachute activities, 

Same parameters

15
parasailing activities, hang gliders, etc.).

31 sUAS operations may not be conducted during 

the night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual 

meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not 

authorized.

Same parameters

32 The sUAS may not be operated by the PIC from 

any moving device or vehicle.

Same parameters

33 The UA may not be operated less than 500 feet 

below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute 

miles from the PIC.

Same parameters

34 The sUAS may not operate in Class B, C, or D 

airspace without written approval from the FAA. 

The sUAS may not operate within five nautical 

miles of the geographic center of a non-towered 

airport unless a letter of agreement with that 

airport’s management is obtained. When 

reasonable and practical, ComEd will initiate a 

NOTAM. However, in the event of an 

emergency, such as a power outage caused by a 

storm, it is not practicable for ComEd to initiate 

a NOTAM because of the advanced notification 

requirement. ComEd will follow any reasonable 

and practicable notice requirements mandated by 

the FAA. 

The UA may not operate in Class B, C, or D 

airspace without written approval from the FAA.

The UA may not operate within 5 nautical miles 

of the geographic center of a non-towered airport 

as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and 

the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA.

The letter of agreement with the airport 

management must be made available to the 

Administrator upon request.

35 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 sUAS 

Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National 

Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: 

www.ntsb.gov. Further flight operations may not 

be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and 

authorization to resume operations is provided.

Same parameters

16
APPENDIX B

SMALL UNMANNED AIRCRAFT SYSTEM DESCRIPTION & SPECIFICATIONS

DJI Innovations – DJI S900

The DJI S900 consists of a graphical, touch-screen control station, an aerial vehicle, and a radio 

repeater station. The aerial vehicle consists of a small hexrotor, a type of rotorcraft, which is 

lifted and propelled by six rotors. It is electrically powered by lithium polymer batteries and 

therefore presents no fuel spill risk. To further increase safety, IIT researchers have designed a 

cage structure that encloses the aerial vehicle, allowing it to roll on the ground to prevent 

damaging crashes. Previous experiments with other similar systems indicate that the cage 

structure has no detrimental impact on the flight capabilities of the system.

The radio repeater station is used to extend the control station’s transmission range. The radio 

repeater station and control station comply with all FCC requirements. The aerial vehicle itself 

performs all actions necessary to hold a fixed position or to travel to a destination. All system 

components monitor their own “health” and battery capacity. A fail safe system takes 

appropriate, pre-programmed actions when error conditions are detected, including hovering in 

place for ten seconds and returning to the take-off point. 

DJI Innovations

6F, Hkust Sz IER Bldg. 

No.9 Yuexing 1st Rd. 

Hi-Tech Park (South), 

Nanshan Dist. 

Shenzhen, Guangdong, China, 518057.

Phone: +86 755 26656677

Email: info@dji.com

DJI Innovations Authorized Dealer – UAV Direct

14365 W. State Highway 29

Liberty Hill, TX 78642

Phone: 1-855-778-6363

Email: ops@uavdirect.com

17
Frame Diagonal Wheelbase

900mm

Frame Arm Length

358mm

Frame Arm 

(Including Motor, ESC, Propeller )

316g

Center Frame Diameter

272mm

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

1185g

Landing Gear Size

460mm(Length)×450mm(Width)×360mm(Height)

Motor

Stator Size

41×14mm

KV

400rpm/V

Max Power

500W

Weight(With Cooling Fan)

158g

ESC Working Current

40A

Working Voltage

6S LiPo

Signal Frequency

30Hz ~ 450Hz

Drive PWM Frequency

8KHz

Weight(With Radiators)

35g

18
Foldable Propeller (1552/1552R)

Material

High strength performance engineered plastics

Size

15×5.2inch

Weight

13g

Flight Parameters Takeoff Weight

4.7Kg ~ 8.2Kg

Total Weight

3.3Kg

Power Battery

LiPo (6S、10000mAh~15000mAh、15C(Min))

Max Power Consumption

3000W

Hover Power Consumption

1000W (@6.8Kg Takeoff Weight)

Hover Time

18min (@12000mAh& 6.8Kg Takeoff Weight)

Working Environment Temperature

-10 °C ~ +40 °C

Gain Value Settings For A2 Flight Controller

Basic: Roll 110%, Pitch 

Attitude: Roll 220%, Pitch 220%, Vertical 120%

For WooKong-M Flight Controller

Basic: Roll 160%, Pitch 

Attitude: Roll 190%, Pitch 190%, Vertical 100%

FRAME

Diagonal 

Wheelbase Frame Arm Length

Frame Arm Weight

(Including Motor, 

ESC, Propeller)

Center 

Frame 

Diameter

800mm 350mm 356g 240mm

19
Center Frame 

Weight Landing Gear Size

Retractable Landing 

Gear Weight

(Including Battery 

Tray)

550g

460mm(Length)×425mm(Wi

dth)×320mm(Height)

(Top width: 155mm)

1050g

FLGHT 

PARAMETE

RS

Takeoff Weight Total Weight Power Battery

Max Power 

Consumpti

on

6.0Kg ~ 8.0Kg 3.7Kg

LiPo (6S、

10000mAh~15000mA

h、15C(Min))

3000W

Hover Power 

Consumption Hover Time

800W(@ Takeoff 

Weight 6.7Kg)

Max: 20 min

(@15000mAh&6.7Kg 

Takeoff Weight)

MOTOR

Stator Size KV Max Power

Weight (w/ 

Cooling 

Fan)

41×14mm 400rpm/V 500W 158g

ESC

Current Voltage Signal Frequency

Drive 

PWM 

Frequency

40A OPTO 6S LiPo 30Hz ~ 450Hz 8KHz

Weight(with 

Radiators)

35g

20
PROPELLER 

(FOLDABLE)

Material Size Weight

Carbon Fiber 15×04in 10g

21
APPENDIX C

EXEMPTION REQUESTS

WITH REASONS FOR REQUESTS AND EQUIVALENT LEVEL OF SAFETY

ComEd requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the DJI S900:

Part 21 Airworthiness Certification

14 CFR Part 21, Subpart H Airworthiness Certificates and 14 CFR 91.203(a)(1) Civil aircraft. 

Certifications required.

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (8.2 kg; 18 lbs) 

and the limited operating area associated with its utilization, it is unnecessary to go through the certificate 

of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA 

to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the sUAS involved.

In this case, an analysis of these criteria demonstrates that the DJI S900 operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The DJI S900 weighs 8.2 kg (18 lbs) It 

will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an 

area pre-disclosed (and detailed on ComEd’s Certificate of Authorization) and in compliance with 

conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by 

both the operator, pursuant to the conditions set forth above, and by local public safety requirements. 

Notification of affected municipalities, the size of the aircraft, the lack of flammable fuel, and the fact that 

the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The 

DJI S900 provides at least an equivalent, and most likely exceeds, level of safety to that of such 

operations being conducted with conventional aircraft that would be orders of magnitude larger and 

would be carrying passengers, cargo, and flammable fuel. 

The automated safety features highlight the design intentions towards safety and reliability on the DJI 

S900.

22
Part 43 Maintenance

14 CFR 43.7 Persons authorized to approve aircraft, airframes, aircraft engines, propellers, 

appliances, or component parts for return to service after maintenance, preventive maintenance, 

rebuilding, or alteration.

This section lists seven different persons who may sign return-to-service documentation, approving 

aircraft and affected components for service after maintenance, preventive maintenance, rebuilding or 

alteration:

1) Certified mechanic or holder of an inspection authorization.

2) Holder of a repair station certificate.

3) Manufacturer.

4) Holder of an air carrier certificate.

5) Certificated private pilot.

6) Repairman certificated with a maintenance rating for light sport aircraft only.

7) Certificated sport pilot for preventive maintenance on an aircraft owned and or operated by him or 

her.

Besides the DJI S900 being nearly maintenance free, the nature of sUAS technology (such as inherent 

safety features) provides for decisions about return-to-service following maintenance and/or related 

activities to be made with minimal risk by persons well trained in the technology (whether any of the 

above seven criteria exist or not).

The DJI S900 performs automatic pre-flight checks and the failure of any check will prevent take-off. 

Checks that cannot be performed by the system will be performed by a qualified person prior to each 

flight and include the following:

• A full visual inspection of the airframe.

• Visual inspection of rotor integrity.

• Charge of all batteries (sUAS, command station and radio repeater station)

14 CFR 43.11 Content, form and disposition of records for inspections conducted under parts 91 

and 125 and 135.411(a)(1) and 135.419 of this chapter. 

