Arthur C. Trembanis

Associate Professor of Oceanography 

and Geology

Director CSHEL

109 Penny Hall

Newark, DE 19716 U.S.A.

Phone: 302-831-2498

Fax: 302-831-4158

Email: art@udel.edu

December	30th,	2015

Coastal	Sediments,	Hydrodynamics,	and	Engineering Laboratory

School	of	Marine	Science	and	Policy,	

College	of	Earth,	Ocean,	and	Environment

109	Penny	Hall

Newark,	DE	19716

U.S.	Department	of	Transportation

Docket	Operations

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

RE: Petition	for	Exemption	and	Relief	from	Specific	Regulations	of	Title	14	of	the	

Code	of	Federal	Regulations	Pursuant	to	Section	333	of	the	FAA	Modernization

and	Reform	Act	of	1012	(Public	Law	112-95)	Regarding Commercial

Employment	of	Unmanned	Aircraft	Systems	(UAS)

Dear	Sir/Madam,

Pursuant	to	Section	333	of	Public	Law	112-95	commonly	known	as	the	“FAA	

Modernization	and	Reform	Act	of	2012”	or	“The	Reform	Act”,	the	University	of	

Delaware hereby	applies	for	authorization	to	conduct	commercial	unmanned	aerial	

systems	(UAS)	operations	within	the	United	States	National	Airspace	System	(NAS)	for	

the	purpose	of	Research,	Education	and	UAS	platform	development.

Federal	Register	Summary

Pursuant	to	14	CFR	§11.81,	the	following	summary	is	provided	for	publication	in	the	

Federal	Register,	should	it	be	determined	that	publication	is	needed:

The	University	of	Delaware seeks	exemption	from	14	CFR	Part	21,	Subpart	H;	14	CFR	Part	27;	

14	CFR	45.23(b); 14	CFR	61.113(a)(b);	14	CFR	91.7(a);	14	CFR	91.9(b)(2)(c);	14	CFR	91.103;	14	

CFR	91.109(a);	14	CFR	91.119;	14	CFR	91.121;	14	CFR	91.151(a);	14	CFR	91.203(a)(b);	14	CFR	

91.405(a);	14	CFR	91.407(a)(1);	CFR	91.409(a)(1)	and	(a)(2);	14	CFR	91.417(a)(b)	to	allow	

commercial	employment	of	Unmanned	Aerial	Systems	(UAS)	in	support of	research,	education	

and	UAS	platform	development	in	the	areas	of	oceanography,	limnology,	and	environmental	

science.				This	exemption	will	enhance	safety	by	reducing	risk	to	the	general	public	and	

property	owners	from	the	substantial	hazards	associated	with	performing	equivalent	work	

with	conventional	aircraft	and	rotorcraft.
1

December	30th,	2015

Coastal	Sediments,	Hydrodynamics,	and	Engineering Laboratory

School	of	Marine	Science	and	Policy,	

College	of	Earth,	Ocean,	and	Environment

109	Penny	Hall

Newark,	DE	19716

U.S.	Department	of	Transportation

Docket	Operations

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

RE: Petition	for	Exemption	and	Relief	from	Specific	Regulations	of	Title	14	of	the	

Code	of	Federal	Regulations	Pursuant	to	Section	333	of	the	FAA	Modernization

and	Reform	Act	of	1012	(Public	Law	112-95)	Regarding Commercial

Employment	of	Unmanned	Aircraft	Systems	(UAS)

Dear	Sir/Madam,

Pursuant	to	Section	333	of	Public	Law	112-95	commonly	known	as	the	“FAA	Modernization	and	Reform	Act	of	

2012”	or	“The	Reform	Act”,	the	University	of	Delaware hereby	applies	for	authorization	to	conduct	

commercial	unmanned	aerial	systems	(UAS)	operations	within	the	United	States	National	Airspace	System	

(NAS)	for	the	purpose	of	Research,	Education	and	UAS	platform	development.

Federal	Register	Summary

Pursuant	to	14	CFR	§11.81,	the	following	summary	is	provided	for	publication	in	the	Federal	Register,	should	it	

be	determined	that	publication	is	needed:

The	University	of	Delaware seeks	exemption	from	14	CFR	Part	21,	Subpart	H;	14	CFR	Part	27;	14	CFR	45.23(b);	14	CFR	

61.113(a)(b);	14	CFR	91.7(a);	14	CFR	91.9(b)(2)(c);	14	CFR	91.103;	14	CFR	91.109(a);	14	CFR	91.119;	14	CFR	91.121;	14	

CFR	91.151(a);	14	CFR	91.203(a)(b);	14	CFR	91.405(a);	14	CFR	91.407(a)(1);	CFR	91.409(a)(1)	and	(a)(2);	14	CFR	

91.417(a)(b)	to	allow	commercial	employment	of	Unmanned	Aerial	Systems	(UAS)	in	support of	research,	education	

and	UAS	platform	development	in	the	areas	of	oceanography,	limnology,	and	environmental	science.				This	

exemption	will	enhance	safety	by	reducing	risk	to	the	general	public	and	property	owners	from	the	substantial	

hazards	associated	with	performing	equivalent	work	with	conventional	aircraft	and	rotorcraft.
2

The	name	and	address	of	the	applicant	is:

Dr.	Arthur	C.	Trembanis

Coastal	Sediments,	Hydrodynamics,	and	Engineering Laboratory

Robotics	Discovery	Laboratories

School	of	Marine	Science	and	Policy,	

College	of	Earth,	Ocean,	and	Environment

109	Penny	Hall

Newark,	DE	19716

art@udel.edu

302-831-2498
3

GLOSSARY	OF	ABBREVIATIONS

AGL Above	Ground	Level

AOI Area	of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AV Aerial Vehicle

CFR Code	of	Federal	Regulations

COA Certificate	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

GCS Ground	Control	Station

LOL Loss	of	Link

NAS National	Airspace	System

NOTAM Notice	to	Airmen

PIC Pilot	in	Command

Section	333 FAA	Modernization	and	Reform	Act	of	2012,	Section	333

SOP Standard	Operating	Procedures

UA Unmanned	Aircraft

UAS Unmanned	Aircraft	System

VFR Visual	Flight	Rules

VLOS Visual	Line	of	Sight

VMC Visual	Meteorological	Conditions

VO Visual	Observer
4

INTRODUCTION	AND	INTEREST	OF	THE	PETITIONER

The	use	of	small	unmanned	aerial	systems	(sUAS)	in	terrestrial	commercial	and	science	applications	is now	

widespread and	transforming	agricultural	assessments,	environmental	compliance	regimes	and	spatial	

ecological	science.	These	devices	are	used	regularly	to	reduce	costs,	increase	safety and	boost	knowledge	of	

key	agricultural	parameters,	to	assess	progress	and	environmental	compliance	in	mining	operations	and	

occasionally	to	study	the	terrestrial	habitats	and	aggregations	of	wildlife	[3].	The	use	of	sUAS	in	coastal	and	

ocean	science	applications	is	also	growing,	and	the	availability	of	safe	and	sophisticated	commercial	hardware	

and	software	solutions	is	now	facilitating	their	use	by	marine	researchers.	The	use	of	sUAS	by	marine	

researchers	can	provide	significant	benefits	including	reduced	costs,	greater	survey	efficiency,	reduced	wildlife	

