Applewhite Aero ● applewhiteaero.com ● PO Box 46955 Seattle WA 98146 ● 206.762.5285

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Applewhite Aero

Safety Checklist

Milo UAS
Applewhite Aero

Milo Safety Checklist

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Rev. Date Pages Affected REVISIONS AUTHOR CHECK APPROVED

1 7/22/2014 ALL Updated Document JDP AC PGA

2 4/20/2015 47 Corrected Coordinate JDP AC PGA

3 4/29/2015 40 - 45 Correct Coordinate JDP AC PGA

Source Document

This document addresses requirements of 14 CFR 91.

Reference Document

This document references FAA Order 8130.34C.
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Table of Contents

1.Introduction ...............................................................................................................................................5

2.Aircraft Segment........................................................................................................................................5

A. Airframe ..............................................................................................................................................5

B. UA Performance Characteristics.......................................................................................................10

C. Propulsion System.............................................................................................................................13

D. Fuel System.......................................................................................................................................15

E. Electrical System...............................................................................................................................15

F. Flight Control Surfaces and Actuators..............................................................................................18

G. Payloads............................................................................................................................................19

3.Control and Communications Segment ...................................................................................................19

A. Avionics............................................................................................................................................19

B. Navigation.........................................................................................................................................20

C. UA Flight Controls............................................................................................................................21

D. Autopilot ...........................................................................................................................................22

E. Control Link......................................................................................................................................23

F. Lost Link and Flight Recovery..........................................................................................................26

G. Control Station ..................................................................................................................................27

4.Ground Support Equipment.....................................................................................................................29

5.Processes and Procedures........................................................................................................................30

A. Configuration Management ..............................................................................................................30

B. Software Management ......................................................................................................................30

C. Electronic Hardware Design and Testing..........................................................................................31

6.Operations................................................................................................................................................32

A. National Airspace System (NAS) Integration and Interaction..........................................................32

B. Flight Phases.....................................................................................................................................34

C. Operating Areas ................................................................................................................................38

(c) Royal City, Washington ....................................................................................................................43

D. Flight Envelope and Test Plans.........................................................................................................47

E. Operating History..............................................................................................................................48

F. Manuals.............................................................................................................................................48

7.Organizational Considerations.................................................................................................................49

A. Pilot/Crew Qualifications/Training...................................................................................................49

B. Maintenance ......................................................................................................................................50
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Table of Figures

Figure 1: The Milo UAS...............................................................................................................................5

Figure 2: Top View.......................................................................................................................................6

Figure 3: Front View.....................................................................................................................................6

Figure 4: Left Side View...............................................................................................................................6

Figure 5: Structural Analysis Diagrams.......................................................................................................9

Figure 6: Milo Flight Envelope: V vs. N ...................................................................................................11

Figure 7: Maximum Rate of Climb............................................................................................................12

Figure 8: Wiring Diagram...........................................................................................................................15

Figure 9: Ground Control Station Sample Screen ......................................................................................16

Figure 10: Milo UAS Electrical Diagram (battery capacity may vary) ......................................................17

Figure 11: Control Surfaces and Servos .....................................................................................................18

Figure 12: Avionics Architecture................................................................................................................19

Figure 13: Avionics Architecture Continued .............................................................................................20

Figure 14: RC Transmitter..........................................................................................................................22

Figure 15: Communications Diagram.........................................................................................................24

Figure 16: GCS Flight Plan Screen.............................................................................................................28

Figure 17: Pendleton Location Sectional....................................................................................................39

Figure 18: Pendleton Primary Test Area.....................................................................................................39

Figure 19: Pendleton Secondary Test Area.................................................................................................40

Figure 20: R-6701.......................................................................................................................................41

Figure 21: Whidbey Island Primary Test Area ...........................................................................................42

Figure 22: Whidbey Island Secondary Test Area .......................................................................................43

Figure 23: Royal City Location Sectional..................................................................................................45

Figure 24: Royal City Primary Test Area ..................................................................................................46

Figure 25: Royal City Secondary Test Area ..............................................................................................47

List of Abbreviations and Acronyms

ATC Air Traffic Control

COTS Commercial Off-the-Shelf

ESC Electronic Speed Control

FCC Federal Communications Commission

FRS Flight Recovery System

GCS Ground Control Station

GPS Global Positioning System

HIL Hardware-in-the-Loop

IAW In Accordance With

IMU Inertial Measurement Unit

LOS Line of Sight

NAS National Airspace System

NOTAM Notices to Airmen

OPA Optionally Piloted Aircraft

PIC Pilot in Command
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RC Radio Control

RF Radio Frequency

SIL Software-in-the-Loop

STA Special Temporary Authority

UA Unmanned Aircraft

UAS Unmanned Aerial System

VFR Visual Flight Rules

VMC Visual Meteorological Conditions
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1. Introduction

The safety checklist is designed to help the FAA evaluate those hazards that are unique to UAS, 

OPA, or OPA/UAS in support of issuing a special airworthiness certificate. Some safety items 

only require brief responses and others may not be applicable to a specific program. Additional 

information and supporting documentation may be required during the evaluation process.

Note: The applicant must identify all responses that contain information deemed 

proprietary, confidential, company-sensitive, subject to International Traffic in Arms 

Regulations (22 CFR subchapter M), or subject to any other classification that would 

restrict or prevent the information from public or foreign disclosure.

2. Aircraft Segment

A. Airframe

(1) Structure. Describe in detail the physical characteristics of the unmanned aircraft 

(UA). Include diagrams and schematics, as necessary.

The Milo UAS is made up of seven separate sections. The separate portions include the 

two wings, the horizontal tail, the two hatch covers, the payload bay cover, and the 

fuselage. The Milo UAS can be compactly stored in a carrying case allowing for easy 

assembly, disassembly, storage and transport.

Figure 1: The Milo UAS
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Figure 2: Top View

Figure 3: Front View

Figure 4: Left Side View

(2) Composition. Describe the various materials and where they are used in the construction of 

the UA. Include details of the fabrication and construction processes and procedures.

The Milo UAS is composed of composite skins and structural members with added 

support from balsa wood. 

a) Wings:

First Method:
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The wings are constructed using a layer of 5.8 oz. carbon fiber with balsa plates 

across the span of the wings sandwiched between the carbon fiber and a layer of 

4 oz. fiberglass. A few strips of additional unidirectional carbon fiber will be laid 

across the structure span wise for added stiffness, and finally three balsa spars 

will be laid in, one main spar which will bear the majority of the load and 

provide torsional stiffness, and also allow a carbon rod to be inserted for 

connection to the fuselage. Two additional smaller spars will span the wing 

allowing attachment of control surfaces and servos.

Second Method:

A foam core will be used. Two ribs will be joined into the wing at the root and 4 

inches into the span. A 7/8 in. carbon fiber rod will be inserted into the wing at 

an angle of two degrees creating the dihedral and a secondary threaded rod will 

be added at the wing root to set the incidence angle of the wing and to allow for a 

method of attachment between the wing and the fuselage. Wiring will be routed 

into the foam. With the foam prepped, composite materials will be adhered to the 

surface to create the actual structure. At least four 1⁄2 inch uni-directional carbon 

strips will be laid on the top and bottom of the wing to act as flanges and a 

Kevlar strip will be laid across the wing 3⁄4 chord from the leading edge to act as a 

living hinge. Finally a layer of 5.7 oz. 45/45 carbon will be laid on each side 

followed by a layer of 1.5 oz. fiberglass to give the wing additional bending 

strength as well as torsional stiffness. Once cured, two places will be cut in and 

reinforced for servo bays, and the living hinges will be cut to allow for the 

movement of the control surfaces. 

Horizontal Tail:

The construction of the horizontal tail is the same as the construction of the 

wings in method one, modified based on the difference in dimensions.

b) Fuselage:

The fuselage consists of two layers of 5.8 oz. carbon fiber along the length, until 

nearly the connecting point of the horizontal tail. At that point, fiberglass is used 

to construct the vertical tail. Four layers of four oz. are used, allowing for better 

communications with the aircraft. Three additional strips of unidirectional carbon 

fiber are laid along the inside of the body, roughly 45ofrom vertical, vertical, and 

-45ofrom vertical beginning from the point where the carbon fiber tube will 

insert into the fuselage. This will help distribute the load from the wings, and also 

provide added torsional stiffness and hoop strength. Finally additional 

unidirectional carbon fiber will be laid along the length of the tail boom, a top, a 

bottom, and one on each side to add bending stiffness in both relevant axes. 