This section deals with inspection record entries for aircraft, including a requirement that these records 

contain the following information:

• Certificate numbers for the inspectors.

• Kind of certificates for the persons approving or disapproving the return to service.

As referenced in the exemption request for 14 CFR 43.7, the DJI S900 is nearly maintenance free. The 

nature of sUAS technology (such as inherent safety features) provides for decisions about return-toservice following maintenance and/or related activities to be made with minimal risk by persons well 

trained in the technology (whether the person making decisions about return-to-service hold a certificate 

or not).

23
Likewise, all persons inspecting the sUAS will have successfully completed training for such activity, 

making them at least as proficient as certificated inspectors.

Part 45 Identification and Registration Marking

14 CFR 45.11 Marking of products.

This section requires the securing of a fireproof marker on the aircraft fuselage exterior so it is legible to 

persons on the ground. Also, the requirement continues that propellers, propeller blades and hubs must 

receive markers.

While the sUAS will involve flight at only 400 feet AGL and within line of site of the pilot, it is not 

feasible that markers described in this section will be legible from the ground given the sUAS and sUAS 

component sizes:

• sUAS width = 900 mm (35.4 in.)

• sUAS height = 460 mm (18.1 in.)

• Propeller length = 381 mm (15 in.)

Further, marker required locations are in some cases non-existent on the battery-powered DJI S900 (i.e., 

aircraft fuselage). Additional specifications are detailed on Appendix B (S900 Specifications). ComEd 

will fulfill any reasonable request by the FAA related to the identification and registration marking of the 

sUAS.

14 CFR 45.23(b) Display of marks; general and 

91.9(c) Civil aircraft flight manual, marking, and placard requirements.

Regulation 45.23(b) provides:

(b) When marks include only the Roman capital letter “N” and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.

Regulation 91.9(c) provides:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with 

part 45 of this chapter.

The DJI S900 has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. 

Given the size of the sUAS, two inch lettering will be impossible. Official marking systems for sUASs 

have not yet been established for operations inside the NAS. ComEd is prepared to fulfill any request by 

the FAA related to identification and registration marking in accordance with 45.29(f) where the pilot, 

observer, and others working with the sUAS will see the identification of the sUAS.

The FAA has issued the following exemptions to this regulation: Exemption Numbers 8738, 10167, 

10167A and 10700.

24
14 CFR 45.25 Location of marks on fixed wing aircraft.

This section requires that operators display marks “...on either the vertical tail surfaces or the sides of the 

fuselage.” As referenced in the exemption request for 14 CFR 45.11, this marking requirement is not 

feasible given the size of sUASs. Also note that the DJI S900 does not contain a fuselage.

14 CFR 45.29 Size of marks.

This section provides requirements for the size of aircraft markings; however, marking requirements for 

sUASs are not specifically listed. Instead, aircraft types referenced in this section include fixed-wing, 

gliders, exhibition, antique, airships, spherical balloons, powered parachutes, etc.

As referenced in the exemption request for 14 CFR 45.23(b) and 91.9(c), ComEd is prepared to fulfill any 

request by the FAA related to identification and registration marking of the sUAS.

Part 47 Aircraft Registration

14 CFR 47.3(b)(2) Registration required.

This section prohibits the operation of aircraft that is eligible for registration unless 1) the aircraft has 

been registered by its owner; 2) the aircraft is carrying aboard the temporary authorization required by 

47.31(c); or 3) the aircraft is an aircraft of the Armed Forces.

Unless the sUAS ground control station is considered part of the sUAS, ComEd requests exemption from 

requirement number two above. While it is feasible to maintain the aircraft registration document at the 

ground control station, it is not feasible for the sUAS to carry the registration document ‘on board’ (given 

the size of the sUAS, as summarized in exemption request 14 CFR 45.11).

14 CFR 47.31(c) Application.

This section requires that each applicant for a Certificate of Aircraft Registration, after completing and 

submitting the application, submitting the aircraft bill of sale and paying the required fee – must comply 

with paragraph c: 

“...the applicant for registration of an aircraft last previously registered in the United States must carry 

the second copy of the Aircraft Registration Application in the aircraft as temporary authority to operate 

without registration.”

ComEd does not possess an aircraft that was previously registered in the United States, making the 

referenced requirement in this section infeasible.

Part 91 General Operating and Flight Rules

14 CFR 91.9(b)(2) Civil aircraft flight manual, marking and placard requirements.

This section prohibits operation of a U.S.-registered civil aircraft for which a flight manual is not 

required, unless there is “...available in the aircraft a current approved Airplane or Rotocraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof.”

As per the size of the sUAS, provided in exemption request 14 CFR 45.11, it is not feasible to make a 

manual and associated materials available in the aircraft.

25
14 CFR 91.9(c) Civil aircraft flight manual, marking and placard requirements.

This section prohibits operation of U.S.-registered civil aircraft without identification specified in part 45.

As stated in the exemption requests specific to part 45:

• It is not feasible that markers described in this part will be legible from the ground.

• Marker required locations are in some cases non-existent on the battery-powered DJI S900 (i.e., 

aircraft fuselage, cabin, cockpit, etc.).

ComEd is prepared to fulfill any request by the FAA related to identification and registration marking of 

the sUAS.

14 CFR 91.103(b)(2) Preflight action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will 

be needed. An equivalent level of safety will be provided as set forth in the DJI S900 Operating Manual 

(Appendix H). The person-in-charge will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

The Aerial Inspection Flight Briefing Sheet in Appendix G provides additional required pre-flight actions.

14 CFR 91.105 Flight crewmembers at stations.

This section contains requirements for crewmembers during takeoff and landing of aircraft. Specifically:

(a) During takeoff and landing, and while en route, each required flight crewmember shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in 

connection with the operation of the aircraft or in connection with physiological needs; and 

(2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and 

landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This 

paragraph does not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or 

(2) The crewmember would be unable to perform required duties with the shoulder harness 

fastened. 

In any sUAS, the ‘crewmember station’ is separate from the actual aircraft (such as a station established 

on the ground). Therefore, compliance with the seat belt and shoulder harness requirements are not 

feasible. Also, members of the crew (such as operators and observers) may reside in separate 

crewmember stations during takeoff and landing of the aircraft (for purposes of safely navigating the 

aircraft). Therefore, compliance with ‘a(1)’ may involve identification of multiple crewmember stations.

26
14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight tests and 

91.319(a)(1) Aircraft having experimental certificates: Operating limitations.

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls.

The DJI S900 is a remotely piloted aircraft and by design, does not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the aircraft via 

radio communications. The flight plan is manually controlled through point-and-click navigation. The 

FAA has approved exemptions for flight training without fully 11 of 20 functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 

9862A. 

The equivalent level of safety will be achieved through prudent use of manufacturer training materials and 

through the use of licensed and qualified pilots familiar with the DJI S900.

14 CFR 91.113(b) Right of way rules: Except water operations.

This section addresses the vigilance required during aircraft operations to see and avoid other aircraft by 

prohibiting aircraft from “...passing over, under, or ahead of...” aircraft that has the right-of-way (until 

the area is clear), weather permitting.

sUASs are not specifically listed in this section to clarify the right-of-way priority for this type of aircraft. 

Also, while sUASs may technically pass under or ahead of other aircraft, safety protocols have been 

established to mitigate risks associated with contacting other aircraft and they include the following:

• Notification to impacted municipalities about flight plans (as shown in the Mandatory Operating 

Requirements (#27).

• Operation of the sUAS may not be in Class B, C, or D airspace without written approval from the 

FAA, and must be below 400 feet AGL at all times. 

• Operation of the sUAS during daylight hours, within visual line of sight and during Visual Flight 

Rules Meteorological Conditions.

Additional precautions designed to help ensure safe operation of the sUAS can be found in the Mandatory 

Operating Conditions section of this document and in the Certificate of Authorization application.

14 CFR 91.115 Right of way rules: Water operations.

This section provides requirements for operating aircraft on the water (to keep clear of and to avoid 

impeding the navigation of any vessel). 

ComEd does not intend to operate aircraft on any body of water as part of this petition.