disturbance,	reduced	risk	to	human	pilots	and	observers	and	higher	data	quality and	quantity,	yet	there	are	

few	programs	exploring	these	opportunities.	The	University	of	Delaware Robotics	Discovery Laboratory	is	

developing	an sUAS	program	to	1)	help	meet	the	growing	educational	needs	of	marine	scientists	seeking	to	

use	sUAS	in ocean	and	coastal	applications	and; 2)	to	support	sUAS-based	research	in	coastal	and	marine	

environments nationally	and	internationally.	To	achieve	these	goals,	our	research	program	must	engage	in	

domestic	sUAS	operations	for	research,	education	and	training	purposes.	Due	to	the	nature	of	our	work, these

flights	will	occur	predominantly	in	remote	coastal	areas,	away	from	human	activities and	often	exclusively	

over	water.		sUAS	are	developing	as	a	legitimate	and	robust	means	of	conducting	research	that	heretofore	

have	been	possible	only	from	manned	aircraft.		Such	traditional	survey	techniques	are	expensive, incur	

substantial	risk	to	personnel and	produce	lower	quality	data.	Our	work	addresses these	issues	through	marine	

science	sUAS	applications	to	the	benefit	of	society	at	large.

OVERVIEW	CHARACTERISTICS	OF	PROPOSED	UAS

DJI	Phantom	3 DJI	Phantom	2+ DJI	Inspire

Aircraft	Type Multirotor	(4	Rotor) Multirotor	(4	Rotor) Multirotor	(4	Rotor)

Aircraft	Weight 1.2kg/2.75lbs 1.2kg/2.75lbs 2.93kg/6.46lbs

Max	Take	off	Weight 1.2kg/2.75lbs 1.2kg/2.75lbs 2.93kg/6.46lbs
5

Dimensions 590x590x350mm 590x590x350mm 438x451x301mm

Max	Flight	time	(aprox) 23min 19min 20min

Max	airspeed 32kts 32kts 44kts

Propulsion Brushless	DC	motor Brushless	DC	motor Brushless	DC	motor

Power Lithium	Polymer	4S

PH3-4480	MAH-15.2	V

15.2v	4	cell	Lithium	

Polymer	battery

22.2v	6	Cell	Lithium	

Polymer	battery

Payload Digital	compact	/Video	

camera

Digital	compact	/Video	

camera

Digital	compact	/	Video	

camera

Airframe	material ABS	Plastic ABS	plastic ABS	plastic

QUALIFICATION	FOR	APPROVAL	UNDER	SECTION	333	OF	THE	REFORM	ACT

The	proposed	operations	in	this	petition	for	exemption	qualify	for	expedited	approval	under	Section	333	of	

the	Reform	Act.	Each	of	the	statutory	criteria	and	other	potentially	relevant	factors	are	satisfied.	

The	proposed	operations	would	permit	the	use	of	small	and	relatively	inexpensive	UAS	under	controlled	

conditions	in	airspace	that	is:	(1)	limited;	(2)	predetermined;	(3)	away	from	populated	areas;	(4)	would	provide	

an	increased	level	of	safety	beyond	that	existing	when	fixed	or	rotor	wing	aircraft	are	used	to	accomplish	the	

same	purpose.

The	UAS's	planned	to	be	operated	are	rotorcraft	aircraft,	each	weighing	typically	less	than	8 lbs.,	and	always	

less	than	55	lbs.,	including	payload.	They	would	operate,	under	normal	conditions,	at	a	speed	of	no	more	than	

40 knots.	The	principal	construction	material	of	the	UAS	aircraft	would	typically	be	plastic.	Specific	operational	

sUASs	are	the	DJI	Phantom	2	Vision+,	DJI	Phantom	3,	and	DJI	Inspire	1.		The	DJI	Phantom	2	Vision+,	DJI	

Phantom	3,	and	DJI	Inspire	1 are	vertical	takeoff	and	landing	(VTOL)	Unmanned	Aircraft	(UA)	with	a	Ground	

Control	Station	(GCS)	utilizing	electronic	tablet	or	smart	phone	systems.		The	DJI	Phantom	2	Vision+	and	

Phantom	3	have	a	maximum	gross	weight	of	approximately	2	pounds	11	ounces,	while	having	a	length	of	16	

inches	width	of	16	inches,	height	of	8	inches,	and	maximum	speed	of	approximately 29	knots.		The	DJI	Inspire	

1	has	a	maximum	gross	weight	of	6	pounds	7.5	ounces,	a	length	of 17.3	inches,	width	of	17.7	inches,	height	of	

11.8	inches,	and	a	maximum	speed	of	approximately
6

42	knots.		The	DJI	Phantom	2	Vision+,	Phantom	3,	and	the	DJI	Inspire	1	UAs	are	equipped	with	four	main	

rotors;	driven	by	Lithium	Polymer	battery	powered	electric	motors.		The	DJI	Phantom 2	Vision+,	Phantom	3,	

and	DJI	Inspire	1	UAs	that	will	be	operated	by	UDel	RDL will	be	registered	in	accordance	with	49	U.S.C.	44103,	

Registration	of	Aircraft,	as	well	as	14 C.F.R	Part	47,	Aircraft	Registration,	and	marked	in	accordance	with	14	

C.F.R	Part	45, Identification	and	Registration	Marking.

Operations	will	be	performed	by	a	qualified	UAS	Pilot	in	Command	(PIC), as	outlined	below,	to	insure	that	the	

UAS	will	"not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public."	Given	the	small	size	of	

the	UAS	involved	and	the	pre-planned	environment	within	which	they	will	operate,	the	applicant	believes	that	

these	operations	fall	squarely	within	that	zone	of	safety	(an	equivalent	level	of	safety)	in	which	Congress	

envisioned	that	the	FAA	must,	by	exemption,	allow	commercial	operations	of	UAS	to	commence	immediately.		

Also,	due	to	the	size	of	the	UAS	and	the	pre-defined,	restricted	area	in	which	the	UAS	will	operate, approval	of	

the	application	presents	no	national	security	issue.	The	operation	of	UAS	by	knowledgeable	professionals	will	

serve	to	enhance	safety,	add	to	the	public	benefit,	and	reduce	environmental	impacts	related	to	current	

methods	of	manned	aircraft	flight	operations.	These	limitations	and	conditions	to	which	the	operator,	or	its	

employees,	acting	as	UAS	PIC	agrees	to	be	bound	when	conducting	commercial	operations	under	a	FAA	issued	

exemption:

1. Operations	authorized	by	this	grant	of	exemption	are	limited	to	the	following	aircraft:	DJI	Phantom	3,	

DJI	Phantom	2+ and	DJI	Inspire.

2. UA	(aircraft	and	payload)	will	weigh	less	than	55lbs.

3. UA	will	be	operated	at	altitudes	not	greater	than	400	feet	AGL.		Altitudes	reported	to	ATC	will	be	in	

feet	AGL.

4. UA	will	be	flown	at	ground	speeds	not	greater	than	40 knots.

5. The	UAS PIC	will	hold	either	an	airline	transport,	commercial,	private,	recreational	or	sport	pilot	

certificate.		The	PIC	must	also	hold	a	current	FAA	airman	medical	certificate or	a	valid	U.S	driver’s	

license	issued	by	a	state,	the	District	of	Columbia,	Puerto	Rico,	a	territory,	a	possession,	or	the	Federal	

government.		The	PIC	must	also	meet	the	recent	flight	experience	requirement	stated	in	14	CFR	§	

61.57	and	flight	review	requirements	stated	in	14	CFR	§	61.56.		The University	of	Delaware Robotic	

Discovery	Laboratory Program (applicant)	employs	a	full-time	private licensed	pilot.