Two bulkheads are placed in the forward part of the fuselage- determining the 

cavity for the payload. Both will consist of balsa sandwiched between layers of 

5.8 oz. carbon fiber. In the vertical tail, there are two spars made of 1/8th in. balsa 

and a handful of ribs. Additionally there is a cardboard tube inserted into the 

balsa framework to secure the Milo’s antenna.

c) Hatches:
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The access hatches are made with the use of molds as well. Once constructed, the 

hatches will be used to cut out the proper ports from the complete fuselage and 

laid into the structure, allowing added lips to be molded from fiberglass or carbon 

fiber to add some extra structure to make up for the break in the skin. Several 

small fasteners will be used to attach the hatches to the fuselage. 

d) General Construction:

As mentioned above, the Milo will be generally constructed following this 

general process: the skins will be laid into molds and vacuum formed to ensure 

correct parameters. Internal structure will be installed and the halves of each 

segment will be joined with proper adhesives and allowed to cure appropriately. 

Once the structure is build, control surfaces will be cut out, and Kevlar hinges 

will be applied, as well as all the necessary hardware for proper function. Once 

mechanical hardware is in place, all systems will be inserted into the Milo, 

utilizing carbon fiber break-out boards for security and ease of access. With 

systems laid, proper steps can be taken to ensure proper weight and CG location 

as directed in The Milo UAS Aircraft Flight Manual, and systems can be tested 

appropriately as directed by the Inspection and Maintenance Program. Following 

successful completion, the Milo UAS will be ready for flight. 

(3) Ability to Withstand Flight Loads. Describe the capability of the airframe structure to 

withstand expected flight loads and provide data/analysis to show that it is flutter-free throughout 

the flight envelope. Include any loads or stress analysis that demonstrates positive structural 

margins of safety during flight.

The Milo airframe has been constructed to be very durable. As discussed above, the 

structure of the Milo consists mainly of carbon fiber. The ratings of which are shown in 

Table 1 below:

Table 1: Carbon Fiber Strength Ratings

Ultimate Strength Ratings: Carbon Fiber

Direction Magnitude (psi)

Tensile Strength 50763

Compressive Strength 21755

In-Plane Shear Strength 5076

Structural analysis on the airframe shows that the loads acting on the Milo are well within 

the ratings of the carbon fiber. Figure 5 below demonstrate the expected loadings which 

will be acting on the UAS.
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Figure 5: Structural Analysis Diagrams

 

As can be seen in the figures above, the forces and stresses created by the loadings on the 

plane, are well within the abilities of the carbon fiber structure to handle. Based on the 

recommendations of Applewhite Aero, which can be seen in Figure 6 below, the Milo 

should not be flown above 3G’s of loading for aerodynamic considerations. Within that 

cap, the structure of the airframe is more than sufficient. Figure 5 above evaluate the 

stresses which will be acting on the wing. They show the transfer between the wing box 

and the two carbon rods which will attach the wings to the fuselage, and demonstrate the 

increase in stresses in those areas. 

The ultimate predicted loads that the Milo will undergo are shown in the table below:

Table 2: Ultimate Expected Loads

Ultimate Loads on Milo UAS

Load Type: Magnitude:

Shear Loading 37.5 lbf

Bending Moment 2925 in-lbf

Bending Stress 6181 psi

Shear Stress 11 psi
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From Table 1 and Table 2 above, it is clear that the stresses acting on the Milo are small 

compared to the ultimate strength of carbon fiber. Comparing the bending stress acting on 

the Milo, to the compressive strength of the carbon fiber, it is found that the wing can 

handle loads a factor of 2.34 beyond the factor of safety of 1.5. The shear stress acting on 

the centerline of the wing box is insignificant based on the amount of shear the carbon 

can handle. 

Flutter analysis will be performed during flight testing, ensuring the airframe will not 

flutter or diverge at any speeds within the flight envelope. Currently, since the structure is 

so strong and therefore the structural damping is so high, Applewhite Aero does not 

anticipate any flutter. 

(4) Unique Characteristics. Identify and describe any unique design characteristic(s) such as a 

hydraulic system, environmental control system, parachute, or brakes.

The Milo UAS does not have any unique design characteristics.

(5) Measurements:

(a) Wingspan: 131 inches

(b) Fuselage length: 73 inches

(c) Body diameter: ≈ 12 inches at widest point

(6) Weight:

(a) Empty: ≈ 15 pound

b) Maximum gross takeoff weight: ≈ 25 pounds

B. UA Performance Characteristics

(1) Maximum altitude: 18,000 feet AGL

(2) Maximum endurance: ≈ Predicted 60 minutes electric, 12 hours fuel

(3) Maximum range: ≈ 27 mile

(4) Airspeed:

(a) MTOW Cruise: ≈ 26 knots

(b) Maximum: ≈ 67 knots

The figure below shows the flight envelope of the Milo, specifying velocity limitations 

based on stall and force loadings acting on the airframe. 
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Figure 6: Milo Flight Envelope: V vs. N

(5) Maximum rate of climb:

The maximum rate of climb was determined from the power provided by the Neu 

brushless motor and the aerodynamic properties of the Milo UAS. The results are shown 

in Figure 7 below, which graphically demonstrates the maximum rate of climb and 

corresponding angle of climb.
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Figure 7: Maximum Rate of Climb

907.2 ft/min @ 23.98 degrees. Limited to 24 degrees by autopilot.

(6) Maximum rate of descent:

203 ft/min. @ -4.1 degrees. Limited to -4 degrees by autopilot.

(7) Maximum bank angle:

Limited to 45 degrees by autopilot.

(8) Turn rate limits:

The Milo UAS is designed to fly at maximum true airspeed of 66 knots. When taking into 

account a maximum bank angle of 45 degrees, the aircraft is limited to a maximum turn 

rate of 46.2 degrees/sec. At the recommended cruise speed of 26 knots, the maximum 

turn angle the Milo can perform is 27.5 degrees/sec.

(9) Identify any performance limitations due to environmental and meteorological conditions. 

Specifically, address the following items:

Performance limitations are intended to be investigated during experimental flight 

testing.

(a) Wind speed limitations:

(i) Crosswind:
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Expected crosswind limitations are 15 knots. The Milo UAS requires 

very short take-off and landing distance which minimizes risk during 

crosswind critical flight periods.

(ii) Gusts:

Based on current estimates, the Milo UAS could fly at recommended 

cruise until gusts reached 8 knots at empty weight and 14 knots at 

MTOW, which is demonstrated in Figure 6 above. Gusts exceeding these 

values cause potential for stall without active control. Gust limitations 

are intended to be investigated during flight testing.

(b) Turbulence restrictions:

Unknown. Turbulence restrictions are intended to be investigated during flight 

testing.

(c) Minimum visibility conditions:

Visual Flight Rules (VFR)

Visual Meteorological Conditions (VMC)

(d) Lighting (for example, daytime flights only):

Daytime only

(e) Outside air temperature (OAT) limits:

-10o C to 54o C (14o F to 130o F), based on recommended battery limits

(f) In-flight icing:

The proposed operating environment does not include operations in icing 

conditions.

C. Propulsion System

(1) Describe the propulsion system and its ability to provide reliable and sufficient power to 

takeoff, climb, and maintain flight at expected mission altitudes.

The propulsion system for the Milo UAS consists of:

1) Motor: Electric: Neu Brushless Electric Motor, kV = 2550 rpm/V or similar

 Piston: VVRC 2.2 HP gas engine or similar

2) Battery: Zippy Li-Po, 22.2 V, 12000 mAh or similar

3) ESC: ICE Castle 100A Brushless Electronic Speed Control or similar

4) Prop: 18.5x12 CFK Robbe fold prop or similar, direct drive

The static thrust (16.7 lbf) to weight (MTOW 25 lbf) ratio is 0.67:1, which will result in 

short take-off runs. At the best lift-to-drag ratio airspeed, the excess-thrust (15.6 lbf) to 

weight (25 lbf) ratio is 0.624:1, which will give steep climbs and excellent acceleration. 
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(2) Fuel-powered propulsion systems.

(a) What type of engine is used? VVRC 2.2 HP gas engine or similar 

(b) What type and capacity of fuel is used? 0.5 gal. Premixed unleaded gas and 2-stroke 

 Oil

(c) How is engine performance monitored? What status indicators and warning messages 

are provided to the pilot?

The fuel propulsion system will not be monitored from the ground. The only 

warning provided the ground will be through the elevation and airspeed 

indication relayed through the onboard telemetry, which is discussed below.

(d) Describe the most critical propulsion related failure modes and their impact on system 

operation.

To be determined in testing. The gas engine has been tested and used in RC 

applications. The engine will be properly mounted to aircraft to avoid adverse 

interplay between the airframe and engine.

