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Figure 1: Skywalker X-8 UAV

Hobby Express Senior Telemaster Plus 

The Senior Telemaster Plus air vehicle is a fixed-wing, electrically-powered, tractor propeller-driven 

design of light wood construction with plastic film covering. The maximum gross weight is 9 lbs, the 

wingspan is 94”, and the maximum operating airspeed is 40 KCAS (sea level standard day). The 

operational ceiling is limited by unaugmented pilot line of sight to less than 400' AGL. The vehicle is 

shown below in 

Figure 2. 

Figure 2: Senior Telemaster Plus
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Freewing T-45

The Freewing T-45 air vehicle is a fixed-wing, electrically-powered, ducted fan-driven design of foam 

construction. The maximum gross weight is 8 lbs, the wingspan is 48.7”, and the maximum operating 

airspeed is 87 KCAS (sea level standard day). The operational ceiling is limited by unaugmented pilot 

line of sight to less than 400' AGL. The vehicle is shown below in Figure 3. 

 

Figure 3: Freewing T-45 (distributed by Motion RC) 

RnR SBXC 

The RnR SBXC air vehicle is a fixed-wing, unpowered or electrically-powered propeller-driven design of 

carbon fiber and foam construction. The maximum gross weight is 9.5 lbs, the wingspan is 170”, and the 

maximum operating airspeed is 87 KCAS (sea level standard day). The operational ceiling is limited by 

unaugmented pilot line of sight to less than 400' AGL. The vehicle is shown below in Figure 4. 

Figure 4: RnR SBXC 
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Risk Mitigation to Air and Surface 

Risk to non-participating aircraft in the National Airspace System (NAS) will be mitigated by operating in 

the inherently low-traffic airspace below 400’ AGL and greater than 5 nm away from charted airports 

(unless otherwise permitted). The use of visual observers and certificated pilots enable compliance with 

14CFR91.113 (collision avoidance). Risk to non-participating persons and property on the surface will be 

mitigated by operating in an unpopulated controlled-access area. 

Airworthiness Plan 

Vehicle airworthiness utilizes Scaled’s established procedures in use for our manned experimental 

aircraft. The pilot-in-command (PIC) will conduct a preflight airworthiness inspection of the aircraft 

prior to each flight in accordance with the intent of 14CFR91.7. This inspection will emphasize airframe 

and flight control system integrity, and verify expected loss-of-signal failsafe behavior and CG location. 

Preflight, normal, and abnormal flight procedure checklists will be prepared and documented in the 

Aircraft Flight Manual or other Operating Documents, which will be available to the PIC at all times prior 

to and during flight operations. Any unsatisfactory inspection findings will result in grounding the 

aircraft until they are resolved. Alterations to the vehicle airframe, systems, or payload between flights 

other than routine battery exchanges will be logged, and a functional test flight performed before 

resuming further operations. 

RF Compliance Plan 

Commercial off-the-shelf radio control equipment operating in the license-free 2.4GHz band will be used 

for initial test flights. Regulatory compliance of RF equipment is demonstrated by the manufacturer FCC 

certification supplied with the equipment. RF equipment will be operated in accordance with 

manufacturer’s instructions.

Crew Qualification Plan 

The required crew are PIC and visual observer. A flight test engineer may also be present to support the 

PIC per CRM best practices and aid in accomplishing flight research objectives. The PIC will hold a FAA 

Sport, Private, Commercial, or Airline Transport Pilot airman certificate and a current flight review in 

accordance with 14CFR61.56 to demonstrate knowledge of NAS regulations and operational procedures. 

Additionally, the PIC will have a minimum of 5 hours of PIC flight time in command of fixed-wing UAS or 

hobbyist R/C aircraft with a gross weight exceeding 10 lbs. Flights under this exemption will be logged in 

accordance with 14CFR61.51. 

The visual observer will be responsible for maintaining a lookout for any non-participating aircraft 

entering the operating area and reporting them to the PIC. The observer will be briefed on the specific 

operating area and reporting requirements by the PIC prior to the beginning of flying activities each day. 

The observer will be colocated with the PIC and in direct verbal communication at all times. 

Both PIC and visual observer will hold a valid US driver’s license or airman medical certificate (any class). 

They will self-certify prior to each flight that they are not experiencing any condition that would impair 

the safe execution of their duties in accordance with 14CFR61.53. 

Operation Plan 

SUAS operations will be conducted using the same established safety and operating procedures 

developed for our manned experimental aircraft operations. The planned operations will consist of 

fundamental flight maneuvers within the specified operating area to expand the aircraft’s flight 
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envelope and perform our desired flight research, below 400' AGL or lower as dictated by the certificate 

of authorization in effect at the time of flight. Maneuvers will include takeoffs, level flight, climbs, 

descents, turns, power on/off stalls, and landings. Aerobatic maneuvers are not planned. All flights will 

be planned with at least a 5 minute reserve energy allowance, and will be aborted in the event of an 

emergency or encroachment of non-participating aircraft or surface vehicles/personnel. Initial flights 

will be performed using direct remotely-piloted operations. Subsequent work may include the addition 

of an onboard autopilot system. No closed-set motion picture or television filming operations will be 

performed. 