6. In	addition	to	holding	an	FAA	issued	airman	certificate,	UAS	PIC	must	complete	a	The	University	of	

Delaware RDL UAS	Training	Program.		This	training	will	include	detailed	review	of	manufacturer	

operating	manuals and practical	demonstration	of	ability	to	safely	operate	UAS	in	a	manner	consistent	

with	how	the	UAS	will	be	operated	under	this	exemption	(to	include	evasive	and	emergency	

maneuvers	and	maintaining	appropriate	distances	from	persons,	vehicles,	vessels	and	structures).		PIC	

qualification	will	have	a	currency	requirement	of	at	least	three	take-offs	and	landings	within	the	

preceding	90	days.		PIC	qualification	flight	hours	will	be	logged in	a	manner	consistent	with	14	CFR	§	

61.51.	

7. sUAS will	not	be	operated	within	5	nautical	miles	(NM)	of	an	airport	having	an	operational	control	

tower,	or	3	NM	of	an	airport	with	a	published	instrument	flight	procedure	but	not	an	operational	

control	tower,	or	2	NM	of	an	airport	without	a	published	instrument	flight	procedure	or	operational	

control	tower,	or	2	NM	of	a	heliport	with	a	published	instrument	flight	procedure. Flights	will	be	

operated	in	Class	G	airspace	whenever possible.	If	operation	in other	airspace	is	required,	the relevant	
7

controlling	agency	will	be	notified	at	least	24	hours prior	to	the	operation	and,	if required,	any	

necessary permission	obtained

8. sUAS	flights	will	operate	within	visibility	and	cloud	clearance	requirements	equivalent	to	Visual	Flight	

Rules	(VFR).

9. sUAS	operations	will	not	be	conducted	during	night,	as	defined	within	14	CFR	§	1.1.

10. sUAS flights	over	land	will	not	be	operated	by	the	PIC	from	any	moving	vehicle	or	device.		sUAS flights	

conducted	entirely	over	water	may	be	operated	from	a	suitable	vessel.

11. sUAS will	not	be	operated	from	a	raised	platform.

12. The	sUAS will	remain	clear	of	and	yield	right	of	way	to	manned	aviation	operations.

13. sUAS will	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	at	all	times.		The	PIC	will	use	human	

vision	unaided	by	device	other	than	corrective	lenses	as	specified	on	PIC’s	FAA	medical	certificate.

14. sUAS	operations	will employ	a	visual	observer	(VO).		The	VO	may	be	used	to	satisfy	the	VLOS	

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

communicate	verbally	for	the	duration	of	the	flight.		Electronic	messaging	or	texting	is	not	allowed	

during	flight	operations.

15. The	VO	will	perform no	duties	other	than	assisting the	PIC see	and	avoid	other	aircraft,	obstacles,	

persons	or	property.

16. sUAS	will	be	equipped	with	an	autopilot	system.		The	sUAS	will	utilize	GPS	navigation,	failsafe’s,	returnto-home	(RTH)	and	flight	abort	safety	features.

17. Prior	to	each	flight	the	PIC	will	inspect	the	sUAS	to	ensure	it	is	in	a	condition	for	safe	flight.		Checklists	

developed	from	manufacturer	operating	documents	will	be	the	basis	for	this	inspection.		If	the	

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

operating	until	necessary	maintenance	has	been	performed	and	the	sUAS	is	found	to	be	in	a	safe	

condition	for	flight.		The	Ground	Control	Station	must	be	included	in	the	preflight	inspection.

18. All	sUAS	operations	will	be	conducted	over remote	and	sparsely	populated	property	or	over	open	

waters.		Permission	for	flight	will	be	obtained in	advance	from	property	owners	or	controlling	agency.

A	Ground	Station	will	be	connected,	by	radio communication,	to	the	sUAS during	the	entire	flight,	

which will	give	the	PIC	flight	information	such	as	GPS	Position, Altitude,	Air	speed,	Battery	Remaining,	

and	other	telemetry information.

19. Flight	boundaries	will	be	established	for	each	flight	and	such	boundaries	will	be	designed	such	that	the	

sUAS will	pass	no	closer	than	100	feet	from	nonparticipating	persons,	vehicles	or	structures.

20. If	the	sUAS	loses	communications	or	loses	GPS	signal,	the	sUAS will	return	to	a	predetermined	location	

within	the	established	flight	boundary	and	land	or	be	recovered	in	accordance	with	manufacturer	

operations	documents.

21. The	PIC	will	abort	any	flight	in	the	event	of	unpredicted	obstacles,	occurrence	of	adverse	weather	or	

loss	of	sUAS	flight	control	capability	in	accordance	with	manufacturer	operations	documents.

22. The	PIC	is	prohibited	from	beginning	a	flight	unless	(considering	wind	and	forecast	conditions)	there	is	

enough	power	to	fly	the	planned	route	to	the	intended	landing	point	and	land	the	sUAS with 25%	of	

battery	capacity remaining.

23. Documents	required	by	14	CFR	§	91.9	and	91.203	will	be	available	to	the	PIC	at	the	Ground	Control	

Station	of	the	sUAS	whenever	the	aircraft	is	operating.		These	documents	will	be	made	available	to	the	

Administrator	or	any	law	enforcement	official	upon	request.
8

24. Before	conducting	flight	operations,	the	radio	frequency	spectrum	used	for	operation	and	control	of	

the	sUAS must	comply	with	Federal	Communications	Commission	(FCC)	or	other	appropriate	

government	oversight	agency	requirements.

25. A	Flight	Operations	and	Maintenance	Log	will	be	maintained	for	each	sUAS.		Cumulative	flight	hours,	

maintenance	activities,	repairs,	alterations	and	inspections	will	be	noted.

26. Any	sUAS	maintenance	or	alterations	that	affect	sUAS	operation	or	flight	characteristics,	e.g.	

replacement	of	a	flight	critical	component,	must	undergo	a	functional	test	flight.		The	PIC	who	

conducts	the	functional	test	flight	must	make	an	entry	in	the	Flight	Operations	and	Maintenance	Log.

SPECIFIC	SECTIONS	OF	14	CFR	FROM	WHICH	PETITIONER	SEEKS	EXEMPTION	OR	RELEIF

14	CFR	Part	21,	Subpart	H	– Airworthiness	Certificates and	14	CFR	§	91.203(a)(1)

The	FAA	has	stated	that	no	exemption	is	needed	from	this	section	if	a	finding	is	made	under	Part	11	and	

Section	333	of	the	Reform	Act	that	the	UAS	selected	provides	an	equivalent	level	of	safety	when	compared	to	

civil	aircraft	normally	used	for	the	same	application.		The	petitioner	submits	that	given	the	small	size	of	the	

UAS,	the	limited	operating	areas	and	procedures	defined	within	the	training	and	operations	section	of	the	

petition,	an	equivalent	level of	safety	is	obtained	and	exemption	is	not	required	(see	Grant	of	Exemption	to	

Astraeus	Aerial,	Docket	No.	FAA-2014-0352).		If	however,	the	FAA	determines	that	there	are	some	

characteristics	of	the	chosen	UAS	that	fail	to	meet	the	requirements	of	the	Reform	Act,	an	exemption	is	

requested.