(e) How does the system respond, and what safeguards are in place to mitigate the risk of 

engine power loss for each of the following?

i. Fuel starvation: The engine will shut down. The electric systems will be 

powered by a battery outside of the fuel propulsion system. This will allow 

controlled landing of the aircraft for retrieval.

ii. Fuel contamination: Same as above.

iii. Failed signal input from the control system: The system will go into the 

same failsafe configurations that are in place for failed communications with the 

electric setup. The preprogrammed system will return the aircraft to the 

launching point, where it will circle until telemetry can be regained.

iv. Engine controller failure: A spring will set the motor to idle. The system can 

then be landed in a controlled glide as mentioned above.

(f) Does the engine have in-flight restart capabilities? No, it requires manual starting on 

the ground.

(3) Electric-powered propulsion systems.

(a) What type of motor is used? Neu Brushless Electric Motor or similar

(b) What is the power output of the motor? 1450 Watts

(c) What current draw range does the motor have?

The propulsion system for the Milo UAS has a current draw range of 2.3 to 125

Amps. This corresponds to 0-100% throttle. During autonomous flight the 

throttle is limited to 75%, which corresponds to a maximum current draw of 94.3 

A.
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(d) Does the system have a separate electrical source? If not, how is UA power managed?

The system has separate power sources for the propulsion and the control 

systems. Propulsion power is managed through the ESC. The ESC contains a 

battery elimination circuit (BEC) which regulates power to the autopilot. A 

second system also equipped with a BEC is used to power the autopilot and 

systems for typical flight operations. Should it be required, the system can adjust 

to power the systems from either source- which is explained in further detail 

below.

D. Fuel System

The Milo UAS has a fuel system for the piston powered configuration. There will be a one half

gallon capacity stored in tanks under the wings in the fuselage. A proper mixture of unleaded fuel 

and single stroke oil will be used. A pressure gradient system inherent in the VVRC piston engine 

will pump the fuel from the tanks to the engine.

E. Electrical System

(1) Describe the electrical system and how it distributes adequate power to meet the requirements 

of the receiving systems. Provide a system level diagram showing electrical power distribution 

throughout the aircraft. Specifically, address the following items:

The Milo UAS electrical system is powered by two battery sources. Power is supplied 

from a 22.2 V battery with higher current capabilities to the ESC which then distributes 

power to the motor and potentially to the autopilot, should the redundancy system 

activate. 

A second battery systems exists for redundancy, and will be the main power source to the 

autopilot. This effectively isolates the power sources for the propulsion system and the 

control systems. However, should it be necessary, power can be diverted to the systems 

from the propulsion power supply.

Once power is into the autopilot, taken from either the systems batteries or the propulsion 

batteries as necessary, it will supply power to all the sensors and servos. A basic wiring 

diagram is shown in Figure 8. 

Figure 8: Wiring Diagram
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(2) How is power generated onboard the aircraft (for example, generator, alternator, batteries)?

Power onboard the Milo UAS is generated via Lithium Polymer 6-Cell battery, typically.

(a) If a limited life power source such as batteries is used, what is the useful life of the power 

source during normal and emergency conditions? How was this determined?

The useful life of the battery is predicted to be 60 minutes depending on the battery and 

charge. Typically, flights will not exceed 30 minutes so as to avoid failures due to power 

loss. More accurate flight time predictions will be determined with testing

(b) How are electrical power status and power remaining information displayed to the pilot?

Remaining battery power is displayed to the user by the ground control station (GCS) 

during flight. The remaining battery power percentage can be seen in Figure 6 on the 

middle left of the screen.

Figure 9: Ground Control Station Sample Screen

(3) Describe the source(s) of backup power in the event of loss of the primary power source.

(a) What systems are powered during backup power operation?

The Milo UAS does not feature a battery backup system. 

(b) Is there any automatic or manual load shedding?

The Milo UAS does not have load shedding capabilities.

(c) How much operational time does the backup power source provide? Include the 

assumptions used to make this determination.

The Milo UAS does not feature a battery backup system. 
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(4) Describe the electrical distribution architecture including all busses, regulators, switches, and 

converters.

The Milo UAS electrical system is shown below in Figure 7. There are effectively two 

power systems on the Milo. The first is the propulsion system powered by six cell

batteries (22.2 V, 12000 mA-h or similar). From the batteries the current flows through a 

power module. This will send current to an ESC which will provide 22.2 V and all 

necessary current to the electric motor. It will also send 5.3 V to a power redundancy 

regulator, as shown in Figure 10, which will allow the system to determine where to 

power the autopilot from. 

A unique feature of the Milo UAS, is the ground power-battery power switch, which 

allows an outside power source to be used on the ground for systems testing, which can 

avoid unnecessary battery drain before flight, thus increasing the total available flight 

time of the aircraft. 

Figure 10: Milo UAS Electrical Diagram (battery capacity may vary)

A second battery system provides a few layers of redundancy. Two 11.1 V batteries are 

in the circuit acting through a regulator to best balance the power draw, and adding a 

level of safety. Should either of the two batteries die or go bad mid-flight, full power 

capabilities will be accessible due to the regulator. From that point there is another 

regulator between the smaller battery system and the larger one. A BEC will supply 5.5 –

6 V to the regulator and therefore force the power to the autopilot to come from the 

smaller battery system. This will allow more flight time, but should both of the systems 

batteries die, the plane will still be fully controllable as the power to the control surfaces 

will then be supplied via the propulsion battery. If the main propulsion battery goes dead, 

the UAS will lose propulsion, but will maintain control of all surfaces allowing the plane 

to glide in a controlled manner to the ground. 

Once the autopilot has been supplied power from either power system, it will supply 5 V 

to all the servos and sensors allowing operation of the UAS.
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F. Flight Control Surfaces and Actuators

(1) Describe the design and operation of the flight control surfaces and servos/actuators.

Include a diagram showing the location of the control surfaces and servos/actuators.

The Milo UAS utilizes six control surfaces to control flight. The control surfaces consist 

of right and left ailerons, right and left flaps, elevator, and rudder. Each control surface is 

controlled by an independent servo which receives a control signal from the autopilot. 

See Figure 11 for a diagram of the control surfaces and corresponding servos. 

Figure 11: Control Surfaces and Servos

(2) Describe any potential failure modes and corresponding mitigations.

Failure modes for the Milo UAS include:

1) Lost communications with the GCS: The Autopilot is equipped with a failsafe 

that allows for a lost communication flight plan.

2) Power loss: The loss of power may result in a flight failure. All UAS flights must 

adhere to a strict flight time limit as determined by the battery capacity. Early 

warning for a power loss may be indicated by reduced performance of the motor. 

3) ESC failure: Failure of the ESC may result in flight failure. The ESC has been 

selected to provide the necessary current requirements without overheating. 

4) Servo or control surface failure: Failure of the control surfaces may result in 

flight failure. Control surfaces and servo linkage must be inspected prior to each 

flight. Servo travel must be verified before flight operations. 

(3) How does the system respond to a servo failure?

Failure of a servo may result in flight failure.

(4) What indications alert the pilot that a servo is stuck or malfunctioning?

A malfunctioning servo is indicated by erratic flight behavior, such as difficulty 

establishing level flight.
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G. Payloads

Several payload modules are in development which may be used to collect or independently 

stream video or telemetry. Payload modules may be externally or internally mounted. Payload 

modules may include one or more of self-contained video (e.g. go-cam), streaming video, and 

sensors (e.g. temperature). Power consumption, weight and balance, and impact on aerodynamic 

efficiency will be considered when payloads are used in flight testing.

3. Control and Communications Segment

A. Avionics

The avionics architecture can be seen in Figure 12. The Milo UAS features a radio module with a 

tail mounted communications antenna. A GPS antenna is located in the nose of the aircraft near 

the autopilot. An RC receiver connects to the autopilot.

Figure 12: Avionics Architecture
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Figure 13: Avionics Architecture Continued

B. Navigation

(1) How does the UA determine where it is? How does it navigate to its intended destination?

The Milo UAS is equipped with an autopilot with an integrated GPS. The GPS device is 

used to determine latitude, longitude, and altitude. The autopilot attempts to navigate the 

aircraft along a waypoint driven flight plan.

(2) How does the pilot respond to the following directions from air traffic control (ATC), a visual 

observer, or other crew member?

(a) Change of aircraft heading.

The vehicle will be reprogrammed for the new heading and the new 

configuration will be uploaded to the vehicle. If the instruction is required to be 

immediately followed, manual control will be implemented on the aircraft and 

the aircraft will be maneuvered to the new heading.

(b) Change of aircraft altitude.

The aircraft will be reprogrammed for the altitude and the new configuration will 

be uploaded to the aircraft. If the instruction is immediate, manual control will 

be taken and the vehicle will be maneuvered to the instructed altitude. 
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(3) What are the causes and effects of loss of heading or altitude?

