U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12­140

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of E.C Flyer LLC for an Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012

Petition for Exemption Filed under Section 333 of the FAA Reform Act and Part 11 of the Aviation

Regulations. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11, E.C. Flyer, LLC, a Florida limited liability company, hereby applies for an

exemption from the listed Federal Aviation Regulations (FARs) to allow it to operate a small Unmanned

Aircraft System (UAS) under the conditions and limitations set forth in this Petition. The areas of aerial

filming production include real estate marketing, feature films, television commercials, documentaries,

construction survey, 3­D mapping, and educational research & development.

Exemption is sought based on information outlined in this Petition (Appendix A), as well as

accompanying E.C. Flyer LLC Standard Operation Procedures (SOPs) (Appendix B), Mission Briefing

and Pilot Checklists(Appendix C).

Introduction

E.C. Flyer LLC is a professional production company specializing in aerial digital media. The company,

which was founded by commercial aviators, intends to operate aerial camera systems for commercial

photography and videography in the United States.

E.C.Flyer LLC has been professionally trained by industry experts, Offshore Aviation LLC, to standards

set forth in COA FAA­2015­0093 (Exemption No. 11723). Offshore Aviation LLC has years of

experience demonstrating UAS technology and has a history of supporting academic research and

development (R&D) projects. The company’s pilots and camera operators have participated in numerous

student science and R&D projects in Maryland, Virginia, and Washington DC and are widely recognized

as experts in UAS design and flight operations.

E.C. Flyer LLC’s comprehensive operations and training programs are based on sound military

techniques and procedures formulated by Offshore Aviation LLC. We use professionally designed

UAS(s) that are supported by technical manuals, military style maintenance programs, and operational

standards designed to promote safe and effective operations.

E.C. Flyer LLC UAS pilots hold FAA commercial, private, and sport pilot certificates. In addition to

these ratings our Chief Consultant and Director of UAS Operations, has accumulated over 2,500 military

jet hours and over 2,000 military UAS hours. He has a Master’s Degree in Aerospace Engineering, is a

graduate of United States Navy Test Pilot School, United States Naval Aviation Safety School and has

been flying in the radio control aircraft hobby for over 16 years. He brings this wealth of knowledge and

experience to our professional UAS operations.

Primary UAS airframe make and model utilized:

● VulcanUAV Mantis

● VulcanUAV Black Widow
Secondary UAS airframe make and model utilized:

● DJI Phantom 3

● DJI Flamewheel F550

Lightweight (< 30.0 lbs gross weight), battery powered multi­rotorcraft with vertical take­off and land

capability. The airframes are manufactured respectively by VulcanUAV Ltd. and Da­Jiang Innovations

Science and Technology Co., Ltd (DJI).

Electronics include:

● An on­board flight computer with GPS navigation and location ability that receives signals for

flight controls from a ground­based transmitter/controller;

● An on­board camera capable of capturing imagery in the form of full color, high definition still

photos and video;

● Onboard camera and gimbal is controlled by separate controller operated by dedicated Payload

Operator (PO);

● An on­board telemetry system that delivers flight data from the on­board flight computer to the

on­board radio transmitter including altitude AGL, horizontal and vertical speed, compass

direction of flight and direction back to its launch site;

● A 600mW, 5.8GHz on­board radio transmitter that transmits live video from the on­board camera

plus all the flight data from the telemetry system described above;

Ground Station Includes:

● A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and

who controls the UAS while in the air;

● A 500mW, 433MHz radio transmitter/controller operated by the PIC to control the UAS while in

flight;

● A 100mW, 2.4GHz radio transmitter/controller operated by the PO to control the camera and

gimbal while in flight;

● A radio receiver receiving live video and flight data from the on­board camera and computer

projects it all together onto a screen for the PIC to view during flight if needed;

● A radio receiver receiving live video and flight data from the on­board camera and computer

projects it all together into a pair of video goggles for the PO to view during flight.