14	CFR	Part	27	– Airworthiness	Standards:	Normal	Category	Rotorcraft

14	CFR	Part	27	sets	forth	the	procedural	requirements	for	airworthiness	certification	of	normal	category	

rotorcraft.		To	the	extent	petitioner’s	UAS	would	otherwise	require	certification	under	Part	27,	petitioner	

seeks	exemption	for	the	same	reasons	identified	in	the	request	for	exemption	from	14	CFR	Part	21,	Subpart	H.

14	CFR	§	45.23	(a)(b)	and	91.9	(c) – Marking	of	the	Aircraft

Regulation	45.23	provides:		(a) Each	operator	of	an	aircraft	must	display	on	that	aircraft	marks	consisting	of	

the	Roman	capital	letter	“N”	(denoting	United	States	registration)	followed	by	the	registration	number	of	the	

aircraft.	Each	suffix	letter	used	in	the	marks	displayed must	also	be	a	Roman	capital	letter.	(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	UAS	has	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	markings	can be	placed.		Given	the	

small	size	of	the	sUAS,	two-inch	lettering	will	not	be	possible.		In	a	previous	Grant	of	Exemption,	the	FAA	
9

determined	that	exemption from	these	requirements	was	warranted	provided	that	the	aircraft “have

identification	(N-Number)	markings	in	accordance	with	14	CFR	Part	45,	Subpart	C	if	the	markings	are	as	large	

as	practicable.”		The	petitioner	additionally	proposes	to	place	all	required	markings,	placards,	flight	envelope	

restrictions,	cautionary	notices	in	an	easily	visible	location at	the	UAS	Ground	Control	Station.		The	FAA	has	

issued	several	exemptions	to	this	regulation:	see	Exemptions	Nos.	8738,	10167,	10167A	and	10700.

14	CFR	§	91.9(b)(2)	– Aircraft	Flight	Manual	in	the	Aircraft

Regulation	91.9	stipulates	(b)	No	person	may	operate	a	U.S.-registered	civil	aircraft— (2)	For	which	an	Airplane	

or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of	this	chapter,	unless	there	is	available	in	the	aircraft	a	

current	approved	Airplane	or	Rotorcraft	Flight	Manual,	approved	manual	material,	markings,	and	placards,	or	

any	combination	thereof.

Given	the	size	of	the	sUAS,	they	have	no	place	or	ability	to	carry	a	flight	manual	aboard	the	aircraft.		An	

equivalent	level	of	safety	will	be	achieved	by	keeping	the	flight	manual	at	the	Ground	Control	Station	where	

the	pilot	operating	the	sUAS	will	have	immediate	access	to	it.		The	FAA	has	issued	several	exemptions	to	this	

regulation:	see	Exemptions	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	10167,	10602,	32827	and	10700.

14	CFR	§	61.113	(a)(b)	and 61.133(a)(i)(ii)	– Private	and	Commercial	Pilot	Privilege	and	Limitations

Regulation	61.113	stipulates	(a)	Except	as	provided	in	paragraphs	(b)	through	(h)	of	this	section,	no	person	

who	holds	a	private	pilot	certificate	may	act	as	pilot	in	command	of	an aircraft	that	is	carrying	passengers	or	

property	for	compensation	or	hire;	nor	may	that	person,	for	compensation	or	hire,	act	as	pilot	in	command	of	

an	aircraft.

(b)	A	private	pilot	may,	for	compensation	or	hire,	act	as	pilot	in	command	of	an	aircraft	in	connection	with	any	

business	or	employment	if: (1)	The	flight	is	only	incidental	to	that	business	or	employment;	and (2)	The	aircraft	

does	not	carry	passengers	or	property	for	compensation	or	hire.

Regulation	61.133	stipulates	(a) Privileges—(1) General. A	person	who	holds	a	commercial	pilot	certificate	may	

act	as	pilot	in	command	of	an	aircraft—

(i)	Carrying	persons	or	property	for	compensation	or	hire,	provided	the	person	is	qualified	in	accordance	with	

this	part	and	with	the	applicable	parts	of	this	chapter	that	apply	to	the	operation;	and

(ii)	For	compensation	or	hire,	provided	the	person	is	qualified	in	accordance	with	this	part	and	with	the	

applicable	parts	of	this	chapter	that	apply	to	the	operation.

Unlike	a	conventional	aircraft	that	carry	pilot,	passengers	and	cargo,	the	proposed	sUAS	are	remotely	

controlled	and	carry	no	persons	or	cargo.		The	sUAS	are	capable	of	a	high	degree	of	flight	automation	and	

employ	technical	capabilities	that	limit	the	potential	for	operation	in	an	unintended	manner.		It is	the	

petitioner’s	belief	that	given	the	size,	weight,	speed,	operating	environment and	operating	capabilities	of	the	

sUAS,	an	equivalent	level	of	safety	may	be	obtained	by	stipulating	the	sUAS	PIC	must	hold	either	an	airline	

transport,	commercial,	private,	recreational,	or	sport	pilot	certificate.	The	PIC	must	also	hold	a	current	FAA	

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

Rico,	a	territory,	a	possession,	or	the	Federal	government.	The	PIC	must	also	meet	the	flight	review	

requirements	specified	in
10

14	CFR	§	61.56	in	an	aircraft	in	which	the	PIC	is	rated	on	his	or	her	pilot	certificate.		The	FAA	has	issued	several	

exemptions	to	this	regulation:	see	Exemptions	Nos.	11284,	11281,	11282	and	11296.

14	CFR	§	91.7(a)	– Civil	Aircraft	Airworthiness

Regulation	91.7	stipulates	(a)	No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	condition.

Should	this	exemption	be	granted	allowing	commercial	operation	of	sUAS	without	an	airworthiness	certificate,	

no	FAA	regulatory	standard	will	exist	for	airworthiness	of	the	sUAS.		An	equivalent	level	of	safety	will	be	

obtained	by	ensuring	compliance	with	sUAS	operator	and	maintenance	manuals	and	safety	checklists	prior	to	

each	flight.

14	CFR	§	91.121	– Altimeter	Settings

Regulation	91.121	requires	that	(a)	Each	person	operating	an	aircraft	shall	maintain	the	cruising	altitude	or	

flight	level	of	that	aircraft,	as	the	case	may	be,	by	reference	to	an	altimeter	that	is	set,	when	operating— (1)	

Below	18,000	feet	MSL,	to— (i)	The	current	reported	altimeter	setting	of	a	station	along	the	route	and	within	

100	nautical	miles	of	the	aircraft;	(ii)	If	there	is	no	station	within	the	area	prescribed	in	paragraph	(a)(1)(i)	of	

this	section,	the	current	reported	altimeter	setting	of	an	appropriate	available	station;	or	(iii)	In	the	case	of	an	

aircraft	not	equipped	with	a	radio,	the	elevation	of	the	departure	airport	or	an	appropriate	altimeter	setting	

available	before	departure.