14 CFR 91.119(b)(c) Minimum safe altitudes: General.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure.

27
As set forth herein, the DJI S900 will not operate at higher than 400 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are detailed on ComEd’s Certificate of Authorization 

application. Because many electric utility system condition inspections must be accomplished at relatively 

low altitudes and at altitudes less than 400 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the 

DJI S900 is built. Also, no flight will be taken without notification to affected municipalities. Because of 

the advance notice, all affected individuals will be aware of the flights. Compared to aerial inspection 

operations conducted with aircraft or rotorcraft weighing far more than 8.2 kg (18 lbs) and carrying 

flammable fuel, any risk associated with these operations will be far less than those currently allowed 

with conventional aircraft operating at or below 400 AGL. The low altitude operations of the sUAS will 

maintain separation between sUAS operations and the operations of conventional aircraft that must 

comply with Section 91.119.

14 CFR 91.121 Altimeter settings.

This section requires that each person operating an aircraft maintain cruising altitude by reference to an 

altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available 

before departure.”

As the DJI S900 does not have an altimeter, ComEd requests an exemption from this requirement. An 

equivalent level of safety will be achieved according to guidelines outlined in the Operating Manual 

(Attachment H) and will include confirmation of GPS signals, the Moving Map Indicator and tracking 

capability from the ground control station. Also, because all operations are within 400 feet AGL of the 

ground and clear of the airspace used by most aircraft, this procedure ensures an increased level of safety.

14 CFR 91.151 Fuel requirements for flights in VFR conditions.

This regulation prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The DJI S900 batteries provide approximately 18 minutes of powered flight, and the enclosed cage to be 

tested around the sUAS by the Illinois Institute of Technology may prove to effectively extend sUAS 

battery life. Without an exemption from 14 CFR 91.151, the sUAS’ flights would be limited to 

approximately 20 minutes in length. Given the limitations on its proposed operations and the location of 

those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable.

ComEd believes that an exemption from 14 CFR 91.151 is safe and within the scope of a prior 

exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance 

with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel does not engender the type of 

risks that Section 91.151 was meant to prevent given the size and speed at which the sUAS operates. The 

fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting DJI S900 

flights to 20 minutes would greatly reduce their utility. In the unlikely event that the DJI S900 should run 

out of fuel (battery power), it would land. Given its weight and construction material, the risks are less 

than contemplated by the current regulation.

28
ComEd believes that an equivalent level of safety can be achieved by maintaining reserve battery power 

to return the sUAS to its planned landing zone from anywhere in its prescribed and controlled operating 

area.

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808.

14 CFR 91.203 (a)(1) and 91.203(a)(2) Civil aircraft: Certifications required.

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and current airworthiness 

certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of 

this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The DJI S900 weighs approximately 8.2 kg (18 lbs) As such, there is no ability or place to carry 

certification and registration documents or to display them on the sUAS. In addition, there is no pilot on 

board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes the following 

Exemption Numbers: 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

And it is ComEd’s understanding that the ground control point may be considered part of the sUAS; 

thereby anything displayed at this location is technically consistent with this requirement and possibly not 

necessary from which to seek exemption.

14 CFR 91.215 ATC transponder and altitude reporting equipment and use.

This section prohibits operation of aircraft without a transponder in certain airspace.

Exceptions are provided for aircraft “...not originally certificated with an engine-driven electrical system 

or which has not subsequently been certified with such a system installed, balloon, or glider....” The DJI 

S900 does not have an “engine-driven electrical system,” so these exemptions apply.

Operational safety will be further improved because, in lieu of being equipped with a transponder, the DJI 

S900 will comply with all mandatory operating conditions specified in this document (and the Certificate 

of Authorization application), including the following:

• Operation of the sUAS may not be in Class B, C, or D airspace without written approval from the 

FAA, and must be below 400 feet AGL at all times. 

• Operation of the sUAS during daylight hours, within visual line of sight and during Visual Flight 

Rules Meteorological Conditions.

• See and Avoid coverage by both the qualified pilot and the qualified observer throughout 

operations.

29
14 CFR 91.403 General. 

This section provides requirements for maintenance in reference to several parts including part 39 

(Airworthiness Directives), part 43 (Maintenance) and part 121 (Altimeter settings).

Given that the following requirement: “(a) The owner or operator of an aircraft is primarily responsible 

for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter” 

appears to only apply to aircraft with airworthiness certificates, the requirement does not apply to the 

operation of the DJI S900.

Given that the following requirement: “(b) No person may perform maintenance, preventive maintenance, 

or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, 

including part 43 of this chapter” appears to apply to aircraft with complicated maintenance needs, the 

requirement does not apply to the maintenance of the DJI S900 (which is nearly maintenance free). 

Appendix H (the Operating Manual) contains maintenance instructions for the DJI S900 and it illustrates 

some of the safety features inherent to this technology and how they provide for decisions about return to 

service following maintenance and/or related activities.

14 CFR 91.405 Maintenance required, 91.407 Operation after maintenance, preventive 

maintenance, or alteration, 91.409 Inspections, and 91.417 Maintenance records.

Section 91.405(a) requires that an aircraft operator or owner “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 ...”

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an 

annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or 

operator to keep records showing certain maintenance work that has been accomplished by certificated 

mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

The DJI S900 is nearly maintenance free, it performs automatic pre-flight checks and the failure of any 

check will prevent take-off. Checks which cannot be done by the system will be performed by a qualified 

person prior to each flight and at predefined intervals as part of the maintenance schedule in the Operating 

Manual (see Appendix H).

Pre-flight checklist includes:

1. Visual inspection of the airframe

2. Visual inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external 

payload, will operate only in restricted pre-selected areas and is not a complex mechanical device. As 

provided in the attached Operating Manual (Appendix H), the operator of DJI S900 will ensure that the 

sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any 

30
maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is 

best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.

The DJI S900’s maintenance instructions (Appendix H) ensure an equivalent level of safety to the 

maintenance requirements in Part 91. In addition, any component failure detectable by the system will be 

reported to the control station and will cause the sUAS to perform a Fatal Condition Response (FCR) or 

Nonfatal Conditioned Response (NFCR), depending on the type of failure.

31
APPENDIX D

‘ComEd Job Briefing and Job Turnover Process’

Consistent with exemption applications already granted, and in the best interest of promoting 

public safety, we are submitting this document confidentially

32
APPENDIX E

‘Personal Protective Equipment Program’

Consistent with exemption applications already granted, and in the best interest of promoting 

public safety, we are submitting this document confidentially

33
APPENDIX F

‘Time Out for Safety Process’

Consistent with exemption applications already granted, and in the best interest of promoting 

public safety, we are submitting this document confidentially

34
APPENDIX G

STAR – Stop – Think – Act – Review

COMED UAV AERIAL INSPECTION FLIGHT BRIEFING SHEET

STAR – Stop – Think – Act – Review

Work Order#: ______________________ Date: ____________________

Obsr__________________________ Ph # (___) ________________ Email ___________________

TSO Approval Received PRE flight Notifications made POST flight Notifications made

Pilot: ______________________ Ph # (___) _________________

 Preflight Inspection Comp

 Crew briefed on safely

 Checked Weather Checked for TFRS in flight path Safe to fly FAA Waiver Received N/A

Insp: ______________________ Data Rec: ___________________ Launch Site: Elevation (MSL): ___

 Crew Chief

Ph # (___) _________________

 Crew Chief

Ph # (___)_________________

Lat: __________ Long: ____________

Max Expected Alt. (AGL):__________

Flight Descr./ Overview: ___________________________________________________________________________________

________________________________________________________________________________________________________

Inspection Type Codes: STandard Comprehensive SPecial Emergency

LINE

INSP

TYPE

CRITICAL

FND / REP LINE

INSP

TYPE

CRITICAL

FND / REP LINE

INSP

TYPE

CRITICAL

FND / REP LINE

INSP

TYPE

CRITICAL

FND / REP

Nearest 

Airports: Miles: _____ Code: ____ Name: ____________ Contact: ___________ Phone #: __________ Briefed:

 Miles: _____ Code: ____ Name: ____________ Contact: ___________ Phone #: __________ Briefed: 

Miles: _____ Code: ____ Name: ____________ Contact: ___________ Phone #: __________ Briefed: 

Police Notification:

Community:__________ Department: _______ Contact: ___________ Phone #: __________ Briefed: 

Weather: In area of Inspection ___________________________________________________________________________________________________

Crew: Understand Crew Resource Management UAV Safety Rules Understand Flight duties Equipment

Equipment checked and determined to be in safe, working condition

UAV Flight Controls Camera Systems Batteries ____________ ______________

 MAPS: Line and SM Current Structure Lists Work Package Structure List for Comprehensive 

Inspections

Discussed: Inflight special precautions __________________________ Communication ________________________________________

Flight obstructions __________________________________ Job assignments ______________________________________

Situational awareness _______________________________ Line-of-fire control _____________________________________

Post Flight: Reports completed and submitted Equipment cleaned, checked and properly stored

ACTION REQUIRED: Every Crew Member is expected to be able to explain the details of the Flight Briefing

POST FLIGHT DEBRIEFING: Yes CONDITION / SCOPE CHANGE: Yes N/A

Completed at the end of each shift! Job Scope Change necessitates conducting a NEW Job Brief! 

