Alchemist Aerials

2409 Townlake Circle #221

Austin, TX 78741

Tel: 941-735-4039

Email: contact@alchemistaerials.com

ATTN: Andrzej Mrotek

2409 Townlake Circle #221

Austin, TX 78741

Tel: 941-735-4039

Email: aj@alchemistaerials.com

A. Alchemist Aerials’s Operations

B. Flight conditions

The sUAS will be flown in airspace under 400 feet above ground level (“AGL”) and

under controlled conditions on restricted, rural, private property. The sUAS will be used

to monitor two different types of sites, open pit mines and natural gas well pads.

The standard pre-flight and operational procedure will be as follows: 

1. Meet at security gate and complete pre-flight security appropriate to each site:

(described-below)

C. Flight Operations

The purpose of every sUAS flight will be to safely, accurately, and efficiently create survey

maps of open mines and to inspect well pads. The sUAS will collect photogrammetric pictures,

survey equipment to set ground control points, and use specialized photogrammetry software to 

process the data. The survey output will be 3D surface models and high resolution aerial 

photographs. 

Every sUAS flight will use at minimum a two man flight crew, both possessing engineering 

credentials. The Pilot in Command (PIC) will have substantial prior experience with operating the

sUAS, and possess a degree in professional engineering and land surveying. The assistant/spotter

will be a licensed engineer intern. 
2. Drive to area to be surveyed.

3. The Pilot in Command begins to ready sUAS for flight.

a. Set up hand held weather station on tripod.

b. Check over airframe, connections, and propellers for any damage during transport in

vehicle. While the airframe has the ability to disassemble easily for transport, the sUAS

will remain fully assembled. The sUAS is transported in the back of a truck which has

a camper shell and straps installed to secure the sUAS in place to minimize electrical

connection fatigue.

c. Install and calibrate camera in gimbal.

d. Turn on and ready lap top on tailgate.

e. Connect communication antennae to laptop.

f. Open Ground Station software and pull up pre-planned photogrammetry flight path.

g. Boot up secondary GPS for tracking and geocoding pictures.

h. Attach secondary GPS to sUAS.

i. Remove main flight Tx1from case and power up, verify voltage and settings.

j. Remove gimbal Tx from case and power up, verify voltage and settings.

k. Remove dual battery pack for flight, measure current voltage, log in battery manual.

l. Strap batteries securely on to sUAS, do not attached main power.

m. Move sUAS to take off point, approximately 30 feet from truck and crew.

n. Attach main power.

o. Listen to power up sequence of beeps for ESC and motors.

p. Using Flight Tx cycle through different control modes observing LED lights for good

connection and response.

q. Using Gimbal Tx cycle through all controls making sure the gimbal and camera

respond to commands.

r. Remove secondary GPS and hold in front of camera taking picture to record a time

stamp picture.

s. Reattach secondary GPS.

t. Set up traffic cones around sUAS with approximately a 20 foot radius. This is the

“home” area and the operators are not allowed inside this area while the electrical motor

is running.

u. Walk back to truck with both Tx.

v. Using Flight Tx activate engine power without moving throttle up. This checks that the

automatic throttle kill is working and also records the “home” point.

w. Using laptop Ground Station now select button connecting laptop to sUAS.

x. sUAS should appear on the screen, along with a recorded home point, battery voltage,

current altitude relative to the ground, and current velocity.

y. Upload flight path data to sUAS.

z. Verify good upload and connection.

aa. Verify weather from portable weather station.

bb. Record time and weather in Flight Log.

cc. sUAS is now fully prep and ready to go.

1

"Tx" represents radio transmitter for command and control. "Rx" represents radio receiver for 

command and control.
dd. Waits for secondary crew member to return from setting out GCP’s.

4. While Pilot in Command is readying the aircraft the second crew member is preparing the

Ground Control Points (GPC’s) and walking the site.

a. Power up and calibrates the survey grade GPS equipment.

b. Begin setting GCP’s and shooting center of targets with survey GPS.

c. While setting out GCP’s secondary crew is also making sure area is clear of all people.

5. Typically secondary crew and pilot finish at about the same time. Upon his return, the

secondary crew member sets the survey GPS to the side and sits next to the lap top and

camera Tx.

6. Pilot double checks take-off area is clear.

7. Pilot takes off flying to the approximate survey altitude.

8. Pilot instructs secondary crew member to initiate preprogrammed flight path.

9. Secondary Crew verifies that the Ground Station has good connection and is tracking the

sUAS.

10. Secondary crew then turns on the camera to take pictures at a continuous interval.

11. During entire preprogrammed flight Pilot always has visual line of sight and is prepared to

take over flight operations. Pilot’s Tx has a flight count down timer which is set to a

minimum of 20% battery reserve (Calculated based on prior field experience to safely return

the sUAS to safe landing with ample margin of error). The timer begins from the point the

throttle is moved out of its start position.

12. During flight secondary crew vigilantly monitors the Ground Station data (Voltage, forward

velocity, altitude, and estimated remaining time to complete the mission) and relays any

sudden changes or alerts to the pilot.