Conventional	aircraft	are	provided	altitude	data	by	a	barometric	altimeter	that	is	most	commonly	set	to	a	local	

barometric	pressure	and	therefore	reports	altitude	relative	to	MSL	(Mean	Sea	Level).		sUAS	operations	are	

restricted	to	altitudes	no	greater	than	400	feet	AGL	(Above	Ground Level).		For	those	sUAS	with	a	barometric	

sensor,	greater	utility	and	an	equivalent	level	of	safety	will	be	obtained	by	setting	the	altimeter	to	read	“zero	

altitude”	when	the	sUAS	is	on	the	ground	prior	to	takeoff	thus	providing	an	AGL	altitude	readout.		If	no	

barometric	sensor	is	aboard	the	sUAS,	a	GPS	derived	altitude	similarly	set	to	zero	at	the	takeoff	point	will	

provide	an	equivalent	level	of	safety.		The	FAA	has	issued	several	exemptions	to	this	regulation:	see	

Exemptions	Nos.	11066,	11065,	11062	and 11063.

14	CFR	§	91.151	– Fuel	Requirements	for	Flight	in	VFR	Conditions

Regulation	91.151	stipulates	that	(a)	No	person	may	begin	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.	(b)	No	person	may	begin	a	flight	in	a	rotorcraft	under	VFR	

conditions	unless	(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	first	

point	of	intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	20	minutes.

This	regulation	is	written	based	on	the	capabilities	of	traditional	civil	aircraft	which	typically	have	flight	times	

with	full	fuel	of	several	hours.		For	the	majority	of	sUAS	which	have	flight	times	of	an	hour,	or	much	less,	this	

regulation	would	effectively	deny	an	ability	for	the	sUAS	to	operate.		The	petitioner	submits	that	an	equivalent	

level	of	safety	will	be	obtained	by	requiring that	no	sUAS	flight	will	begin	unless	(considering	wind	and	forecast	
11

conditions)	there	is	enough	fuel	(battery)	to	fly	the	planned	route	to	the	first	point	of	intended	landing	and	

land	with	25%	of	battery	capacity in	reserve. This	restriction	would	be	more	than	adequate	to	return	the	sUAS	

to	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area.	

The	FAA	has	issued	several	exemptions	to	this	regulation:	see	Exemptions	Nos.	2689F,	5745,	10673	and	10808.

14	CFR	§	91.405(a),	91.407(a)(1),	91.409(a)(2),	91.417(a)	and	(b)	– Maintenance	Inspections

Regulation	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...”		Regulation	91.407(a)(1)	

similarly	makes	reference	to	requirements	in	Part	43.		Regulation	91.409(a)(2)	requires	an	annual	inspection	

for	the	issuance	of	an	airworthiness	certificate.		Regulation	91.417(a)	and	(b)	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.

Exemption	from	these	regulations	is	needed	because	Part	43	and	these	sections	apply	only	to	aircraft	with	an	

airworthiness	certificate.		An	equivalent	level	of	safety	will	be	obtained	by	requirement	that	each	sUAS	will	

have	a	flight	and	maintenance	log.		Maintenance	and	inspections	will	be	accomplished	in	accordance	with	

manufacturer	recommendations.		The	FAA	has	issued	several	exemptions	to	this	regulation:	see	Exemptions	

Nos.	11066,	11062,	11067A	and	11065.

14	CFR	§	91.103	– Preflight	Action

Regulation	91.103	stipulates	Each	pilot	in	command	shall,	before	beginning	a	flight,	become	familiar	with	all	

available	information	concerning	that	flight.	This	information	must	include—(a)	For	a	flight	under	IFR	or	a	

flight	not	in	the	vicinity	of	an	airport,	weather	reports	and	forecasts,	fuel	requirements,	alternatives	available	if	

the	planned	flight	cannot	be	completed,	and	any	known	traffic	delays	of	which	the	pilot	in	command	has	been	

advised	by	ATC; (b)	For	any	flight,	runway	lengths	at	airports	of	intended	use,	and	the	following	takeoff	and	

landing	distance	information: (1)	For	civil	aircraft	for	which	an	approved	Airplane or	Rotorcraft	Flight	Manual	

containing	takeoff	and	landing	distance	data	is	required,	the	takeoff	and	landing	distance	data	contained	

therein;	and

(2)	For	civil	aircraft	other	than	those	specified	in	paragraph	(b)(1)	of	this	section,	other	reliable	information	

appropriate	to	the	aircraft,	relating	to	aircraft	performance	under	expected	values	of	airport	elevation	and	

runway	slope,	aircraft	gross	weight,	and	wind	and	temperature.

The	petitioner	seeks	exemption	to	the	extent	that	an	FAA-approved	Flight	Manual	is	required.		An	equivalent	

level	of	safety	will	be	provided	by	following	the	Operations	Manual	provided	by	the	manufacturer.		

Additionally,	the	PIC	will	conduct	preflight	actions,	to	include	performing	all	required	checklists,	reviewing	

weather,	flight requirements,	battery	charge,	landing	and	takeoff	distance,	aircraft	performance	data,	and	

contingency	landing	areas,	before	initiation	of	flight.

14	CFR	§	91.109	– Flight	Instruction
12

Regulation	91.109	stipulates,	in	part,	that	(a)	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.

sUAS	by	their	design	do	not	have	fully	functional	dual	controls.		Flight	control	is	accomplished	through	the	use	

of	a	control	interface	that	communicates	with	the	aircraft	via	radio.		Given	the	size,	speed	and	limited	

operational	parameters of	the	sUAS,	an	equivalent	level	of	safe	training	can	be	performed	without	dual	

controls.		The	FAA	has	issued	several	exemptions	to	this	regulation:	see	Exemptions	Nos.	11066,	11062,	

11067A	and	11065.

14	CFR	§	91.119	– Minimum	Safe	Altitudes

Regulation	91.119	stipulates,	in	part,	that,	Except	when	necessary	for	takeoff	or	landing,	no	person	may	

operate	an	aircraft	below	the	following	altitudes:	(a) Anywhere. An	altitude	allowing,	if	a	power	unit	fails,	an	

emergency	landing	without	undue	hazard	to	persons	or	property	on	the	surface.	(b) Over	congested	

areas. Over	any	congested	area	of	a	city,	town,	or	settlement,	or	over	any open	air	assembly	of	persons,	an	

altitude	of	1,000	feet	above	the	highest	obstacle	within	a	horizontal	radius	of	2,000	feet	of	the	aircraft.	(c) Over	

other	than	congested	areas. 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.

An	exemption	to	91.119(c)	is	required	because	sUAS	operations	will	be	conducted	at	altitudes	no	greater	than	

400	feet	above	the	surface.		The	size,	speed,	weight	and	limited	operational	parameters	of	the	sUAS	allow	for	

an	equivalent	level	of	safety.

WHY	GRANTING	THIS	PETITION	IS	IN	THE	PUBLIC	INTEREST

As	introduced	above,	the	requested	exemption	would	authorize	the	Applicant	to	perform	commercial	

operations	with	sUAS	that	will	provide	significant benefits to	the	public	interest:

1. The	commercial	use	of	sUAS	to	perform	marine research	and	educational	activities	at	The	University	of	

Delaware in	support	of	government	entities, private	research	institutions,	scientific	studies	and	

environmental monitoring,	all	of	which	are	critical	to	the	well-being	of	the	general	public. This	includes	

rapid	studies	of	coastal	geomorphology	crucial	to	storm	assessments	and	sea	level	rise,	water	quality	

studies,	environmental assessments	and	critical	habitat	mapping.