Comments GIVE DETAILS: ____________________________________________________________________________

______________________________________________________________________________________________

Supervisor Quality Review of Job Brief (Initials) Date: 

LEGIBLE EMPLOYEE INITIALS

1ST BRIEF 2ND BRIEF

35
APPENDIX H

‘DJI Innovations S900 Specifications’

See link for online manual and operating videos:

http://www.troybuiltmodels.com/items/DJI-S900.html

PILOT OPERATING HANDBOOK

DJI S‐900/Zenmuse

Author: Gene Payson Revised: 9/02/2014

http://www.troybuiltmodels.com

PILOT OPERATION HANDBOOK

DJI S-900/Zenmuse

This book is offered in a format so that pilots can customize the checklists to their exact needs. Please print 

out this handbook, make notes while watching the video regarding the checklist, then change the wording 

and order to suit your needs. Then print out the revised form and laminate it in plastic. Use it every time you 

operate your aircraft. Keep the log books regarding the following:

• Pilot flight time

• Aircraft flight time

• Aircraft maintenance and updates

• Battery usage, date put into service, voltage, mah vs time

Print out and make readily available the error message legend of various flashing lights. Know what to do 

without hesitation should you observe warnings.

Insurance is a must! Not only will it be expensive to repair your aircraft in the event of an incident, if you 

injure bystanders or damage other people’s property you are liable for damages which could run into the 

millions of dollars. One insurance company which currently writes policies on sUAS is 

www.Transportrisk.com

Errors & Omissions should be sent to customerservice@troybuiltmodels.com. We will promptly update the 

POH for everyone to have the latest updates available.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

36
DJI S900 KEY PARAMETERS

Max Takeoff Weight: 18 lbs.

Approved Cameras: Sony Nex5/7, Panasonic GH3/4, Blackmagic Cinema

--- No Gimbal

13.5lbs = S900 NO Gimbal and TBM 21000

12.3lbs = S900 NO Gimbal and TBM 15000

--- Nex-7 Gimbal

17.2lbs = S900 with Nex-7 and TBM 21000

16lbs = S900 with Nex-7 and TBM 15000

--- GH3/GH4 Gimbal

17.68lbs = S900 with GH3/GH4 and TBM 21000

16.48lbs = S900 with GH3/GH4 and TBM 15000

--- BMPCC Gimbal

17.3lbs = S900 and TBM 21000

16.1lbs = S900 and TBM 15000

--- 5D Gimbal

22.5lbs = S900 and TBM 21000 - OVERWEIGHT!

21.3lbs = S900 and TBM 15000- OVERWEIGHT!

Flight Times using 90% of battery:

15,000 mah battery with gimbal and camera: 15+ min 

21,000 mah battery with gimbal and camera: 20+ min

These times are averages in our tests. Individual flight times may differ based on weight and flying style.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

DJI S-900/Zenmuse

CHECKLISTS • DJI S-900 BENCH SET UP & TESTS

o All screws/bolts are tight

o Timer alarm for flight time to not exceed 80% battery capacity set properly

o Batteries are secure

o Antennas are secure

o Props balanced

o Props aligned

o Props not chipped

o Check blades, arms, etc. for cracks/damage

• Wiring Tight

• No excessive flexing of motors or booms

• Booms/motors will not twist

• Center of gravity is correct

• Warning lights set for low battery if used

• Batteries charged. Replace any battery which cycles below 80% of rated capacity

• Laptop Battery

• Flight Battery

• Handheld Rx Battery

• RC Tx Battery

37
• Video Rx Battery

• Spare Laptop Battery

• DJI S-900 INVENTORY CHECKLIST

o Load Flight plan

o Aircraft

o Camera with SD card

o Spare parts/tools

o Spare batteries

o Two RC transmitters

o Laptop

o Battery Charger

o Flight Controller Cable

o Video monitor, stand, battery, antennas

o Goggles

o Datalink & cable

o Battery Y-harness

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• DJI S-900 PREFLIGHT CHECKLIST

o Position: GCS, S900

o Emergency LZ

o Wind

o Area secure

o Antennas

o GCS

o Lens cap

o Camera On

o SD card

o Flight battery: voltage – install - CG

o C2 Tx: Switches – On - Model Selection - 5.4V+

o Photo Tx – Switches – On - Model Selection - 5.4V+

o Copter On

o Calibrate? - Cycle

o Copter Voltage on GCS

o GPS Mode – Double Purple/Single Purple

o Course Lock Mode - Green

o Camera/Gimbal tests

o Upload mission

o Zero altitude

• TAKEOFF CHECKLIST

o Timer

o GPS mode (Course lock?)

o Motor startup/checks

o Takeoff

o Landing Gear

• LANDING CHECKLIST

o LZ clear

o Landing Gear

o Land

o Flight Time

o Copter/Camera Power down

38
o Adjust Params

o Power Down batteries

o Motor Temps

o Logbooks

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• ERROR MESSAGES

o White flashes

• IMU malfunction. Land and determine cause. Possibilities:

• GPS/Compass not pointing forward

• IMU not pointing forward

• Set up of X, Y, Z for location of IMU and Compass is incorrect

o Excessive rocking/instability possible causes:

• Weak motor

• Structure flexing from fatigue or cracks

• Motor mount

• Main frame

• Booms

• Loose Bolts causing flexing or misalignment

• Props

• Mounts

• Props out of balance

• Props misaligned

• Excessive wind speeds or gusts

• Excessive Gains

• Excessive motor power. Max motor power must a little more than typical ascent 

power.

o Red Flashes (1, 2 or 3 flashes with pauses) – GPS loss (3 is more serious). Land if loss lasts 

for more than 30 seconds. Possible causes:

• Clouds

• Structures

• GPS mal-function

• GPS too close to electrical components

• GPS vibration

• © 2014 Troy Built Models, Inc. All Rights Reserved.

TABLE OF CONTENTS

• Section 1: General

• Section 2: Limitations

• Section 3: Emergency Procedures

• Section 4: Normal Procedures

• Section 5: Performance

• Section 6: Weight and Balance/Equipment List

• Section 7: Air Vehicle and Systems Description

• Section 8: Handling, Service and Maintenance

• Section 9: Supplements

• © 2014 Troy Built Models, Inc. All Rights Reserved.

39
SECTION 1

GENERAL

NOTE: In an effort to minimize costs and maximize spare parts availability, many COTS (commercial off 

the shelf) components have been utilized. Some may have slight modifications to better suit this application. 

Most COTS products have separate data sheets, assembly manuals and instruction manuals. They are 

reference in this document, with key factors being emphasized.

As with all high technology products utilizing constantly evolving software, it is important to periodically 

check for online upgrades to the COTS components, including hardware, firmware and software.

WARNING: Great care must be taken with the batteries. Much of this manual and supplemental information 

is devoted to the use and care of the batteries, especially the flight batteries. They are less volatile than 

gasoline, though they should be treated with the same respect. Become very familiar with proper techniques 

of their use.