13. As the mission completes the Pilot informs the secondary crew he is taking back over control.

14. Secondary crew turns off the camera.

15. Pilot begins to land the sUAS.

16. After safely touching down the Pilot immediately goes and unplugs the main power. He then

checks the pictures to verify if the pictures are good and the mission was successful.

17. If successful secondary crew leaves to go pick up GCPs.

18. Pilot checks battery voltage and records in battery log.

19. Pilot records flight time in Flight Log.

20. Pilot turns off both Tx, secondary GPS, and camera.

21. Pilot looks over airframe to see if any damage or loose connections happened from the flight.

22. Pilot begins to pack all equipment back up for safe transport.

The flight crew will follow separate safety procedures for open mine surveying and for

natural gas well pad surveying. 

At the mine sites, the flight crew will check in at the security gate and go through a safety 

inspection. The crew will meet a mine representative who serves as a liaison in directing any mine 

personal and will have any dump trucks or bulldozers on the pile clear off before the crew begins 

its survey. After the flight, the mine representative will inform any trucks and bulldozers that they 

can begin operations again. (See Exhibit 1) 

At the well sites, the flight crew will unlock the security gate upon arrival and put on personal 

protection equipment, which includes hard hats, safety glasses, flame resistant coveralls, and steel 

toed boots. The crew then drives around the well pad site to inspect the flight area, set out ground 
control points, and take land based photographs, and parks just outside of the well pad entrance. 

(See Exhibit 2) 

IV. Privacy

There is little concern that the proposed flights will cause invasions of privacy because all

flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge. In addition, as the overflight areas will be rural, there is little to no chance that 

there will be inhabited houses in the visual area or other people who have not consented to being 

filmed or otherwise agreed to be in the area where filming will take place. No attempt will be made 

to identify any individuals filmed during the flights except in cases where they are trespassing 

upon or damaging customer property, or interfering with the applicant’s or its customers’ 

operations. 

V. Aircraft and Equivalent Level of Safety

Alchemist Aerials proposes that the exemption requested herein apply to civil aircraft that

have the characteristics and that operate with the limitations listed herein. These limitations 

provide for at least an equivalent or higher level of safety to operations under the current 

regulatory structure.

These limitations and conditions to which Alchemist Aerials agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 15 lbs.

2. Flights will be operated within line of sight of a pilot and observer.

3. Maximum total flight time for each operational flight will be 12 minutes. Flights will be

terminated at 20% battery power reserve should that occur prior to the 12 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL. Despite this limitation,

the majority of flights are anticipated to operate at no more than 270 feet AGL.

5. Minimum crew for each operation will consist of the sUAS pilot and the visual observer.

6. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s

activities. It will be mandatory that all personnel who will be performing duties in connection

with the operations be present for this briefing.

7. The operator will file any necessary paperwork in light of the exemptions with the

appropriate Flight Standards District Office (“FSDO”).

8. The operator will submit a written Plan of Activities to the FSDO at least one day before the

proposed operations begin.

9. Pilot and observer will have been trained in operation of sUAS generally and received upto-date information on the particular sUAS to be operated.
10. Pilot and observer will at all times be able to communicate by voice and/or text.

11. Written and/or oral permission from the relevant property holders will be obtained.

12. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental

agencies.

13. The sUAS will have the capability to abort a flight in case of unexpected obstacles or

emergencies.

14. If the multirotor and its controller disconnects during flight, the system’s failsafe protection

will come to the rescue and the multirotor will return to home and land automatically, rather

than flying off uncontrollably or landing at an unknown location.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual 

line of sight and national security – provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of applicant’s sUAS in the mining, oil, and 

gas inspection industries pursuant to Alchemist Aerials’s rules of operation appended hereto. 

VI. Public Interest and Safety

Use of the sUAS will increase ground safety by eliminating ground surveying on the mine

floor and help prevent wildfires and exposure to H2S gas at the well pads, Currently, under safety 

regulations by the Mine Safety and Health Administration (MSHA), the coal stockpiles are 

surveyed by employees who walks on the piles with survey grade GPS collection equipment. This 

task takes two employees several hours to complete. 

The surveyors currently face the following challenges: 

A. In the stockpiles:

1. The piles are extremely steep and high – up to 100 feet above natural ground. The coal

material of the piles is loose and shifts easily, which makes the sides of the piles very

hazardous and can lead to unexpected coal slides, which endanger the workers.

2. Inventories of coal piles are collected on a monthly basis. The coal has not been run

through a crusher, and the size of the coal can range from dust to 5’ chunks, which

create a tripping hazard for people walking through the piles. Using the sUAS will

eliminate tripping hazards to the surveyors.

3. During August and September, the heat index routinely breaks 100oF, which can lead

to heat related illness and injury. Using the sUAS instead will reduce the risk of heat

exhaustion to the surveyors as the time spent by the surveyors on the mine floor will

be reduced from up to three hours, to an hour or less.