Table 3: Responses to Various Hazards in Flight

Loss of Control of the Aircraft

Hazard Action Implementation

Loss of Propulsion Pilot will take manual control and land.

External Pilot 

Manual Override

Loss of Lift Due to 

Structural Failure or 

Weather Factors

Pilot will take manual control and land.

Loss of Heading, 

Altitude, and Position 

Information

Pilot will take manual control and land.

Loss of Radio Control 

Link

The autopilot will execute a 

preprogrammed lost link flight plan. Automatic 

Loss of Control 

Surface Performance Pilot will take manual control and land.

Operator Training,

External Pilot 

Manual Override

Loss of UAS Electrical 

Power

The UAS’s inherent stability will allow 

it to ride out a short blackout. 

Otherwise, the electric motor will 

shutoff and the flight will be 

terminated.

Automatic

Loss of 

GCS/Telemetry Link

No effect to manual control. In 

autonomous mode, the aircraft will 

execute a preprogrammed lost link 

flight plan.

External Pilot 

Manual Override, 

Automatic

(4) How does the system identify and respond to a loss of the primary means of navigation? Is 

there a backup means of navigation? How does the system respond to a loss of the secondary 

means of navigation?

If the primary means of navigation is lost, the aircraft may be manually piloted. The 

aircraft will only be operated within visual range of the pilot.

(5) Describe the procedures to test the altimeter system (see § 91.411). 

The Milo UAS uses a GPS to determine altitude. Altimeter system tests can be performed 

by raising and lower the aircraft and checking for correct response. 

C. UA Flight Controls

(1) Describe how the control surfaces respond to commands from the flight control computer.

During flight the autopilot sends control signals to each servo that correspond to the 

desired angular displacement of the servo. The autopilot measures the current roll, pitch,
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and yaw values and sends corresponding control signals to both stabilize flight and steer 

the aircraft.

(2) Describe how the pilot provides input to the control surfaces.

The pilot may control the aircraft through the use of flight plans or manual flight. Flight plans 

are entered through the GCS and consist of a series of waypoints which include GPS 

coordinates and altitude. Flight plans may be created or modified dynamically during flight.

Flight plans may be changed by qualified members of the ground crew, but must be checked 

by the PIC prior to being uploaded to the autopilot. Manual flight is controlled through the 

use of a RC transmitter shown in Figure 10. Thumb-sticks are used to control the roll, pitch, 

yaw and throttle.

Figure 14: RC Transmitter

(3) Flight control computer.

(a) Does the flight control computer interface with auxiliary controls that might cause an 

unintended action?

The flight control computer does not interface with any auxiliary controls.

(b) Describe the flight control computer interfaces required to determine flight status and 

to issue appropriate commands.

Flight status is determined by the autopilot in conjunction with the GPS sensor. 

Flight data is transmitted through a 2-way transmitter to the GCS.

D. Autopilot

(1) How was the autopilot system developed? What industry or regulatory standards were used in 

the development process?

The autopilot system was developed by DIY Drones using the ArduMega board.

(2) Is the autopilot a commercial off-the-shelf (COTS) product? If so, name the 

type/manufacturer and provide the criteria that was used in selecting the system.
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Yes. The Milo UAS is equipped with ArduPilot Mega autopilot. The ArduPilot Mega is 

an open source, low-cost autopilot, developed by DIY Drones.

(3) Describe the procedures you use to install the autopilot. How is correct installation verified? 

Reference any documents or procedures provided by the manufacturer and/or developed by your 

company.

The autopilot is installed by sliding the autopilot into fuselage compartment and 

connecting the wiring harnesses. In order to ensure correct installation the preflight 

inspection will be conducted. Refer to the Milo Aircraft Flight Manual or Flight 

Checklists for more information.

(4) Does the autopilot employ input limit parameters to keep the aircraft within structural limits? 

If so, provide a table of these limits. How were these limits validated?

Table 4: Throttle Limiting Values

PARAMETER DESCRIPTION LIMIT VALUE REMARKS

THR_MIN MINIMUM THROTTLE 0% GLIDING DESCENT

THR_MAX MAXIMUM THROTTLE 75%

TRIM_THROTTLE CRUISE THROTTLE 35% LEVEL FLIGHT

LIM_ROLL_CD MAX BANK ANGLE 45°

LIM_PITCH_MAX MAX PITCH ANGLE 24°

LIM_PITCH_MIN MIN PITCH ANGLE -4°

Limits are validated through field testing.

(5) Where do the autopilot commands reside once they are input by the pilot?

Autopilot commands are transmitted to the autopilot from the GCS where they are stored 

in the internal memory of the autopilot. 

(6) What type of software-in-the-loop (SIL) and hardware-in-the-loop (HIL) simulations have 

been performed? What was the outcome of the simulations?

Fully autonomous flight of another Applewhite Aero airframe, the Invenio UAS, which 

utilizes the same autopilot and GCS hardware and software has been flight tested

successfully. HIL testing has been performed to verify the correct sensor reading, control 

surface response, and GPS link. 

E. Control Link

(1) Provide a detailed control system architecture diagram that includes informational or data 

flows and subsystem performance. Include values for data rates and latencies, if known.

Figure 11 is a diagram of the communication system. The Milo UAS is subject to two

minor latency issues. The first is the GPS signal which updates at rate of 10 Hz. The 

second is the MAVLink protocol that manages data transmission between the GCS and 

the autopilot, which is sent at a rate of 50 packets per second.
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Figure 15: Communications Diagram

(2) Describe the control link(s) connecting the UA and the control station. Specifically address 

the following items:

(a) What spectrum will be used for the communications and how has the use of this 

spectrum been coordinated? If spectrum approval is not required, under what regulation 

is the use of the frequency authorized?

2.402 - 2.478 GHz, 902 - 928 MHz 

The use of this spectrum has been coordinated with the Federal Communications 

Commission and a Special Temporary Authorization has been obtained.

(b) What type of signal processing and/or link security (that is, encryption) is employed?

The Milo UAS uses the MAVlink communications protocol which has been 

demonstrated effectively in over 255 small aircraft. 

(c) What is the data link margin in terms of the overall link budget at the maximum 

anticipated distance from the control station? How was it determined?

The primary test area, Figure 19, has a maximum distance possible of 1.4 miles.

The antenna used in the GCS has a specified maximum distance of 1.8 miles 

(2896 meters), which corresponds to a minimum detectable power of -100 dBm. 

At a distance of 1.4 miles (2253 meters) the power received by the GCS is –98.6

dBm. This provides the Milo UAS with a data link margin of 1.4 dBm. All data 

used in the calculation of data link margin and link budget is calculated from 

using the Friis Transmission Equation.

(d) Is there a radio signal strength and/or health indicator or similar display to the pilot? 

How are the signal strength and health value determined and what are the threshold 

values that represent a critically degraded signal?
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Radio signal strength is displayed to the user via the wireless telemetry 

connection in the GCS. This can be seen in Figure 6 at the top middle of the 

screen. The wireless telemetry connection is presented to the user as a percentage 

of bad data packets. During operation the autopilot receives “MAVLink heartbeat 

messages” from the GCS. If no heartbeat message is received within a time limit 

(specified by a configuration file), the autopilot will execute a preprogrammed 

lost link flight plan.

(e) Does the system employ redundant and/or independent communications links? If so, 

how dissimilar are they?

RC communications and GCS communications are independent.

(f) For satellite links, estimate the latencies associated with using the satellite link for 

aircraft control and for air traffic control (ATC) communications.

The Milo UAS uses a MediaTek GPS, or similar, antenna with a 10 Hz update 

rate. 

(g) What are the potential sources of radio frequency (RF) interference within the 

proposed operating area and how are they monitored, managed and/or mitigated?

Access to the flight area is controlled by the Navy. Flights are coordinated so as 

to avoid interference. When interference is detected or suspected, flight 

termination should be considered.

(3) What design characteristics or procedures are in place to prevent or mitigate the loss of the 

control datalink due to the following:

(a) RF or other interference?

A pilot will take manual control of the aircraft.

(b) Flight beyond communications range?

A pilot will take manual control of the aircraft.

(c) Antenna masking during turns and pitch angles?

A pilot will take manual control of the aircraft. The fuselage is made mostly of 

carbon fiber which will mask the signal if angles are improper, but the vertical 

tail is made of fiberglass which will allow signal to propagate which will lessen 

the possibility of antenna masking.

(d) Loss of control station functionality?

A pilot will take manual control of the aircraft.

(e) Loss of UA functionality?

The loss of UA functionality may result in a lost data link depending on the 

particular failure. In the event of control surface failure or structural failure of the 

airframe, the autopilot will continue to receive and transmit data as long as the 

autopilot is powered and within range of the GCS.
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(f) Atmospheric attenuation including precipitation?