Proposed Operations:

E.C. Flyer LLC intends to use the UASs in three general areas. First, E.C. Flyer LLC seeks an exemption

to perform video filming and photographing by air for public and private use. Second, it will employ

UASs to inspect land, residential commercial and industrial structures and property. Third, E.C. Flyer

LLC seeks permission to use UASs to offer training to persons, from both private and public entities,

which are interested in the safe operation of UAS.

Specifically, E.C. Flyer LLC will use UASs which are equipped with cameras and sensors, in order to

engage in the following commercial activities:

(a) Video filming by air and photographing for public and private purposes, including: cinematography,

educational research & development, feature films and documentaries.
(b) Video filming by air and photographing to support professional operations in engineering, land

surveying, architecture, real estate and other related professional activities.

(c) Inspections by air of infrastructure such as bridges, highways, electrical installations, dams, aqueducts,

photovoltaic power stations, wind farms and pipes. These inspections will only be done under contract

with the owners or with any local government authority.

(d) Inspection by air of land and residential, commercial and industrial structures, only under contract

with the owners or with any local government authority.

(e) Inspections by air to detect sources of pollution and gas emissions, under contract with the owners in

the area or with any local government authority.

(f) Support provided to search and rescue operations and reconnaissance in cases of need, emergency or

natural disasters and only when government authorities have requested it by contract or donation.

(g) E.C. Flyer LLC is an avid believer that offering training to persons, private and public entities, which

are interested in the safe use of UAS(s), will enhancing their skills and safety controls which make the

NAS safer and further protects persons and property.

Relevant Statutory Authority:

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant

to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to

operate in the National Air Space ("NAS") where it is safe to do so based on the following considerations:

• The UAS’s size, weight, speed and operational capability;

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

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

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety

regulations and minimum standards when the Administrator decides a requested exemption is in the

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f)

(permitting exemptions from§§ 44701(a), (b) and§§ 44702­44716,et seq.). A party requesting an

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2)

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

E.C. Flyer LLC proposed UAS Operations Meet the Requirements of Section 333

of the Reform Act

E.C. Flyer LLC proposed operations in this Petition for Exemption qualify for expedited approval

pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are

satisfied.

Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational Capability:
E.C. Flyer LLC will employ the UASs for the operations specified in this Petition for Exemption. The

flight speed will not exceed 30 miles per hour, and it will not be flown in controlled airspace without prior

permission from the controlling agency or at an altitude that exceeds 400 feet AGL. All flights will be

flown in such a way that they can be safely terminated with a reserve battery power of 25% of the

battery's maximum charge. The UASs do not carry any flammable propellant or fuel. They have an

integrated GPS system that calculates the UAS’s position and height and relays that information via a

secure connection to the operators. Additionally, the UASs contain a failsafe mode which activates if its

connection to the remote control is lost or can via a switch on the PICs transmitter/ controller, and this

system permits the UAS to return to a predetermined location and land without injury or damage. For

added safety, the aircraft are equipped with bright LED position lighting in the standard FAA

configuration (red, green and white strobe). These can be easily seen during the day and

give positional awareness to PIC and other aircraft.

Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manual:

E.C. Flyer LLC SOPs, Pilot Checklists, and Briefing Guide, plus VulcanUAV and DJI operator’s manuals

contain all of the procedures and limitations necessary to successfully perform the operations specified in

this Petition for Exemption.

Public Interest:

The public interest will be served by granting E.C. Flyer LLC’s Petition for Exemption. Congress has

established a national policy that favors early integration of UASs into the NAS under controlled, safe

working environments such as those proposed in this Petition. In addition, the public also has an interest

in reducing the hazards associated with alternate methods of conducting similar aerial photographic

operations. Currently operations are conducted using teams that climb structures using ladders to position

equipment, or low flying helicopters and aircraft. By using UAS, exposure to physical hazards will be

reduced by conducting the operation while remaining safely on the ground.