All operations will be conducted during day (as defined by 14CFR1.1) VFR conditions within visual lineof-sight (VLOS) of the PIC and observer. Equivalent-level of safety to existing manned NAS operations is 

provided by visual observers scanning for non-participating aircraft and the ability of the PIC to 

command evasive maneuvers in accordance with 14CFR91.113 (“see and avoid”). Operations will be 

conducted over a controlled-access area that excludes non-participating persons and property from 

potential exposure to hazards. 

In the event visual contact is lost, the failsafe flight termination system will be activated by the PIC. In 

the basic remotely-piloted configuration (direct control, no autopilot), upon loss of transmitter contact 

the airborne avionics will be programmed to command a throttle closed, full up-elevator flight condition 

that will result in an immediate stall condition and descent to ground within the established flight test 

area. If an autopilot is installed, the loss of link function will be set to return the vehicle to the launch 

site and orbit at a safe altitude. This will provide an opportunity to resume normal operations. 

The minimum flight visibility will be 3 nm and all flights will be conducted 500’ below and 2000’ laterally 

clear of all clouds. Flight above clouds will not be conducted. These mitigate a potential loss of VLOS by 

the PIC, and meet the basic VFR minima prescribed by 14CFR91.155. Official weather conditions will be 

determined from the airport reporting site nearest to the operating area. This would typically be the 

Mojave airport (KMHV), Lancaster – Fox Field (KWJF), Air Force Plant 42 (KPMD), or Edwards AFB (KEDW). 

The intended operation area is controlled-access, unpopulated, high-desert scrubland in the Mojave 

Desert area of California. Launch and recovery locations will be sited and flights conducted to ensure all 

operations are conducted at least 5 nm away from all charted airports unless a letter of agreement with 

that airport’s management is obtained or otherwise permitted by a certificate of authorization. 

Summary of 14 CFR Section Exemptions Sought 

Section Relief Sought Reason Sought

Part 21, 

Airworthiness 

Certification

Self-certification of vehicle 

airworthiness

The nature of the airframe and systems 

differ substantially from those used in 

manned aircraft and evaluated by FAA 

testing. An in-house testing program will 

provide an equivalent level of safety.

Part 43, 

Maintenance

Part 43 Appendix B, 

recording of major 

repairs and 

alterations

Logbook entry in lieu of filing Form 

337

Recording such paperwork for this aircraft 

imposes an undue burden on FAA staff
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Part 45, Markings All markings as large as practical The prescribed character height exceeds 

the vehicle fuselage dimensions

Part 47, 

Registration

Registration in accordance with

current SUAS policy 

Comply with current SUAS policy

Part 61, 

Certification of 

Pilots

61.23(c), 

Operations required 

medical certificate 

or US driver’s 

license

Expand to include operating this 

UAS

The risk to the public of operating this UAS 

is less than a manned light-sport aircraft 

which is included in this section. The 

ground operating environment is benign 

for crew.

Part 91, General 

Operating and 

Flight Rules

91.105(a)(2), (b)

Flight crew

members at 

stations

Safety harnesses not required Aircraft is unmanned; crew station on 

ground and is not in a moving ground 

vehicle.

91.109(a)

Flight instruction

Dual control requirement Transition training of operators with 

substantial prior experience on other types 

can be safely performed without a dual 

control system.

91.119(c)

Minimum safe 

altitudes

Operation closer than 500’ to 

participating flight crew

Routine flight below 500’ AGL is desired to 

minimize conflict with other NAS users; this 

may result in flight closer than 500’ to 

participating personnel on ground.

91.151

Fuel requirements 

for flights in VFR 

conditions

Fuel interpreted as energy stored 

onboard for propulsion. 5 minute 

reserve energy allocation.

Minimizing onboard stored energy 

improves safety in the event of mishap. 

91.207 

ELT

No ELT required Aircraft is unmanned; no crew requiring aid

in the event of mishap.

91.407(a) Return to 

Service

Persons not certificated as 

mechanics/repairmen may authorize 

return-to-flight following training by 

a certificated repairman.

The nature of the airframe and systems 

differ substantially from those used in 

manned aircraft and evaluated by FAA 

testing. An in-house training program will 

provide an equivalent level of safety. 

91.405(a)

91.409

Inspections

Compliance via preflight inspection The simple nature of the airframe and 

systems enable a comprehensive preflight 

check to include all topics that would 

otherwise be addressed by 91.409(a) and 

(b) checks on a manned aircraft.