A pilot will take manual control of the aircraft.

F. Lost Link and Flight Recovery

(1) Lost link.

(a) How is it determined that the UA is experiencing lost link and how is this displayed to 

the pilot?

During operation the autopilot receives “MAVLink heartbeat messages” from the 

GCS. If no heartbeat message is received within a time limit (specified by a 

configuration file), the GCS considers the UAS to have lost the communication 

link. This is displayed to the user on GCS screen with a red ‘X’ covering the 

Wireless Telemetry Connection value. 

(b) Describe the operational procedures in the event of a lost link.

During the programming of the flight plan, a lost link flight plan is also 

programmed into the autopilot. In the event that a lost link occurs during 

autonomous flight, the autopilot will execute what is programmed into its flight 

plan. If the aircraft executes any maneuver that does not adhere to its flight plan, 

manual control will be taken by the pilot until the link is reestablished. 

(c) Describe the sequence the UA will follow in the event control link is lost.

The autopilot has two main options for lost link programming. The first will 

continue with the pre-programmed mission even though the link is lost. The 

second will send the aircraft to a recovery location immediately. 

(d) Describe how the aircraft will react during takeoff, climb, cruise, descent, and landing 

in the event of a lost link.

The autopilot has two main options for lost link programming. The first will 

continue with the pre-programmed mission even though the link is lost. The 

second will send the aircraft to a recovery location immediately. 

(e) How is it determined that the lost link functionality of the system is operational?

In the event of a return to launch flight plan operation the Milo UAS will visually 

alter current flight plan and return to the launch site. 

(f) How does the UA navigate when in the lost link mode?

During lost link mode the aircraft will use the onboard GPS to navigate.

(g) What parameters are used to define the lost link or return home point? How is this 

point selected? How is this point entered? What happens when the UA reaches this point?

The lost link/return home point is pre-designated as the recovery point. When the 

aircraft reaches this point, it will be instructed to circle until manual control is 

taken and the aircraft is landed.
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(h) Under what conditions is a return home mode both manually and automatically 

activated?

Return home mode will be automatically activated if it is pre-programmed to 

return home during the lost link procedures. Return home mode will be manually 

activated if weather falls below minimum VMC or for operational reasons, such 

as out of line of sight.

(i) What do the control station displays indicate during lost link? Is it clear that the data is 

stale or invalid?

In the event of lost link a red ‘X’ will display over the Wireless Telemetry 

Connection. (See Figure 6) Additionally, lost link may be evident to the crew

when the orientation and GPS data will no longer update.

(2) Flight Recovery System (FRS).

The Milo UAS does not include a FRS. 

G. Control Station

(1) Describe or diagram the control station configuration. Include screen captures of the control 

station displays.

The UAS is controlled by the GCS using the following functionality:

1) Flight Planner: Before a UAS flight, an appropriate crew member must first 

create flight plans and mission limits using the GCS Flight Planner screen. Prior 

to uploading them to the UAS, the PIC will check the flight plan. An example 

screen of the Flight Planner can be seen in Figure 12. This screen consists of 

three sections. The first section displays an overhead image of the flight zone. 

The second section consists of a list of waypoints for a flight plan. The final 

section is the action section where the crew members can send a flight plan to 

the UAS. Flight plans and flight boundaries can be created and sent to the 

autopilot from this screen. The Flight Planner can also be used to create and edit 

flight plans mid-flight.

2) Flight Data: After flight plans and mission limits are set, the pilot will monitor 

and control the UAS from the Flight Data screen. An example screen of Flight 

data is shown in Figure 6. The Flight Data screen consists of three sections. The 

first section is the Telemetry Data section in the upper left corner of the screen. 

The section directly below the Telemetry Data is the Action Section where the 

ground crew would control the UAS by changing the flight plan or flight mode. 

The final section consists of an overhead representation of the UAS along the 

flight plan.
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Figure 16: GCS Flight Plan Screen

(2) Does the pilot have a standardized screen set up at the initiation of each phase of flight?

Each phase of flight is considered an individual flight plan. Every flight plan entered by a 

qualified crew member is done through the Actions tab on Flight Data screen. (See 

Figure 6) The Actions tab set up remains constant at every point during UAS operation.

(3) How accurately can the pilot determine the attitude and position of the UA?

The attitude and position of the UA is determined by 3 sensors on the autopilot. A GPS

device is used determine the latitude, longitude, and altitude of the UAS to within 3 

meters. The attitude of the aircraft is determined by the Inertial Measurement Unit (IMU) 

which will produce an accurate attitude to within 1 degree.

(4) What commands are safeguarded from inadvertent activation and how is that achieved (for 

example, a two-step process to command “kill engine”)?

The Milo UAS contains two major safeguards to protect the aircraft from inadvertent 

activation. 

The first failsafe is the throttle failsafe. In order for the pilot to completely stop 

the engine the pilot must first set the UAS in manual operation via a switch on 

the RC transmitter. The second step is to pull the throttle to 0%, only then will 

the engine stop.

The second failsafe is a 2-step flight plan change safeguard. This consist of 1) 

altering a flight plan waypoint, 2) sending the updated flight plan the UAS.
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(5) What kind of inadvertent input could the pilot enter to cause an undesirable outcome (for 

example, accidentally hitting the “kill engine” command in flight)?

Even with the existing safeguards a crew member still has ability to send the UAS 

undesirable commands. These consist of sending the UAS an incorrect flight plan or 

setting the UAS into manual mode and performing a piloting error. 

(6) Are any other programs running concurrently on the ground control computer? If so, what 

precautionary measures are used to ensure that flight-critical processing will not be adversely 

affected?

No other programs will be running concurrently other than background programs such as 

anti-virus programs.

(7) What are the possible conditions that would cause a ground control station display or interface 

lock-up?

A lock-up could occur due to a random error in the operating system or the GCS 

software. The only way to mitigate this is to limit the number of programs the computer 

is running during flight operations.

(8) Are any of the primary flight controls based on the Windows operating system?

The GCS is a Windows operating system that the flight control software is run on.

(9) What alarms or warnings does the system provide to the pilot (for example, low fuel or 

battery, failure of critical systems, departure from operational boundary)?

The GCS features the following visual warnings to the UAS ground crew. A large red ‘X’ 

over the Wireless Telemetry Connection will be displayed in the event of a lost 

communication link. In the event of a lost GPS link the GCS will display “No GPS” in 

the GPS field of the GCS.

(10) Describe the means of providing primary and backup power to the ground control station.

The GCS consists of a laptop (with an attached radio transmitter/receiver) and an RC 

transmitter for manual flight. The primary source of power for the system will be a 

generator. The laptop itself has a battery that will provide uninterrupted power supply and 

backup power. The RC transmitter is battery powered, failure of RC control will trigger 

return to home from autopilot.

(11) What procedures are in place should the control station lose primary and secondary power?

If the control station should lose primary and secondary power, the pilot will take manual 

control of the aircraft and land.

4. Ground Support Equipment

Describe all the support equipment that is used on the ground. Include any launch or recovery 

systems, ground data terminals, generators, and power supplies.
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Launch/Recovery: Bungee launch- consisting of a rubber bungee staked to the ground 

and connected to the airframe by a small hook allowing quick launches with small 

amounts of space. The Milo does a belly landing and is recovered by hand.

Generators: Generator used to provide primary power source for GCS.

RC Transmitter: Used to manually control the aircraft. Powered by internal battery.

5. Processes and Procedures

A. Configuration Management

(1) What procedures are in place to manage change configuration? Is it documented?

See the Applewhite Aero Configuration Management document.

(2) Describe the procedures used for controlling drawings, test procedures, engineering changes, 

etc.

See the Applewhite Aero Document Management document.

(3) Describe the quality assurance system, methods and procedures used, and structure within the 

organization.

See the Applewhite Aero Quality Control document.

B. Software Management

(1) Describe what software functions were developed by the applicant or the applicant’s 

suppliers, and what functions are implemented by COTS software.

All functions are implemented by the COTS software.

(2) What software development process(es) have been used in the development of software 

components for the aircraft and the ground control station, and what software lifecycle data is 

available for review?

None. The Milo UAS is equipped with COTS software only.

(3) How will updates to system software (including COTS software) be implemented?

The autopilot software is open source and is updated through the supplier’s website. 

Applewhite Aero will research any changes to the autopilot software, and decide if the 

new software should be implemented. After software is updated a systems check will be 

done to ensure proper functionality of the UAS.

(4) Describe how the software requirements are validated and how the software is verified.

The software is verified by system checks on the ground that are done when software is 

updated.

(5) For aspects of software development that are allocated to suppliers, describe the process of 

supplier oversight.
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There is no software development allocated to suppliers past their initial release of the 

software.