2. A	significant	reduction	in	costs	to	conduct	research,	training	and	education	programs.	At	present,	our	

marine	research	programs	that	use	aerial	surveys	can	cost	tens	of	thousands	of	dollars	per	day.	By	

incorporating	sUAS	into	these	programs	we	can	incur	significant	savings	and	more	efficiently	and	safely

6conduct	research	in	the	public	interest

3. The	use	of	sUAS	will	decrease	congestion	in	the	National	Airspace	System	along	with	reducing the	

noise	and	air	pollution	generated	during	traditional	manned	aircraft	flight	operations.

4. When	using	sUAS	to	complement	field	personnel,	they reduce	safety	concerns	when	gathering	data	

from	inaccessible	or	unstable/unsafe	areas	and	in	extreme	weather	or terrain.

5. Operation	of	sUAS	will	substantially	reduce	the	risk	to	life	and	property	in	the	air,	and	on	the	ground,	

which	is	commonly	associated	with	traditional	manned	aircraft	flight	operations for	marine	science	
13

missions.

6. Similar	to	the	current	manned	aircraft	flight	operations	in	marine	science	that	have	been	conducted	for	

many	decades,	sUAS	used	for	similar	tasks	will	not	generate	any	new	privacy	issues.

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." Approval	of	this	exemption	will	allow	for	

safer,	more	efficient	and	less	costly	marine	science	missions,	and	produce	much	higher	data	quality.

SUMMARY	OF	REGULATIONS	FROM	WHICH	PETITIONER	SEEKS	EXEMPTION	OR	RELIEF

14	CFR	Part	21,	Subpart	H

14	CFR	Part	27

14	CFR	45.23(b)

14	CFR	61.113(a)(b)

14	CFR	91.7(a)

14	CFR 91.9(b)(2)(c)

14	CFR	91.103

14	CFR	91.109(a)

14	CFR	91.119

14	CFR	91.121

14	CFR	91.151(a)

14	CFR	91.203(a)(b)

14	CFR	91.405(a)

14	CFR	91.407(a)(1)

CFR	91.409(a)(1)	and	(a)(2)

14	CFR	91.417(a)(b)	

Appendices:

A – DJI Phantom 2 Vision+/Phantom 3 – Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet

C – Link to DJI Phantom 3/2 Vision+ Manufacturer’s User Manual

D – Link to DJI Inspire 1 Manufacturer’s User Manual

E- UDel RDL sUAV Logbooks

F- UDel RDL sUAS SOP all aircraft
14

APPENDIX – A

DJI PHANTOM 2 VISION+/PHANTOM 3 TECHNICAL SPECIFICATIONS

The University of Delaware only utilizes safe and reliable sUASs. DJI is an industry leader in small UAS 

production. DJI sUASs are loaded with ground breaking software enabling the user to set parameters which will 

not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a

predetermined and set distance. In addition, DJI software provides real-time altitude and location information to 

the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 3/Phantom 2 Vision+

.

1.1.1 Aircraft 

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s 

1.1.1.5 Max Tilt Angel - 350 1.1.1.6 Max Ascent Speed – 6m/s 

1.1.1.7 Max Descent Speed – 2m/s 

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

.

1.1.2 Gimbal 

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030 

1.1.2.3 Controllable Range – Pitch: -900 - 00 

1.1.2.4 Maximum Angular Speed – Pitch: 900/s 

.1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 32F - 104F (0C - 40C)

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording – 1080p30 & 720p

 4.1.3.6 Recording Field of View - 1100/850 

.1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm 

1.1.4.4 Transmitter Power – FCC Compliance: 100mW 

1.1.4.5 Working Voltage – 120mA@3.7V 

1.1.5 Range Extender 

1.1.5.1 Operating Frequency – 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm 
15

1.1.5.4 Power Consumption – 2W

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

The University of Delaware only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will 

not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a

predetermined and set distance. In addition, DJI software provides real-time altitude and location information to 

the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Inspire 1

.

2.2.1 Aircraft 

2.2.1.1 Model – T600 

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350 

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude – 4500m 

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 20 minutes 

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 14F to 104F (-10C to 40C) 2.2.1.15

Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3 

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.030 

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 

2.2.3.1 Name – X3 
16

2.2.3.2 Model – FC350 

2.2.3.3 Total Pixels – 12.76M 2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940 

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 

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

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 

.

2.2.4 Transmitter

2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C)

2.2.4.6 Battery – 600mAh LiPo 2S 

APPENDIX – C

DJI Phantom 3 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en_0915.pdf

DJI Phantom 2 Vision+ Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.6_en.pdf

APPENDIX – D

DJI Inspire 1 Manufacturer’s User Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

APPENDIX – E

APPENDIX – F
University of Delaware Robotic Discovery Laboratory

sUAS Pre-flight Inspection

Date:

General Location: 

UAS Serial #

Airframe Check:

Check the central body, props and fuselage for cracks or other 

damage.

Verify that the ground sensors and camera are free of obstructions and 

that the lens is clean.

Inspect the propellers for chips or cracks.

Inspect the battery for signs of damage or swelling.

Record Battery Number: 

Camera Payload:

Check the camera settings for flight 

conditions Check that the camera has a 

fresh memory card

Ensure that the Start area is clear of obstacles.

Check that the Home area and landing approach are free of obstacles.
Inflight)Standards (BACK)OFCARD)

Do not take risks! Your own safety and that of your environment depend on the good behavior

of the pilot.

Always keep a distance from people, animals and objects. Improper operation can cause serious

injury and property damage!

Never fly towards viewers and avoid spectatoroverflights.

Keep in mind that viewers could approach the Copter without being aware of potential 

dangers. Only fly in sight. In the case of a manual control, you must be able to see the 

position and attitude. Never rely 100% on autonomous flight features such as GPS, compass,

or altitude control. You must always be able to take manual control of theCopter.

Do not fly in blocked air space, such as in the vicinity (less than 5 miles) of airports, etc.

Pay attention to undervoltage warning indicators – failure to comply with manufacturers

discharge specifications can cause damage to the battery.

Note: Confirm GPS 3D fix prior to using the navigation functions. The LED light on top of the

GPS in blinking mode will indicate that you have sufficient satellites to utilize GPS navigation. 

The Copter will automatically remember this as home once the gyros are calibrated. Be sure 

that this home position is clear of potential obstructions as the Copter may over run the home 

position by 1-2 meters.

Warning: Home position is determined in the position the Copter aquires a GPS 3D fix 

BEFORE take off.

You should make sure you have GPS 3D fix prior to motor start otherwise it will return to the 

'home location' logged from the previous flight. Fluctuation in GPS navigation between 1-3

meters should be anticipated.

Preflight Checklist (FRONT OF CARD)

Visual Inspection

a. OVERVIEW: Perform an overall visual check of the aircraft prior to powering systems.

b. FRAME: All frame structural components in good condition.

c. FASTENERS: All mission critical screws, nuts and clamps secure and tightened to

inch/lbs.

d. CONNECTORS: Ribbon, molex and bullet connectors properly installed and firmly seated.

e.CLEAN: Check all electrical control surfaces to be clear of dirt and grime.

f. MOTORS: Motor mounts and motors secure and aligned to the airframe.

g. PROPELLER: Propellers in good condition and free of any deformation.

h. PROPELLER: Propellers installed snug to propeller mount.

i. PROPELLER: Check for correct propellerrotation.

j. PROPELLER: Motors/Propellers spin smoothly and there are no objects in the rotational

plane.

k. RECEIVER: Confirm an unobstructed satellite receiver location and 

connection. 

l. WIRING: Secure all loose/slack wiring to adjacent frame components.

n. DATA: MicroSD card installed and seated.
Battery)and)Power Supplies

a. MAIN: Flight pack battery fully charged and all cells balanced.

b. RADIO: RC transmitter battery showing propervoltage.

c. AUX: Auxillary batteries (e.g. iPad/iPhone) fully charged.

d. MOUNT: Check secure attachment of all Copter batteries and power supplies.