• GENERAL CHARACTERISTICS

• Primarily for ISR (Intelligence, Surveillance, and Reconnaissance)

• Economical due to extensive use of COTS products

• Low Visual Signature

• Low Aural Signature

• Quick Launch and Recovery

• Short Training Period

• Simple Operation

• Waypoint Navigation

• Backpackable

• VTOL

• Quick Repairs

• Redundant Flight Systems

• Safety Return to Home during lost link or low battery

• High Degree of Mission Success

• GPS navigation aid

• Various sensors

• 18 lb max takeoff weight

• Operating Temp Range: -5°C to +60°C

• Flight Modes: Manual and GPS aided waypoint navigation

• Maximum Operating Altitude: 1000 meters

• Maximum Operation Wind Conditions: 10 m/s

• Propulsion System: LiPoly batteries

• Takeoff: Manual or Automatic

• Landing: Manual or Automatic

• Takeoff/Recovery Area: 5m square

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• IMPORTANT DIMENSIONS

o Distance rotor to rotor across the center: 35” 

o Height with GPS/Compass folded down: 21” 

o Height with GPS/Compass up: 25”

o Length of landing gear skids: 17”

o Distance between landing gear skids: 18”

o Collapsed size: 22” x 19”

40
• IMPORTANT WEIGHTS

o --- No Gimbal

o 13.5lbs = S900 NO Gimbal and TBM 21000

o 12.3lbs = S900 NO Gimbal and TBM 15000

o --- Nex-7 Gimbal

o 17.2lbs = S900 with Nex-7 and TBM 21000

o 16lbs = S900 with Nex-7 and TBM 15000

o --- GH3/GH4 Gimbal

o 17.68lbs = S900 with GH3/GH4 and TBM 21000

o 16.48lbs = S900 with GH3/GH4 and TBM 15000

o --- BMPCC Gimbal

o 17.3lbs = S900 and TBM 21000

o 16.1lbs = S900 and TBM 15000

o --- 5D Gimbal

o 22.5lbs = S900 and TBM 21000 - OVERWEIGHT!

o 21.3lbs = S900 and TBM 15000- OVERWEIGHT!

• MOTORS

o Manufacturer: DJI-Innovations

o Number of motors: 8

o Motor type: 41mm x 14mm

o Motor Model Number: 4114-11

o Motor KV/RPM: 400

o Motor max @ 25.2V: 10,000 rpm

o Motor Max Power: 500 Watts

o Power rating: 3000 Watts maximum power consumption for all 6 motors

o Current Max: 100 amps

o Amp Draw Typical Average: 55 amps

• PROPELLERS

o Manufacturer: DJI-Innovations

o Material: Composite

o Number of propellers: 6

o Propeller model number: DJI 15 x 5.2

o Number of blades: 2 - folding

o Propeller Diameter: 15”

o Propeller Pitch (fixed): 5.2”

o Max rpm: 10,000 rpm

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• ELECTRONIC SPEED CONTROLS

o Manufacturer: DJI-Innovations

o Number of speed controls: 6

o Speed control model number: DJI 40A Opto

o Rating in amps: 40 Amps continuous

o Signal Frequency: 30 - 450 Hz

o Drive PWM Frequency: 8 KHz

• AUTOPILOT

o Manufacturer: DJI-Innovations

o Autopilot Model Number: DJI A2

o Components: GPS/Compass, IMU, Master Controller, Power Distribution System, LED

Indicator Lighting System, Data Transceiver, GCS Software

41
o Power Consumption: 5W

o Operating Temp Range: -5°C to +60°C

o Software Compatible: Windows XP sp3 / Windows 7

o Hovering Accuracy: Vertical : ± 0.5m; Horizontal: ± 2m

• ANALOG WIRELESS LINKS

o Distributor: DJI-Innovations

o Frequencies:

• 2.4 Ghz datalink with WiFi

• 2.4 Ghz Command & Control

• 5.8 Ghz Video

o Power Consumption: <1 watt

o Usable Range: <2 km.

• DIGITAL WIRELESS LINKS (Lightbridge)

o Distributor: DJI-Innovations

o Frequencies:

• 2.4 Ghz (C2 & Video)

o Power Consumption: <1 watt

o Usable Range: <2 km.

• FLIGHT BATTERY

o Manufacturers: Various COTS suppliers

o Battery chemistry recommended: Lithium Polymer

o Battery Capacity: up to 21,000 mah or greater depending on max gross weight

o Battery cell count required: 6S (6 cells in series)

o Battery Voltage: 21V minimum during hover, 22.2V nominal, 25.2V maximum

o Battery Minimum Rated Discharge Rate: 20C minimum

o Battery Minimum Charge Rate: 1C (3C preferable)

o Battery Rest Time between discharging and charging: 0-30 minutes

o Batteries used simultaneously: typically 1

o Recommended Battery Discharge Amount: 80-90%

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• FLIGHT PARAMETERS

o Flight Time: 20+ minutes typical

o Payload Max: 9.5 lbs for battery, sensor and gimbal

• WARNINGS

o Never power a video transmitter or receiver without an antenna connected or overload failure 

will occur.

o Read all information regarding batteries contained in this manual and supplements.

o Batteries are highly flammable and can explode, especially when fully charged. Improper

charging, vibration, impact, high discharge, etc. can lead to explosion and fire. Batteries must

be charged under constant supervision and using proper precautions.

o Batteries fully charged must be handled with extreme care.

o Batteries must not be stored above 60% charged state.

o Store batteries between 20% - 60% charged state. Fully charge just before use.

o Fully charged batteries which are not to be used within 24 hours should be discharged to 20%

- 50% charged state.

o Discharging LiPoly batteries in excess of 80% of their rated capacity can cause harm to the 

batteries.

42
o Using more than one battery at a time requires the proper wiring harness so that the voltage is 

no more than 25.2V. Over voltage will cause serious damage to electrical equipment.

o Using more than one battery at a time requires weight and balance checks. Proper CG is 

critical to performance. Airframe must not be overloaded.

o GPS/Compass must be facing forward.

o Do not use GPS Mode without GPS lock.

o Use low strength thread locking compound on all screws.

o Wireless Video and Data ranges vary considerably on many factors including weather,

equipment, and obstructions. Be prepared for com failures.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

SECTION 2

LIMITATIONS

• AIRSPEED LIMITATIONS

o Vne – Velocity to Never Exceed: 15 m/s

o Va – Typical Maneuvering Speed – 5 m/s

• POWER & POWERPLANT LIMITATIONS

o 40 Amps max per motor

o 40 Amps max per speed control

o 320 Amps max total

o Do not exceed 80-90% discharge of rated battery capacity

o Do not charge batteries which are warmer than air temperature

o Allow batteries to cool after use before charging

o Leave an air gap between batteries when multiple batteries are used simultaneously

• WEIGHT LIMITS

o Takeoff Weight Max: 18 lbs

• Must be checked prior to takeoff if any change in equipment is made

• CENTER OF GRAVITY LIMITS

o 3mm from the center of any of the three pairs of arms

• Must be checked before every flight to ensure batteries were installed in the proper

location.

• Check all 4 pairs of arms before flight

• MANEUVER LIMITS

o This aircraft is intended for non-aerobatic operations

o G-loading maximum: 2G

• TEMPERATURE LIMITS

o Operating Temp Range: -10°C to +40°C

o In cold temperatures

• Keep IMU at room temperature if possible before the flight

• Keep Batteries above 5°C before flight

• Do not fly with any frost or ice on the propellers

o In warm temperatures

• Batteries heat up when discharged

• The higher the discharge rate the higher the temperature increase during use

• At temperatures above 45°C, use of 2 or more batteries is required to lower the load 

on any one battery pack to keep it cooler.

43
• WEATHER LIMITS

o Light dust and light rain require the use of a shield for the electronics in the center section.

o Light dust and light rain are acceptable for the unshielded motor and ESC.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• RANGE LIMITS

o FUEL

• Fuel capacity is a primary limiting factor.

• Flying into the wind will use more battery power to travel the same ground distance.

Higher air speeds will be required to penetrate the wind which used more battery 

power. Take this into account when flying a mission.

• Where possible, fly upwind at the start of a mission and downwind at the end to avoid 

depleting the battery before returning to base. Have alternative landing sites available 

in case of emergency landing.

o WIRELESS LINK

• Wireless links will be stable in LOS (line of sight) in most conditions

• Wireless links are always susceptible to shorter ranges due to

• Atmospheric conditions

• Other transmission devices in the area

• Jamming

• Antennas not aligned properly

• Improper voltage

• Antenna blockage from AV in certain positions

• Multipath – reflection off buildings or ground which cause multiple signals to 

arrive at different times and/or phase.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

SECTION 3

EMERGENCYPROCEDURES

• MOTOR FAILURE

o Operation is possible with one motor/ESC/propeller failure

• The two adjacent motors/ESCs will be increased in thrust automatically by the flight

controller to overcome the loss

• In cases where the airframe is highly loaded the maximum rating of 40 amps may be 

exceeded by these two motors/ESCs

• Operation should be terminated as soon as possible to reduce the possibility of damage 

to the remaining motors

• COMMUNICATION FAILURE

o Video link failure

• 5.8 Ghz being the shortest wavelength in general AV use has the least ability to

penetrate. This link should be the first to be lost.

• It is best to lose video first! It is the least likely to cause a crash when it fails.