(6) How is software load control implemented for the system to ensure that the correct software 

components are loaded onto the system?

There is no software load control. System checks are required when new software is 

loaded to prevent any issues.

(7) What software quality assurance processes are used in the development of the system 

software? How are suppliers a part of the process?

Suppliers are not a part of the process, they release the product only. For quality 

assurance with our systems, the ground checks are done to make sure each component 

works as it should.

(8) Is there a system for reporting and tracking problems? How are suppliers integrated into the 

problem reporting system?

Yes, refer to the Applewhite Aero Flight Reporting document.

(9) What procedures are in place to manage configuration changes? How are they documented?

See the Applewhite Aero Documentation Management document.

(10) What programming language(s) are used?

The ArduPilot Mega is programmed using the Arduino programming language.

(11) What requirements standards, design standards, and coding standards are used in the 

software development process? What ensures that the standards are followed?

The software is released from the supplier, and then Applewhite Aero adjusts certain 

parameters to fit the airframe and mission profile.

C. Electronic Hardware Design and Testing

(1) Describe the standards and processes used to design, test, and modify electronic hardware 

system elements such as line replaceable units, circuit board assemblies, and COTS components.

The Milo UAS is comprised of almost entirely of COTS components. Assembly of the 

autopilot components, wiring harnesses, and final assembly of the Milo UAS is

completed by Applewhite Aero. Every COTS component undergoes a system and 

functionality test prior to flight of aircraft. The autopilots undergo testing to ensure 

accurate communications with the GCS and accurate measurement of the IMU. 

(2) How is safety critical hardware components considered in the design, test, and modification 

processes described above relative to non-safety critical hardware components?

The most safety critical components of the Milo UAS consist of the autopilot, RC 

receiver, servos, ESC, and battery. Each of these safety critical components is a COTS 

component. Each component is selected to meet or exceed the flight demands of the 

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6. Operations

A. National Airspace System (NAS) Integration and Interaction

(1) Surveillance and Aircraft Visibility.

Since the Milo UAS is scheduled to be flown in an active restricted airspace, no transponder 

is deemed necessary.

1) Is the UA equipped with TSO approved Mode-C or Mode-S transponder? If yes, 

under what TSO and Class of equipment was the transponder approved?

No.

2) Is the UA equipped with a non-TSO approved Mode-C or Mode-S transponder?

If yes, describe the method used to determine that the transponder meets the 

performance and environment requirements of any class of TSO-C74d (Mode C) 

or TSO-C112 (Mode S). Highlight any TSO deviations or non-TSO functions.

No.

3) What functions and/or settings of the transponder can be changed by the pilot?

N/A.

4) Describe the transponder test procedures (Reference § 91.413).

N/A.

5) Does the UA have a high-visibility paint scheme that enables other pilots to see 

and avoid the UA and enables the observer(s) to visually acquire and track the 

UA?

The Milo UAS will have a highly visible paint scheme including bright 

colors and shapes designed to draw the eye.

6) What characteristics of the aircraft shape or structure increase its ability to be 

seen and tracked?

The Milo UAS has a large vertical tail and forward portion of the 

fuselage that create a large and distinctive profile, allowing for better 

tracking. See Figure 4.

7) Does the UA have anti-collision lights? Does the UA have position lights? What 

are the procedures if the lights are inoperative?

The Milo UAS is not equipped with lights. The aircraft will only operate 

in daylight VMC conditions. Future systems will be equipped with lights 

and strobes to add visibility to the aircraft and create the potential for 

flight in limited visibility conditions. 

8) For optionally piloted aircraft (OPA), does the cockpit have instrument and 

cockpit lighting?

The Milo UAS is not optionally piloted.
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(2) ATC and crewmember communications.

(a) How does the pilot communicate with ATC?

The pilot will use cell phone communications to contact the ATC, or the Range 

Safety Officer will coordinate between ATC and the pilot.

(b) How does the pilot communicate with other users of the airspace?

The Milo UAS will be flown in active restricted airspace; no aircraft should be in 

the airspace. Evasive action will be taking to avoid any other users. If there are 

multiple groups utilizing the restricted airspace at one time, the flights will be 

coordinated through the Range Safety Officer.

(c) Describe the communications equipment (that is, radios), including any equipment on 

the aircraft.

Table 5: Communications

Communications Equipment

Equipment: Manufacturer: Model: Frequency Range:

Transceiver Digi International XBEE09P 902-928 MHz

Transmitter Spektrum DX7 2402-2478 MHz

Transmitter Spektrum DX18 2402-2476 MHz

(d) Is there an intercommunication system that allows for communication between the

pilot(s), ground support personnel, crewmembers, and observers?

Due to small team size, verbal communication should be adequate. Intercoms or 

short-range radios will be available, if needed.

(e) What procedures have been established in the event of intercom failure?

In the event of intercom failure, verbal communication will be used. If this 

backup method is not adequate, a pilot will land the aircraft.

(3) Sense and avoid.

(a) Describe the method(s) in place for sense and avoid, and if applicable, identify the 

members of the flight crew that hold this responsibility.

The method is to visually scan the airspace for potential conflicts. It is the 

responsibility of the pilot in command (PIC) and observer(s) to avoid conflicts.

(b) What are the minimum traffic detection capabilities in azimuth and elevation?

N/A

(c) Describe the procedures that will be implemented should an aircraft enter the 

operating area.

If another aircraft should enter the flight area, a pilot will take manual control of 

the Milo UAS and immediately initiate a traffic avoidance maneuver.
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(4) Chase aircraft operations.

Milo UAS testing will not include chase aircraft operations.

B. Flight Phases

(1) Pre-flight/taxi operations.

(a) Describe the entire flight planning process, including how weather briefings and 

updates are obtained.

1) Flight planning will begin with a list of tasks to be completed during the flight 

test.

2) These tasks will be used to generate a mission profile.

3) The flight control software will be programmed with the mission profile taking 

into account the physical geometry of the test area.

4) Prior to or on the day of the proposed flight profile, a preflight crew briefing will 

take place with all parties involved.

5) Weather will be obtained from NOAA (www.aviationweather.gov) to verify 

current and forecast area weather. NOTAMS, PIREPS and any other pertinent 

information will be researched.

6) The vehicle will be assembled, inspected, programmed for the flight profile, and 

a complete systems check will be performed.

7) The test range safety officer will be informed of an impending flight.

8) The cognizant ATC will be informed of an impending flight for at least the first 

flight of the day. That is, unless the range safety officer does not handle this duty.

9) All crew members of the flight team need to agree to proceed with the flight.

10) The aircraft will then be launched according to the flight plan.

11) Since the vehicle has a short duration flight envelope, several flights can be made 

within one area forecast.

12) Updates for weather and NOTAMS will be obtained every four hours via 

www.aviationweather.gov.

13) Upon conclusion of the flight test plan for the day, the test range officer and the 

cognizant ATC will be informed that no more flights are to be conducted that 

day.

(b) Describe your coordination procedures with ATC before takeoff by addressing at a 

minimum:

1) Notices to Airmen (NOTAM).

The cognizant ATC will be contacted prior to any flight operations and 

relevant NOTAMS will be researched. Including local and FDC.
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2) Filing the flight plan.

Flight plan filing is not required for the specified airspace.

3) Transponder codes.

The Milo UAS is not equipped with a transponder.

(c) Describe UAS preflight activities and the system and support equipment required by 

addressing at a minimum:

1) The process by which the system is prepared for flight.

The system will undergo a pre-flight inspection. Information regarding 

the pre-flight inspection can be found in Maintenance Section of this 

document.

2) The systems required to prepare the system for flight.

The systems required to prepare the Milo UAS for flight include the 

portable GCS and the RC transmitter.

3) What critical process points are established, such as system configuration files 

needed to establish flight controls calibration?

Configuration files are noted on the flight plan datasheet for both the 

aircraft configuration and for the mission profile. (See Flight Reporting 

document).

(d) Describe how mapping updates are performed on the control station.

The ArduPilot Mega utilizes Google Earth for mapping which installs updates 

automatically when connected to the Internet. Prior to flight, automatic updating 

will be disabled in order to prevent any issues during flight.

(e) Describe the flightline/operations safety program, if any.

Sterile Cockpit will be observed. For further information see the Flightline Safety 

Program document.

(f) How do you ensure the area is clear for taxi?

Taxi will not be required. The aircraft is bungee launched.

(g) Describe the procedures to ensure the engine isn’t started in a manner that could cause 

injury to ground personnel.