Transmitter/Reciever

a. POWER: Always power the radio transmitter prior to powering systems on the Copter.

b. MODEL: Verify correct model type, battery voltage on transmitter screen.

c. TEST: Range test your transmitter and receiver out to expected flight path.

d. TRIM: Check that all stick trims at center position.

e. SWITCH: All auxillary switches (GPS and Navigation control) are in the OFF position.

f. STICK: Throttle stick on the transmitter in the down/off position.

Tool Software

a. ERROR: Interface connection to Copter tool displays “no error” status.

b. LIGHT: LED-green (no error) status on all mission critical PCB controlboards.

c. POWER: Flight pack voltage gauge correct in GUI

d. NAVIGATION: GPS navigation fail-safes set within user-defined parameters.

Environment

a. AIR: Ideal flight conditions are light/no winds and no moisture.

b. SOLAR: Check: Current Solar Data (from NOAA). Solar X-ray flares will have an effect 

with the Geomagnetic Field. This can translate into erratic autonomous flight control when 

using the GPS navigation. Daily updates can be found here:

http://www.n3kl.org/sun/noaa.html

c. PUBLIC: Determine if barriers or crowd control personnel are needed to protect public from

harm.

General maintenance as per RCAPA guidelines: Any damage or worn out parts need to be 

replaced or repaired before the next flight occurs. Log books are not only used to log aircraft 

flight times with a running total, but to record all maintained, i.e. component installation, 

repairs, and replacement. Each aircraft should have an identifying number that can be connected 

to the aircraft and corresponding aircraft log book. The logbook should be kept with the aircraft. 

All repaired aircraft shall be tested, deemed airworthy, and so noted in the maintenance logbook

before resumption of AP duties.
UAS Flight Plan

Date YYYY _ MM _DD _ _

Time GMT :

Pilot

PIC

Observers

General Location

Aircraft serial #

Daily flight number XX

Battery Capacity

Battery serial number (s)

Flight plan name

Mission area name

Payload

Camera Mode

ISO settings

Shutter speed

F-Stop

Environmental

Wind direction Deg

Wind speed m/s

Temperature

Landing type Land/Boat/Water

Launch time GMT :

Land time GMT :

Flight log file name

Land Voltage

Battery Capacity used
Pilot!Flight Log

Pilot: Aircraft Type Serial # Location T/O time (hh:mm) Flight duration

(min)

Wind Speed Direction Visibility Takeoff/Land 

type

Date

Pilot Signature Total hours in past 90 days xxx

(I certify the entries 

in this log are true)

Total hours to date xxx
UAS!Maintenance!Log

UAV 

Maintenance

Log

Date Aircraft Seri

al 

Num

ber

Maintenance / Fault

description

Parts Replaced Service Technician Inspected By Pilot Test flight 

Date

Test Flight 

Time

Test

Flight 

Log

Certifie

d 

Airwort

hy by
UD Robotic Discovery Laboratory

RDL sUAS Standard Operating Procedures

1.0 Purpose

The purpose of this document is to establish standard operating procedures (SOPs) for the use of 

sUAS in Marine Science and Coastal Geomorphology Projects in the Robotic Discovery Laboratory 

and the University of Delaware

2.0 Scope

These SOPs apply to all sUAS flight conducted during Marine Science and Coastal 

Geomorphology Projects in the Robotic Discovery Laboratory and the University of Delaware

3.0 Definitions

Small Unmanned Aerial Vehicle (sUAV) – A small, remotely piloted aircraft, often with a GPS, 

inertial measurement unit and sensor system on board.

Small Unmanned Aircraft System (sUAS) – The collective term for a UAV, base station, 

communications equipment, launch and recovery devices, and other ancillary equipment 

required to operate the sUAV.

DJI Phantom 2+/Phantom 3/Inspire sUAS – The sUAS developed by DJI, is a 4 rotor helicopter. 

It employs DJIs proprietary electronics for several layers of control from full autonomous 

waypoint flights, Altitude hold, position hold, come home and emergency landing procedures. 

The Phantom 2+ and Phantom 3 models are comprised of 4 rotors mounted on a plastic central 

body. 

Flight Area – The horizontal and vertical space in which flight operations for the sUAS are 

planned.

DJI Go – The Phantom sUAS’s proprietary flight planning and monitoring software.

LiPo battery fireproof bag – This flame retardant bag is a convenient way of safeguarding your 

LiPo batteries during charging, transit, and storage.

4.0 Responsibilities

sUAS Operator – The sUAS operator is responsible conducting pre-flight inspections to ensure 

the sUAS is in safe working order. The operator is responsible for operating and maintaining 

contact with the sUAS at all times during flight operations. The operator is responsible for 

executing evasive safety actions if a visual observer reports another manned or unmanned 

aircraft in the vicinity of the flight area.

Visual Observers – Visual observers are responsible for being the operator’s and the external 

pilot’s eyes and ears during flight operations. Prior to flight operations, one or more visual 
UD Robotic Discovery Laboratory

observers will position themselves around the flight area such that they collectively have a clear 

view of the sky in all directions. During the flight, the visual observers are responsible for 

communicating to the operator the location of any people, wildlife, and/or aircraft in the vicinity of 

the flight area.

5.0 Equipment Checklists

5.1 sUAS equipment checklist

Complete the equipment checklist for each below prior to travelling to the flight area.

Phantom/Inspire

____ Helicopter frame c/w motors and flight electronics

____ Camera gimbal

____ Ground station monitor controller

____ Landing floats for water operations

____ micro SD card for camera

____ Spare propellers (2 x CW, 2 x CCW minimium)

____ Tool kit and spare parts kit.

____ DJI flight manual

____ DJI Flight logs

____ iPad or iPhone with DJI Go installed

___ 12 x GCP targets (if necessary)

___ LiPo battery fireproof bag

6.0 Pre-flight Inspections

Phantom 2+/Phantom 3/Inspire sUAS Pre-flight Inspection

Please refer to the relevant pre-flight inspection form and complete prior to each flight.

It is essential these checks are completed prior to each flight to ensure the aircraft is safe to fly 

and records are maintained.

7.0 sUAS Operations Standards

The standards of operations are designed to prevent sUAS accidents; comply with Federal state 

and local regulations; prevent injury to employees and the public; and reduce sUAS operating 

and repair costs.
UD Robotic Discovery Laboratory

7.1 General sUAS Operations Standards

1) Only authorized persons may operate RDL sUAS. In order to be considered authorized, 

personnel must have passed any require manufacturer training courses for the sUAS they will 

be operating.

2) All persons operating RDL sUAS must comply with RDL policies, as well as local, state and 

federal laws.

3) Proper sUAS usage is the responsibility of the operator.

4) The use of hand-held cellular phones and other devices while operating the sUAS is 

prohibited.

7.2 DJI Phantom/Inspire sUAS Operations Standards

1) Install the propellers, making sure the propellers are the correct rotation and tight.