• 5.8 Ghz can lose link with little warning.

• Ensure that the GCS station antennas are perpendicular to the AV. Do not point the 

antenna at the AV.

• Yaw the AV to change the antenna position

• Other links should still be good. Return back to the GCS until link is restored.

44
• Transmitters produce heat when in operation. When overheated they may have 

thermal protection which interrupts use temporarily. Use of a heat sink or fan may be 

required especially with high ambient temperatures.

• Higher gain antennas may be used, but do so with caution. High gain antennas are 

directional.

• Multiple antennas using “diversity” can be used. Diversity is a device which 

determines the best signal, and uses that.

• 5.8 Ghz even at high wattages theoretically has less range than lower frequencies.

Changing to 1.3 Ghz is an option, though there are other issues to be considered.

o RC link failure

• 2.4 Ghz antennas can lose link with little warning.

• Anything in between the two antennas can cause temporary signal loss especially a 

person.

• Hold the transmitter up in the air and walk in the general direction of the AV (aerial 

vehicle).

• Ensure that the antenna is vertical. Do not point the antenna at the AV.

• The failsafes on the RC link should be set so that the AV returns to home. Should this 

require a heading change, the antenna may move into a more desirable position and 

link will be restored.

• The onboard equipment may block the signal. Yaw the AV so that the antennas point 

towards the GCS.

• A LRS (long range system) can be used as a permanent solution. This is higher in 

wattage and usually on 433 Mhz.

o Data Link Failure

• 900 Mhz do not lose link without some warning. When drop outs are noticed to

increase in frequency that is the limit of the range.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• If using 900 Mhz, this is on cell phone frequency. If a cell tower is nearby it can 

swamp the signal. 900 Mhz may not be usable in that area. Change to a different freq. 

or remain closer to the AV

o LOW BATTERY POWER

 Fail-safes can be set such that in the event of low battery power, either due to a failure

or too long of a flight, the warning light on the AV will constantly flash amber. This is 

the first level of warning.

 The second warning level is red flashing lights

 Auto landing will occur when battery power is low. It may land in a tree or a lake, so 

this is not desirable.

 Landing with 80-90% of battery depleted is best. Therefore landing with 17,000 mah 

used and 3,000 mah remaining of a 20,000 mah battery is desirable. Batteries should 

be drawn down equally when in use if they are both charged equally and both in 

relatively the same condition/age.

 Do not mix partially charged batteries. Only use completely charged batteries.

 Over discharging a battery below 19.8V can permanently damage the battery.

o GCS FAILURE

 Takeover by the external pilot should happen ASAP using the RC link.

 Most often happens due to a low battery.

 Keep a spare 3 cell LiPoly battery with the appropriate plug to plug into the charge 

jack for emergency use. Most chargers are 19V output which is roughly equivalent to 

a 4-cell battery. 3-cell batteries may work.

45
o COMPASS CALIBRATION ERROR

 If the compass is out of calibration the warning light will flash red. This is the same

signal as low voltage. If the voltage is correct, there is a calibration error.

 Recalibrate the compass following the instruction manual

o FIRE

 Fires can occur due to a short circuit or battery failure.

 Disconnect the battery ASAP unless there is danger in doing so if there is any 

electrical issue.

 It is not possible to put out a battery fire.

 Do not attempt to put out a battery fire. Use a fire extinguisher to put out fires 

surrounding the battery. A CO2 fire extinguisher is better than the powder or chemical 

type. CO2 does not leave a residue. Water can be used though it may cause other 

electrical component failures.

o FORCED LANDINGS

 If alternate emergency landing zones should be chosen ahead of time.

 Be sure that the LZ is clear of people to avoid any incidents.

 Land in the nearest LZ which is clear of people.

 Announce your intentions of landing as loud as necessary to alert people of the 

incoming AV.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

SECTION 4

SET UP SUGGESTIONS

• ELECTRONICS BURN IN

o We recommend that you put weights onto the landing skids to keep the copter on the ground 

and run the copter at about 70% throttle for about 2 hours to burn in the electronics. Most 

electronic failures occur in the first 2 hours of operation.

• GPS/COMPASS MAST LENGTH

o We found that the higher the mast, the better the GPS reception

• Nex5N vs. Nex7 vs. Panasonic GH3

o These cameras are excellent for stills, and very good for video. The best for video is the 

Panasonic GH4 with 4k capabilities.

o We found that the Nex 5N takes exceptional quality stills and video, though most 

professionals use the Nex 7.

o Use the Panasonic GH4 if you primarily shoot video

• RADIO SET UP

o Follow the instructions in the manual

o We prefer the switch assignment as shown in the checklists above though feel free to modify

to your liking

• COPTER COMMAND AND CONTROL

o We recommend the use of a dual rate switch for main copter operation.

• High rate – used to initialize the motors. The flight controller will not engage unless it

sees full down throttle, full left rudder, full left cyclic and full back cyclic. However, 

these may be too high for normal flying. On high rate it is helpful to utilize fairly high 

exponential to make the stick feel soft around center. Adjust to your preference.

 Low rate – used for typical flying. Set the end point adjustments such that full stick 

deflection offers the maximum speed required in normal flying. If conditions require 

higher flight speeds, switch to high rate. On low rate it is also helpful to utilize a small 

46
amount of exponential to make the stick feel soft around center. Adjust to your 

preference.

• ZENMUSE COMMAND AND CONTROL

o We recommend the use of a dual rate switch for gimbal operation.

• High rate – used to initialize the gimbal. The gimbal may not engage unless it sees full

motion. However, these may be too high for shooting video smoothly. This is best for 

still photography so as to put the camera on target quickly. On high rate it is helpful to 

utilize fairly high exponential to make the stick feel soft around center. Adjust to your 

preference.

 Low rate – used for videography. Set the end point adjustments such that full stick 

deflection offers the maximum speed required for videography. If conditions require 

higher gimbal speeds, switch to high rate. On low rate it is also helpful to utilize a 

small amount of exponential to make the stick feel soft around center. Adjust to your 

preference.

• TIMERS

o Use of the countdown timer is a good backup method to ensure landing with battery power.

 Set the timer for 20 minutes (or what you deem appropriate) and have it start when the 

throttle is over 1⁄4. Then adjust the timer upwards until the amount of battery used is

about 80-90% of the total available. If using 20,000 mah batteries, a total of 17,000 

mah would be the target. Set the timer such that you have a minute or so to land after

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• BATTERIES

the alarm sounds so that you have adequate time to return to base. Adjust to your preference.

o Replace the transmitter standard battery with a Lipoly battery to extend use times to 8 hours.

Supplied batteries often last about 2 hours.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

NORMALPROCEDURES

• PREFLIGHT CHECKLIST

o Confirm all communication radios are operational

 Radio with ATC

 Radios with others in the group

o Set a perimeter of 100 meters

 Area must be clear of people to avoid collision

o Check for overhead power lines and other obstacles to avoid

o Check structural integrity

 In event of prior crash, inspect all booms, props and motor mounts for excessive flex

indicating structural fatigue/failure

o Have a manual flight plan avoiding obstacles.

o Load auto flight plan if using one

 Be sure that the total flight time is under 10 minutes to avoid low battery

o Clean lens

 Remove lens cap

o Ensure camera has SD card installed

 Many flights have been wasted due to this!

o Install batteries

 Ensure that the straps are tight and the Velcro keeps the batteries from moving which

47
will avoid a shift in the CG (Center of Gravity – or that it balances evenly)

o Check CG (Center of Gravity)

 Lift the copter on each of the 3 pairs of arms. The copter should balance properly. If

not, do not fly. Rearrange the equipment such that the CG is

o IMU pointing forward

 The Inertial Measurement Unit is set so that it must face forward

o GPS/Compass installed, limited free play, pointing forward

 This device must be installed with a screw to hold it in place. It cannot vibrate easily.