Aircraft will be hand launched by a crew member who has been trained by 

Applewhite Aero on how to safely launch the aircraft. The crew will maintain a 

safe distance away from the launch the plane using a pull cord. All crew 

members will be aware of the situation and vigilant for signs of malfunction, 

giving warning should the situation require it, allowing all personnel to react 

appropriately to maintain their safety.
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(2) Take off/launch. Provide a description of system equipment required for this operation.

Identify unique system performance and procedures.

The Milo UAS will be launched using a bungee system staked to the ground and hooked 

to the aircraft appropriately. Once the bungee is drawn back to the proper tension, the 

plane will be released from a safe distance via a foot pedal. 

(3) Flight.

(a) Identify the components of the system, including support equipment that is required 

for the UA to conduct safe flight operations. Information presented in response to this 

item shall address at a minimum:

1) The process by which the system is operated during flight.

A ground station is required for initial programming of the vehicle. Once 

programmed, the vehicle can operate independently of any ground 

station in a completely autonomous mode. Ground stations are provided 

to monitor the progress or change the mission profile during flight.

2) The systems required to operate the system during flight.

The systems required to operate the Milo UAS during flight include the 

portable GCS and the RC transmitter.

3) Critical process points that are established.

Monitor progress of the UAS during flight.

(b) Describe the method for switching between pilot-controlled (manual) and autonomous 

flight modes. At what points during the flight will this happen?

A switch on the RC transmitter switches between manual and autopilot mode.

Manual control will be taken in the event of another aircraft enters the flight area, 

and an evasive maneuver cannot quickly be programmed into the autopilot, or the 

lost link or any other flight mode behaves in a way counter to the programmed 

flight plan.

(c) What indication does the pilot have that they are in control of the aircraft?

The observed behavior is in alignment with the mission profile and the pilot can 

demonstrate manual control and a return to automated flight.

(d) For OPA, describe how the remote control equipment will be engaged and disengaged 

during ground and flight operations.

The Milo UAS is not optionally piloted.

(e) How are changes made to the flight plan during flight?

The new flight plan is programmed into the ground control station and then sent 

to the UAS, the autopilot will adjust its flight plan/path accordingly.

(f) Describe the procedures in the event of lost communication with ATC (if applicable).
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Notification with ATC is either via phone call or relayed via the RSO. Constant 

communication is not required.

(4) Landing/recovery. Provide a description of system equipment required for this operation. 

Identify unique system performance and procedures.

The Milo UAS will belly land and will be recovered on foot. There is no additional 

equipment needed for landing/recovery.

(5) Post-flight.

(a) This subsection intends to identify the parts of the system, including support 

equipment required for the UAS to conduct safe operations. Information presented in 

response to this item shall address at a minimum:

1) The process by which the system is operated post-flight.

a. Verify landing site is safe for recovery

b. Recovery

c. Perform post-flight inspection/maintenance

d. Post-flight debrief

e. Document flight “lessons learned” if applicable

f. Prepare system for next flight, if applicable

g. After the final flight, the system may be dismantled and packed into its 

case

2) The systems required to operate the system post-flight.

None.

3) Critical process points that are established.

a. Verify that landing site is safe for recovery.

b. Post-flight inspection

(b) Describe the process for a post-flight inspection.

The post-flight inspection is follows the same procedures as the pre-flight 

inspection described above.

(c) Describe the process for incident/accident reporting.

Any incident, accident, or any flight operation that transgresses the lateral or 

vertical boundaries of the flight test area or any restricted airspace must be 

reported to the UAS Integration Office (AFS-80) within 24 hours. AFS-80 can be 

reached by telephone at 202-385-4636 or by fax at 202-385-4559. Accidents that 

result in death or serious injury to any person, or accidents that cause substantial 

damage to a UA with a maximum gross takeoff weight of 300 pounds or more 

must be reported to the National Transportation Safety Board (NTSB) per 

instructions on their website: www.ntsb.gov. Further flight operations must not 
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be conducted until the incident is reviewed by AFS-80 and authorization to 

resume operations is provided to Applewhite Aero.

C. Operating Areas

(1) How do you ensure that there is no unusual ground activity under the flight operations area? 

For example, are there any weekend events scheduled? Are there housing areas or public 

gathering places?

An initial visual scan of the bay will be conducted prior to flight for potential conflicts. 

Ongoing scans will be conducted during flight and potential conflicts will be avoided.

(2) Identify any military or civilian routes through the proposed operational area.

 (a) Pendleton, OR:

The testing sites are located north-northeast of Holden, OR, just outside of Pendleton, as 

can be seen in figure 13. There are a few minor roadways passing near the boundaries of 

the Primary and Secondary Pendleton sites as can be seen from figures 14 and 15 below. 

The roadway’s include Hartle Rd, Highway 37, Co 891 Rd, Co 888 Rd, and N. Juniper 

Rd. 

 

(b) Whidbey Island, WA:

V287 passes through R-6701. The activation of R-6701 should preclude the use of V287 

at or below 5000 ft. MSL.

(3) Identify the proposed operating area on an aeronautical chart. The proposed area needs to 

define lateral boundaries and requested altitudes.

(a) Pendleton Airport – Class G, Active Restricted

Pendleton, OR

Testing will occur in the airspace indicated in Figure 13, below. Most testing will be 

conducted within the primary test area as defined in Figure 14. A secondary test area is 

defined in Figure 15.
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Figure 17: Pendleton Location Sectional

Figure 18: Pendleton Primary Test Area
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Northeast Test Area:

Point P1: N45°55’48” W118°54’07”

Point P2: N45°55’55” W118°53’46”

Point P3: N45°55’55” W118°53’13”

Point P4: N45°56’06” W118°53’13”

Point P5: N45°56’10” W118°52’12”

Point P6: N45°54’50” W118°52’12”

Point P7: N45°54’50” W118°52’52”

Point P8: N45°55’16’ W118°52’52”

Point P9: N45°55’16” W118°54’07”

Leg 1 – P1 to P2: 0.33 miles

Leg 2 – P2 to P3: 0.46 miles

Leg 3 – P3 to P4: 0.22 miles

Leg 4 – P4 to P5: 0.78 miles

Leg 5 – P5 to P6: 1.51 miles

Leg 6 – P6 to P7: 0.52 miles

Leg 7 – P7 to P8: 0.49 miles

Leg 8 – P8 to P9: 1.00 miles

Leg 9 – P9 to P1: 0.62 miles

Figure 19: Pendleton Secondary Test Area
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Southwest Test Area:

Point P1: N45°55’16” W118°57’50”

Point P2: N45°55’16” W118°56’38”

Point P3: N45°54’50” W118°56’38”

Point P4: N45°54’50” W118°57’11”

Point P5: N45°53’06” W118°57’14”

Point P6: N45°53’06” W118°58’30”

Point P7: N45°54’50” W118°58’30”

Point P8: N45°54’50” W118°57’50”

Leg 1 – P1 to P2: 1.00 miles

Leg 2 – P2 to P3: 0.49 miles

Leg 3 – P3 to P4: 0.47 miles

Leg 4 – P4 to P5: 1.98 miles

Leg 5 – P5 to P6: 0.99 miles

Leg 6 – P6 to P7: 2.00 miles

Leg 7 – P7 to P8: 0.50 miles

Leg 8 – P8 to P1: 0.49 miles

(b) R-6701 (Admiralty Bay) – Class E, Active Restricted

Whidbey Island, Washington

Testing will occur under the R-6701 airspace indicated in Figure 16, below. Most testing 

will be conducted within the primary test area as defined in Figure 17. A secondary test 

area is defined in Figure 18.

Figure 20: R-6701
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R-6701:

Northwest Corner: N48°10’ W122°41’

East to: N48°10’ W122°34’54”

Southeast to: N48°05’42” W122°31’36”

West to: N48°06’06” W122°41’18”

North to: N48°10’ W122°41’

Leg 1 - Northwest Corner to Northeast Corner: 4.72 miles

Leg 2 – Northeast Corner to Southeast Corner: 5.52 miles

Leg 3 – Southeast Corner to Southwest Corner: 7.49 miles

Leg 4 – Southwest Corner to Northwest Corner: 4.50 miles

Figure 21: Whidbey Island Primary Test Area

Primary Test Area:

Launch Area: N48°07’06” W122°35’54”

Point P1: N48°07’06” W122°35’12”

Point P2: N48°06’30” W122°34’54”

Point P3: N48°06’30” W122°35’54”
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Leg 1 – Launch to P1: 0.50 miles

Leg 2 – P1 to P2: 0.76 miles

Leg 3 – P2 to P3: 0.76 miles

Leg 4 – P3 to Launch: 0.73 miles

Figure 22: Whidbey Island Secondary Test Area

Secondary Test Area:

Point S1: N48°09’06” W122°41’06”

Point S2: N48°09’54” W122°38’54”

Point S3: N48°09’12” W122°36’42”

Launch Area: N48°07’06” W122°35’54”

Point P3 N48°06’30” W122°35’54”

Point S4: N48°05’54” W122°36’18”

Point R4: N48°06’06” W122°41’18”

Leg 1 – S1 to S2: 2.00 miles

Leg 2 – S2 to S3: 1.87 miles

Leg 3 – S3 to Launch: 2.53 miles

Leg 4 – Launch to P3: 0.73 miles

Leg 5 – P3 to S4: 0.68 miles

Leg 6 – S4 to R4: 3.89 miles

Leg 7 – R4 to S1: 3.45 miles

(c) Royal City, Washington

Provide an aeronautical chart(s) or aerial photograph(s) of the operating area in which the 

experimental flights will be conducted. For experimental aircraft, indicate where initial flight 

testing will occur on an aeronautical chart or aerial photograph. Include the following:
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 The areas over which the flights are requested to be conducted and the address of base 

operation (§ 21.193(d)(3)).