2) Make sure the camera power is on, the memory card has sufficient space and that the battery 

has sufficient charge.

3) Check flight controller on the sUAV.

4) Enter flight log information.

5) Move the sUAV to flat and level ground away from obstructions and people.

6) Turn on the Transmitter and check the correct model is selected and there is at least 50% 

battery remaining.

7) Install and connect the battery (s) to the sUAV.

8) Start DJI software and verify all flight parameters are correct. 

9) After initialization check for a GPS lock and telemetry is received at the Transmitter.

10) Conduct a Transmitter range test.

11) Check all control switches are in the correct position for takeoff 

12) Calibrate the Gyro’s. It is important to do a calibration on land prior to going to sea.

13) Start motors and do a pre-flight motor test to ensure all controls are working satisfactorily. 

14) Ensure that the Start area is clear of obstacles.

15) Check that the Home area and landing approach are free of obstacles.

16) Check airspace and area of operation are clear of aircraft or personnel

Takeoff

1) Orientate yourself with the front boom pointing away from you, and confirm that the take-off 
UD Robotic Discovery Laboratory

direction in front of you is free of obstacles. Start the motors. Check all telemetry is correct. 

Utilize the auto take off. Confirm that the system is hovering properly then throttle up to a safe 

altitude.

In-flight Monitoring

1) Monitor the sUAV telemetry at least every 30 seconds. Battery voltage and capacity are 

critical as they can slump quickly. You must ensure you have at lest 25% battery capacity 

remaining at the end of the mission and that the aircraft has landed well before the battery 

warning alarm sounds.

2) Visual observers should maintain visual contact with the sUAV throughout the duration of the 

flight and should let the sUAV operator know if any other aircraft are in the vicinity of the flight 

area.

3) The operator should monitor the telemetry for any warnings or failures. At all times, the 

operator should be prepared to return the flight controls to full manual control and bring 

the aircraft back to the landing site or an alternate site if an issue arises.

Critical Failures

A critical failure is an error that occurs in flight that prevents the continuation of normal flight. 

The sUAV operator’s response to each critical failure is listed below as the emergency action.

1) Loss of GPS fix: the GPS position is no longer available which makes it impossible for the 

sUAV to navigate or position hold. 

Emergency action: In the first instance, take manual control. After 10 seconds return to GPS 

operation. If the Flight control fails to re-initialize the GPS control be prepared to return to full 

manual control and bring the aircraft back to the landing site or an alternate site if required.

2) Loss of Altitude control: the aircraft can no longer maintain automatic altitude control.

Emergency action: In the first instance, turn off the Altitude Hold and take manual control. After 

10 seconds return to Altitude Hold. If the Flight control fails to re-initialize control be prepared to 

return to full manual control and bring the aircraft back to the landing site or an alternate site if 

required.

3) Empty battery: the battery is completely empty. 

Emergency action: The flight control system should have brought the aircraft back to the home 

position on the low battery warning and initiate and emergency landing if the aircraft cannot 

reach the home position before the last critical battery level has been reached. If these systems 

fail it is important to give a loud verbal warning “ Aircraft Down” so the ground crew can 

prepare for an uncontrolled decent.

4) Motor malfunction: 1 or more motor (s) is not working.

Emergency action: Under most moderate payload conditions the sUAV will compensate for a 

loss of motor. If 1 or 2 motors fail the aircraft may go into a semi controlled decent. With more 

than 2 motors failed, the aircraft will descend rapidly and uncontrollably. It is important in either 
UD Robotic Discovery Laboratory

failure to give a loud verbal warning “ Aircraft Down” so the ground crew can prepare for an 

uncontrolled decent.

Post-flight sUAV Breakdown

1) Make note of flight time, land battery voltage and capacity used etc in the flightlog.

2) Remove the battery and place into a safe storage location: i.e. in fire-retardant LiPo battery 

bag.

2) Inspect frame for any damage.

3) Download flight logs and camera images from flight controller.

8.0 Personal Protective Equipment (PPE)

The site-specific job safety analysis for sUAS operations will require one or more of the 

following types of PPE are to be worn by sUAV operators and/or visual observers during flight 

operations.

1) Head Protection. Regulated by 29 CFR 1910.135; specified in ANSI Z89.1, Safety 

Requirements for Industrial Head Protection. Head protection equipment may include hard hats, 

hardhat liners, hoods, and protective hair coverings. 

2) Eye and Face Protection. Regulated by 29 CFR 1910.133(a); specified in ANSI Z87.1, Eye 

and Face Protection. Eye and face protection equipment may include safety glasses or other 

eyeware

3) Foot protection. Regulated by 29 CFR 1910.136; specified in ANSI Z41.1, Safety Toe 

Footwear. Foot protection equipment may include safety shoes, boots, and overboots. 

9.0 Asset Management

9.1 DJI Phantom/Inspire Maintenance

Cleaning and Storage

Following flight operations use a damp cloth to wipe off dirt from the sUAV. Never bring the 

sUAV in contact with water, as this may damage the electronics and airframe. Aircraft should be 

stored in a clean, cool and dry location away from direct sunlight.

Post-Flight Inspection

Following flight operations check the functions of the sUAV airframe and electronics using the 

following steps.

1. The motor must be clean and spin smoothly without friction to function correctly. Ensure that 

there is no sand or other obstructions within the motor. If there is something blocking the motor 

from spinning smoothly blow some air through the motor to dislodge the obstruction.

2. Check condition of all propellers. Ensure no cracks or signs of damage.
UD Robotic Discovery Laboratory

3. Check airframe for signs of damage.

4. Check all fasteners are tight.

4. Open photo folder on laptop and insure images were captured and that the coverage and 

quality is sufficient. Note any concerns on the flight logs and ensure a technician certifies the 

aircraft airworthy prior to any following operations.

Proper Battery Care

Proper care of your sUAV battery is important to prevent damage to your sUAV and to maximize 

flight time and safety. The sUAV is powered by a Lithium Polymer (LiPo) battery composed of 

cells connected in series. A single LiPo cell can have a range between 3 V (empty) and 4.2 V 

(full) in its normal operating range. 

This results in an empty battery voltage for a;

11.1v 3 cell battery pack of 9 V and a fully-charged battery voltage of 12.6 V. 

14.8v 4 cell battery pack of 12v and a fully charged battery voltage of 16.8v

A well-balanced and healthy battery should have all three cells at a voltage very close to 

each other and between 3 and 4.2 V. 

Discharging a Lipo battery below 3v/cell can cause irreversible damage and will severely limit

the flight time of the aircraft.

It is important, where possible, to return batteries to a storage voltage when not being used.

DANGER: Lipo batteries can be extremely dangerous if mishandled, shorted or 

overcharged. It is important to check the manufacturers specifications and the correct 

charge/discharge and capacity values are set on the charger prior to commencing 

charging. 

Always charge battery in the carrying case provided or a Lipo fire retardant bag.

Never leave batteries unattended while charging due to risk of fire

Avoid leaving the battery in direct sunlight due to risk of fire. 

The battery log should be filled out for each charge operation. This will provide necessary 

information on the number of cycles the battery has undergone and any deterioration of the 

battery. The flight technicians will monitor the battery log and remove and replace battery packs 

when they have reached the end of their service life.

When travelling with or not using the sUAV’s LiPo batteries, store them in the carrying case

provided or within a LiPo fire retardant bag.