If it does not point forward, the corrections in ATTI and GPS mode will be incorrect 

and it will crash. The FC will provide a warning with constant flashing white lights.

o Level copter using a bubble level with front pointing in correct direction for course lock – do 

not turn on

 Keep in mind the best angle for pointing the landing gear in the direction that will 

keep the landing gear out of the shot when flying.

o Turn on Pilot Tx

o If using the rate gyro, set it at the correct position. This is usually a slider switch. Gains

should have the range set from 200 – 350. Use the highest gain possible which does not cause

oscillation.

o Check Model Selection on Tx to be S900

o Throttle on Tx Down

o Return to Home switch Off

o Adjust gain to correct position (if required)

o Manual Flight Mode Switch to manual (not ATTI or GPS mode)

o Flight Path Switch Off – Not Course or Home or POI

o Check Tx battery voltage (above 7.5v)

 These settings above are required to initialize the copter properly. If the switches are

in the incorrect position, it will not initialize properly which may cause some of the 

functions like course lock or GPS mode to not operate properly.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• If the copter does not function properly after takeoff, land immediately and disconnect 

the copter power. Then put all the switches in the proper position for initialization and

turn the power back on to the copter.

o Count down timer should be set correctly depending on battery capacity. This can be adjusted 

to your flying style. The timer should engage at 1⁄4 throttle and trigger an alarm at the proper 

time. This is a backup alarm in case the indicator lights on the copter are not visible.

o Turn on Photography Tx

o Check Model Selection on Tx – should read Zenmuse

o Check Tx battery voltage (above 5.4v for Futaba 14ch)

o HDMI switch Off

o Freestyle switch Off (FPV On)

 These settings above are required to initialize the Zenmuse properly. If the switches

are in the incorrect position, it will not initialize properly which may cause some of 

the functions like live video or gimbal operation to not operate properly.

 If the camera or gimbal do not function properly, disconnect the copter power. Then 

put all the switches in the proper position for initialization and turn the power back on 

to the copter.

o Engage power to copter

 Plug in the 2 battery packs. Typically the battery packs use red T-style connectors in a

parallel wire harness. This Y-harness has a yellow connector. It is preferable to 

connect the batteries to the Y-harness first, then plug in the yellow connector. This 

reduces (but does not eliminate) electrical arcing.

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 6 quick chirps should be heard confirming 6S LiPoly batteries are recognized by the 

ESCs.

• Hearing less than 6 chirps indicates fewer cell battery packs are being 

recognized which is incorrect. Check for improper or damaged batteries.

o Do not move or vibrate the Squadcopter until 30 seconds after full GPS Lock

 Initial 3 red blinks is normal meaning no GPS lock. No red flashes indicates full GPS

lock.

 Continue with checklist as you are waiting for full GPS lock, but do not move the 

copter.

 If the GPS takes more than 5 minutes to lock, there is a problem with the area. It is not 

receiving the proper signals from the satellites. GPS signals are weak, so trees, people, 

buildings, terrain, weather, have an effect. Move the copter into a more open area 

where it can more easily see the satellites.

o Check Copter Voltage from both Tx’s (transmitters)

 The transmitters receive a signal from the corresponding receivers. The voltages are

regulated to about 5v. If the voltage is below 4.4v or above 6v do not fly. There may 

be power regulation issues. The receivers cannot work outside this voltage 

consistently. Also there is some issue if the voltage is outside that range which should 

be resolved before flying.

o Engage Attitude Mode – Must achieve double amber flash

o Engage GPS Mode – Must achieve double purple flash

o Engage course cock mode – Must achieve double green flash

o Disengage course lock mode. Must achieve double purple flash. Stay in this mode until just

prior to takeoff, after takeoff at any time, or do not use.

o Do not engage motors. Set throttle to center position. Must achieve single purple flash when 

in GPS mode.

 To verify that the sticks are all centered properly:

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• With throttle in the center position, use the trim buttons on the transmitter to check 

that the sticks are centered. Trim the roll (the stick located on the right side of the 

transmitter when moved to the right and left) to the right, counting the number of 

clicks until a double flash occurs. Then center the trim. Then move the trim to the left, 

counting the number of clicks until a double flash occurs. An equal number of clicks 

should be counted each side of center.

• Do this check for the 3 stick movements other than throttle.

• Center the trim such that when the stick is in the neutral position that there are equal 

numbers of clicks in each direction. This ensures that when the sticks are neutralized 

that the flight controller will recognize this signal and engage GPS mode.

o Calibrate GPS/Compass before the first flight each day or if receiving continuous red blinks 

or continuous white blinks.

 Flip the GPS mode switch 7 times very quickly from manual to GPS. End with the 

switch in the manual position. The indicator light will be blue. Rotate the copter about

1.5 turns in a horizontal position. A green flashing light indicates that this is complete. 

Then hold the copter vertically and rotate about 1.5 turns. A white flashing light 

indicates that this is complete. Repeat if necessary until this is completed.

o After calibration, reset the copter by cycling battery with copter pointed in the correct heading 

for course lock.

o Engage Camera

o HDMI switch On

 This will stop video from playing on the back of the camera and will send the video

signal to the video transmitter via the HDMI connection.

49
o Freestyle switch On (FPV Off)

 This allows the camera to be operated freely through the transmitter

o Verify camera operation

 Operate the shutter

 Set the focus to auto or manual. Manual setting is usually set to infinity to stop 

constant focusing of the camera.

o Verify data link if installed

 Roll the copter about 45 degrees on its side by lifting one side of the copter and resting

one side of the landing gear on the ground

 A corresponding roll should be seen on the gauge.

 If the copter is rolled to the right, it will appear on the gauge that the horizon rolls to 

the left – not the right because the view from inside the copter is that the horizon rolls 

the opposite direction of the copter.

o Verify altitude is about 0 via gauge on computer

 If it is not about 0, the altitude settings for the waypoints will be off by this amount.

This could cause the copter to fly at 10 meters or 30 meters if the waypoint is set for 

20 meters and the altitude is off by 10 meters one way or another. If the copter thinks 

it is at 10 meters when it is on the ground, then it will only rise 10 meters above the 

ground to achieve what it believes it to be 20 meters above the ground.

 The altitude can be reset using the ground control software by going to altitude offset.

o Alternate Emergency Landing Sites Established

• NORMAL TAKEOFF

o Confirm clear for takeoff with ATC

 Necessary if within 5 miles of an airport

• © 2014 Troy Built Models, Inc. All Rights Reserved.

• ATC clearance is required days or weeks before flying.

o Engage GPS mode – Double purple flash when the throttle is down.

o Switch to Course Lock flight mode if required. Purple flashes are replaced with green flashes.

Flying in course lock is not required, but helpful in many instances.

o Announce loudly: “CLEAR PROP”

o Move both of the sticks to the bottom left corners to engage the motors. Within 1 second

move the throttle up 1/8 – 1/4. The copter should not lift off until about 1⁄2 stick is reached.

o Verify data and video links before lifting off. If anything is not working properly, move the 

throttle stick to low to disengage the motors and determine a solution.

o If all flight checks are passed, announce loudly: “TAKING OFF”

o Advance throttle to about 3/4. Copter must jump off of the ground to avoid one skid coming

up before the other skid, and the skid on the ground getting caught and flipping the copter

over sideways.

o Ascend to 3 meters. Then decrease throttle to 1⁄2 to engage the GPS hold.

o Verify links, GPS, Attitude, etc. Should be single purple flash.

o Verify that the copter is holding position within .5m in all directions.

o Verify camera operation

o Verify course lock is operational by rotating 90 degrees and pushing forward on stick.

o Verify copter stability. If unstable, land and reset gains, recalibrate, or retest as necessary.

o Proceed with manual mission or

o For autopilot operation

 Ascend to 10 meters

 Command AVO to proceed with mission.

• Pilot should say “It’s yours”

• Response from AVO “I have it”

50
o Manual pilot/observer must monitor the informational LED and be ready to take over in 

manual mode when necessary.

 White flashes indicates flight controller issue

 Amber flashes indicates low battery

 Red flashes indicate loss of GPS or severe battery condition

• Quick decisions are required when red flashes are indicated

• 10 seconds or more of loss of GPS signal will stop waypoint guidance and any 

GPS hold and put into manual mode.

• Red indicator light battery warning requires immediate landing

o Manual pilot to request copter flight battery voltage readout from AVO periodically.

 Reset the first and second indicator lights as required for your set up.

 When recharging the batteries, the goal is to put 4,000 mah into a 5,000 mah battery 

pack. Adjust the voltage warnings to your style of flying.

 Also use the countdown timer on the transmitter. This gives a good indication of 

battery level because the current used is fairly constant from flight to flight.

• POST LANDING

o Note flight time from transmitter. Write this down in the log book.

o Note battery power used during the flight. Write this down in the log book.

o ALWAYS disconnect the main power to the AV first, then turn off the transmitter.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

o Check motor temperatures by touching them with your fingers. Any motors which are 

excessively hot should be further inspected and possibly replaced.

o Check battery temperatures by touching them with your fingers. Battery temperatures should 

not be hot to the touch. Battery temperatures should be slightly above ambient.

o Inspect all components especially the propellers for wear.

o Note in logbook which batteries were used to calculate life cycle.