– Class E Airspace: 15 mi. Southwest of Moses Lake, WA

 The proposed flight test area using latitude and longitude on an aeronautical chart or 

aerial photograph. For example, if the perimeter of the proposed flight test area is in the 

shape of a rectangle, the latitude and longitude of the corners must be stated. The distance 

of each leg of the perimeter must be stated.

Testing will occur within the bound airspace indicated in Figure 4, below. Most testing will be conducted 

within the primary test area as defined in Figure 5. A secondary test area is defined in Figure 6.

 Proposed upper and lower altitude limits

Upper limit: 5000 ft MSL

Lower limit: 20 ft AGL

 Class of airspace to be used.

Class “E” airspace, where the restriction will be active during the flights. All 

flights will be conducted under supervision of the Range Safety Officer.

 Flight rules and weather conditions, for example, visual flight rules (VFR) and visual 

meteorological conditions (VMC).

Milo UAS flight testing will be conducted under VFR in VMC conditions, and 

will maintain line of sight communication and operation.

 Whether flight testing will include payload testing. If so, describe the payload and its 

operation.

Several payload modules are in development which may be used to collect or 

independently stream video or telemetry. Payload modules may be externally or 

internally mounted. Payload modules may include one or more of self-contained 

video (e.g. go-cam), streaming video, and sensors (e.g. temperature).

 Whether the aircraft will perform any aerobatic maneuvers as defined by § 91.303.

The Milo UAS will not be performing any intentional aerobatic maneuvers.
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Figure 23: Royal City Location Sectional

Royal City Location Sectional:

Northwest Corner: N46°53’ W119°38’30”

Northeast Corner: N46°53’ W119°35’

Southeast Corner: N46°49’30” W119°35’

Southwest Corner: N46°49’30” W119°38’30”
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Figure 24: Royal City Primary Test Area

Primary Test Area:

Northwest Corner P1: N46°52’43” W119°37’08”

East to P2: N46°52’43” W119°36’26”

North to P3: N46°52’58 W119°36’27”

East to P4: N46°52’58” W119°36’04”

South to P5: N46°52’17” W119°36’07”

Southwest to P6: N46°51’51” W119°36’19”

West to P7: N46°51’52” W119°37’08”

Leg 1 - Northwest Corner P1 to P2: 4.59 miles

Leg 2 – North P2 to P3: 1.89 miles

Leg 3 – East P3 to P4: 2.61 miles

Leg 4 – South P4 to P5: 6.36 miles

Leg 5 – Southwest P5 to P6: 4.07 miles

Leg 6 – West P6 to P7 6.01 miles

Leg 7 – North P7 to P1 8.61 miles
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Figure 25: Royal City Secondary Test Area

Secondary Test Area:

Point S1: N46°20’49” W119°50’42”

Point S2: N46°20’50” W119°46’49”

Point S3: N46°19’12” W119°46’49”

Point S4: N46°19’11” W119°50’41”

Leg 1 – S1 to S2: 2.60 miles

Leg 2 – S2 to S3: 1.35 miles

Leg 3 – S3 to S4: 2.37 miles

Leg 4 – S4 to S1: 1.39 miles

D. Flight Envelope and Test Plans

(1) Describe the conditions under which flight envelopes will be tested. How close will 

operations be to any populated areas and major highways?

Conditions: VFR and VMC.

Primary Test Area

(a) Pendleton, OR: 17 miles north-northwest of Pendleton, OR and just northnortheast of Holden, OR.

(b) Whidbey Island: 150 feet from a local highway, SR-525, at closest point.
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Secondary Test Area

(a) Pendleton, OR: As defined above.

(b) Whidbey Island: Over the water, Admiralty Bay.

(2) Describe how you plan to meet test objectives under the proposed flight envelope and 

operating area. Include test plans, if possible.

Purpose: To perform research and development evaluations of the Milo UAS.

Activity: Operation of the Milo UAS. 

Specifically, overall flight performance and autopilot will be evaluated by taking the 

Milo UAS through increasingly complex flight paths in maneuvers. The evaluation may

also entail endurance testing, adjusting the center of gravity to measure stability, and 

effects of speed variations on the airframe. Secondary purposes are to perform crew 

training in the operation of the Milo UAS and market research. 

Max Operating Altitude: 18000 feet MSL

Milo UAS flight testing will be conducted under VFR in VMC conditions, and will 

maintain LOS communication and operation. A pilot will be on-site to take control of the 

UAS should the autopilot lose its link with the ground station or if the UAS does not 

perform as expected.

The maximum operating altitude will be 5000 feet MSL. The flight endurance of the

Milo UAS is between 30 – 45 minutes, typical. Flights will vary in duration but will 

typically not exceed 30 minutes. The quantity and frequency of experimental flights will 

be dependent on the results of the preceding flights, weather/ sea conditions, and 

operational readiness. 

E. Operating History

Describe the operational history of the UAS. Include details of the following items:

The Milo UAS is a new airframe that is yet to be flight tested.

F. Manuals

Is there an operating manual for the aircraft?

Yes, refer to Milo Aircraft Flight Manual.

Does the manual have a section with all of the aircraft limitations in one location?

Yes.

Does the operating manual have bolded or underlined procedures for emergencies for memory 

item steps?

Yes.

Is there an operation checklist for all phases of the operation?

Yes.
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Are here separate checklist items for normal, abnormal, or emergency procedures?

Yes.

7. Organizational Considerations

A. Pilot/Crew Qualifications/Training

Reference: 14 CFR part 61 – Certification: pilots, flight instructors, and ground instructors; part 

63 – Certification: flight crewmembers other than pilots; part 65 – Certification: airmen other 

than flight crewmembers.

(1) Crew. Is there a crew resource management training program? If so, describe the program.

Crew resource management IAW AC 120-51E.

(2) Pilots.

(a) Do the pilots have a current pilot certificate? If so, what type of pilot certificate?

Paul Applewhite: 

ATP, CFI, CFII, MEI with over 11,000 hours flying experience

Dave Beardsley:

Private Pilot Certificate

(b) Do the pilots have a current medical certificate? If so, what class of medical 

certificate?

Paul: First Class

Dave: Second Class

(c) Describe in detail and reference any procedures that show that the pilots are properly 

trained.

All pilots and observers will complete training as required by the FAA. Pilots and 

observers will also complete Applewhite Aero internal training in the operation 

of the Milo UAS.

(d) Is there an established formal training curriculum for all pilots including PIC, 

supplemental, or chase pilots(s)?

Yes. (Chase pilots are not required)

(e) Is the pilot type rated for the aircraft being flown?

Yes.

(3) Observer.

(a) Do the observers have a current pilot certificate? If so, what type of pilot certificate?

No.
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(b) Do the observers have a current medical certificate? If so, what class of medical 

certificate?

Yes, all observers have a current second class medical certificate.

(c) Does the observer understand the applicable aviation regulations such as see and avoid, 

clear of clouds, and right of way rules?

Yes.

(d) Is the observer a current pilot or have a training curriculum? Is there an established formal 

training curriculum for all observers? If so, please provide it during the site visit.

Yes.

(e) Describe, in detail, how the observer is properly trained to be an effective member of the 

flight team.

Observers receive same the training as a pilot and the same process is used to 

qualify/certify a pilot.

(f) Does the observer understand the following:

1) Proper communications and phraseology?

Yes.

2) Proper visual scan techniques?

Yes.

3) Standard flight operations at non-towered airports?

Yes.

4) Containment areas and how to determine whether the UA is operating within that 

area?

Yes.

B. Maintenance

(1) Provide an inspection and maintenance program.

Refer to Milo Inspection and Maintenance Program document.

(2) Provide information on unique system maintenance activities, such as maintenance of a 

pneumatic launcher system.

The Milo UAS does not have any unique systems requiring maintenance.