• AIRCRAFT FLIGHT LOG BOOK (Can be purchased inexpensively)

o Keep a log of all flights.

 Date

 Time of Day

 Time in Operation (in hours)

 Battery serial numbers

 Mah used in flight

 Location

 Pilot, Observer, Sensor Operator Names

 Flight Objective

 Remarks

• AIRCRAFT MAINTENANCE LOG BOOK (Can be purchased inexpensively)

o Keep a log of significant inspections, tests, repairs, alterations, equipment changes.

 Date maintenance is performed

 Accumulated hours of operation

 Remarks

• PILOT LOG BOOK (Can be purchased inexpensively)

o Keep a log of all flights. Include the following:

 Aircraft flown

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 Aircraft serial number

 Date

 Time of Day

 Time in Operation (in hours)

 Location

 Flight Objective

 Remarks

• © 2014 Troy Built Models, Inc. All Rights Reserved.

SECTION 5

PERFORMANCE

• FLIGHT TIMES

o The AV is designed to hover at high efficiency. Hovering is much less efficient than flying on 

a wing, thus flight times are low compared to fixed wing aircraft.

o All the weight of the AV is supported by power from the batteries. As the batteries are used in 

a flight, the amount of power available decreases. Therefore the power reserve is constantly 

decreasing as the battery is being used. Thus loading a rotorcraft above its limit is not 

recommended. While the AV may have enough power to lift off initially on a full charge, the 

power reserve at partial charge may be too low to allow for maneuvering and will result in a 

crash.

o High lateral speeds will add lift to slightly improve efficiency. The rotors act similar to fixed 

wings at higher speeds. This increase in efficiency may be negated by the increased power 

consumption of forward flight.

o High winds or gusts decrease efficiency/flight time. The motors work harder to hold position.

o As weight increases flight times decrease.

• WIRELESS TRANSMISSION

o Refer to the specific manuals for performance ratings.

o Wireless communications utilized provide acceptable communication for LOS.

o In general:

 LOS is required

 The higher the GCS antennas, the better the range

 Any freq. at may have severe degradation due to location to other admitters such as 

cell towers

 RSSI (Received Signal Strength Indication) should be monitored for indication of 

communication drop out.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

SECTION 6

WEIGHT AND BALANCE EQUIPMENT LIST

o CG is critical to the efficient operation of any AV

o When components are shifted, the CG will be altered.

o The main components which are moved on a regular basis are the sensors and the batteries.

o The sensors are typically in the front of the AV, and the batteries are located in the correct

position to offset all the components on the AV.

o The CG must be tested after any change to the components or their placement.

o The CG should be tested by lifting the UV with fingers on the bottom of the arms. Check all 3

pairs of arms. The CG should be no more than 2mm off in any on the 3 checks. The closer the

CG is to the centerlines of the arms the more efficient and the more stable the AV will be.

52
• WEIGHT

o Weight is critical to the operation of any aircraft

o Weight is especially critical to a rotor wing aircraft. At full throttle the motors have a finite

amount of thrust. All the weight is lifted by the battery power, there is no wing to assist in

providing lift.

o As the batteries are operated, they lose power. At full charge they have about 25v. At 20% 

remaining capacity they have about 21v. This is a loss of 8% of the power available which is 

significant.

o Do not overload the aircraft or there will not be sufficient reserve power to maneuver at low 

battery levels.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

SECTION 7

AIR VEHICLE AND SYSTEMS DESCRIPTION

• FLIGHT BATTERY REQUIRED

o Manufacturers: Various COTS suppliers

o Battery chemistry recommended: Lithium Polymer

o Battery Capacity: up to 21,000 mah or greater depending on max gross weight

o Battery cell count required: 6S (6 cells in series)

o Battery Voltage: 21V minimum during hover, 22.2V nominal, 25.2V maximum

o Battery Minimum Rated Discharge Rate: 20C minimum

o Battery Minimum Charge Rate: 1C (3C preferable)

o Battery Rest Time between discharging and charging: 0-30 minutes

o Batteries used simultaneously: typically 1

o Recommended Battery Discharge Amount: 80-90%

• WERELESS COMMUNICATIONS

o Refer to the specific manuals for performance ratings.

o Never power a video transmitter or receiver without an antenna connected or overload failure

will occur.

o Wireless communications utilized provide acceptable communication for LOS.

o In general:

o LOS is required.

o Lower frequencies penetrate objects such as trees better than higher freqs.

o Lower freqs have longer range than high freqs

o Higher freqs can transfer more data than lower freqs

o Higher freqs use smaller/shorter antennas

o The higher the GCS antennas, the better the range and reception

o Any freq at may have severe degradation due to location to other admitters such as cell towers

o Range must be constantly monitored.

o Alternate antenna types may be utilized to improve link/range. Patch, helical, omni, etc. can

be substituted. They must be verified before use.

o Alternate freqs may be utilized to improve link/range.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

SECTION 8

HANDLING, SERVICE AND MAINTENANCE

• PROPELLER CARE

o Propellers must be checked each flight for nicks or cracks

53
o Propellers are designed to last indefinitely if they do not impact dust, dirt or more.

• BATTERY CARE AND USE

o Refer to instruction sheet included from the battery manufacturer. Typical information 

follows.

o Batteries are highly flammable and can explode, especially when fully charged. Improper 

charging, vibration, impact, high discharge, etc. can lead to explosion and fire. Batteries must 

be charged under constant supervision and using proper precautions.

o Batteries fully charged must be handled with extreme care.

o Any battery which puffs up is considered damaged and must not be used. It is in a dangerous

state. Never charge a puffed up battery.

o Any battery which holds less than 80% of its rated capacity should be discarded.

o Cycle test each battery after every 50 cycles or if a battery is suspected to have lost as

significant amount of its capacity to determine the current capacity.

o Properly dispose of batteries. First discharge the battery fully using a battery cycler. Bring to a 

recycler such as a home improvement store.

o Always charge flight batteries under “balance” mode.

o Flight Battery Recommended Charge Rate: 1C which takes approximately 1 hour to charge

o Flight Battery Maximum Charge Rate: May exceed 5C. Charge rates higher than 1C will

decrease life cycles. Maximum charge rating per the manufacturer will provide 300+ cycles.

Use the lowest charge rate which is practical.

o Battery Rest Time between discharging and charging: 30 minutes minimum, 1 hour 

maximum.

o Do not charge if the battery is more than 2°C warmer than ambient, especially if the 

temperature is above 20°C. The outer surface is cooler than the inner core after use. Damage 

will occur when charging a warm battery.

o Recommended Battery Discharge Amount: 80%. Using more of the capacity of the battery 

will decrease the life cycles

o As battery temperature approaches freezing the capacity of Lithium Polymer batteries 

decrease. Keep warmer than 5°C before installing into the UV (unmanned vehicle).

o Battery capacity decreases at higher discharge rates. Using more batteries decreases the 

discharge rate of each battery thereby extending individual battery capacity slightly.

o Lower discharge rates improve the life cycles.

o Batteries are rated at greater than 300 life cycles. 1,000+ life cycles are possible.

o Batteries must not be stored above 60% charged state for extended periods.

o Batteries should be stored below 25°C for extended periods

o Store batteries between 40% - 60% charged state. Fully charge just before use.

o Fully charged batteries which are not to be used within 24 hours should be discharged to 40%

- 60% charged state using the battery discharger.

o Using more than one battery at a time requires the proper wiring harness so that the voltage is 

no more than 25.2V. Over voltage will cause serious damage to electrical equipment.

• © 2014 Troy Built Models, Inc. All Rights Reserved.

54
• PREVENTATIVE MAINTENANCE

o ANNUAL INSPECTION (SUGGESTED)

 If the airframe has in excess of 300 hours in a one year period, an annual inspection

must be completed by an approved technician.

 An approved technician should disassemble the AV and inspect all components for 

wear and replace any components as required.

 Test all batteries for capacity.

 Upgrade firmware and software to latest revisions

o 500 HOUR PM (SUGGESTED)

 An approved technician should disassemble the AV and inspect all components for

wear and replace any components as required.

 Replace all motors.

 Test all batteries for capacity.

 Upgrade firmware and software to latest revisions.

© 2014 Troy Built Models, Inc. All Rights Reserved.

55