Additionally, E.C. Flyer LLC’s intended uses for the UAS’s have identifiable safety benefits that include

reducing the danger and emissions associated with full size aircraft, such as dangerous fuels, vastly lower

noise pollution, vulnerable aircrew and public safety in general. If there is a mishap with the UAS the

impact to persons and property is far less than if a full size aircraft is involved.

Federal Register Summary:

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

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

E.C. Flyer LLC seeks an exemption from the following rules:

Parts 21; §§ 45.23(b); 27; 61.113(a) and (b); 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109;

91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

The exemption will enhance safety by reducing risk to the general public and property

owners from the substantial hazards associated with performing equivalent work with
conventional aircraft, rotorcraft, or other methods.

Conclusion:

E.C. Flyer LLC’s Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act

of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas,

operation within visual line of sight and national security. Additionally, the Petition provides more than

adequate justification for the grant of the requested exemptions to permit E.C. Flyer LLC to operate the

selected UASs for the operations specified herein.

Granting the exemption will benefit the public interest as a whole in several ways, including (1)

significantly improving safety and reducing risk by alleviating human exposure to danger, and (2)

improving the quality of services and decreasing operating costs compared with conventional flight

operations.

Very Respectfully,

Brad Saxon

Managing Director

E.C. Flyer LLC

5325 Old Berryhill Rd

Milton, FL 32570­8159

brad.saxon@offshorepix.com
Appendix A

The regulations from which the exemptions is requested are listed below, underneath each are our

proposed equivalent level of safety:

Parts 21,§§ 45.23(b); 27, 61.113(a) and (b) 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121;

91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14,

Code of Federal Regulations (14 CFR).

Exemptions Requested:

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

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

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

E.C. Flyer LLC seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 27, 45, 61

and 91 for purposes of conducting the requested operations using a UAS. Listed below are the specific

sections of 14 C.F.R. for which exemption is sought:

14 C.F.R. Part 21, Subpart H ­ Airworthiness Certificates:

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform

Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used

for the same application. (Regulatory Docket No. FAA­2014­0352). These criteria are met, and therefore

no exemption is needed.

Equivalent Level of Safety:

The UASs selected by E.C. Flyer LLC are safe when taking into account their size, weight, speed, and

operational capability. The UASs weigh less than 30 pounds and will be flown at less than 30 miles per

hour and outside controlled airspace unless prior permission is granted by controlling agency.

Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials and or flammable

liquid fuels, and operate exclusively within the parameters stated in the Operator’s Manuals and SOPs.

Operations under this exemption will be closely controlled and monitored by the operator

and will be conducted in compliance with local public safety and security requirements.

E.C Flyer LLC will also provide the FAA with advance notice of all operations via NOTAMS and

coordination with the local FSDO. In all cases, the UAS operated under the proposed conditions, will be

at least as safe as, or safer than conventional rotorcraft operating with an airworthiness certificate without

the restrictions and conditions of the proposed UAS operations.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category

rotorcraft. To the extent the E.C. Flyer LLC UASs would otherwise require certification under Part 27, we
seek an exemption from Part 27's airworthiness standards for the same reasons identified in the request for

exemption from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. §§45.23(b), Display of marks; general

These regulations provide that each aircraft must display "N" and the aircraft's registration number in

letters at least 2 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS does not

have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration

number assigned to it by the FAA.

E.C. Flyer LLC proposes to achieve an equivalent level of safety by including the word

"EXPERIMENTAL" as large as practicable on the top of the aircraft, where the PIC, PO and others in the

vicinity of the aircraft while it is preparing for launch will be able to see the designation. Finally, the

ground station will display a high contrast flag or banner that contains the words "Unmanned Aircraft

Ground Station" in letters 3 inches high or greater. The banner should be visible to anyone that observes

the aircraft and chooses to investigate its point of origin.

In a previous Grant of Exemption, Regulatory Docket No. FAA­2014­0352, the FAA determined that

exemption from these requirements was warranted provided that the aircraft "have identification

(N­Number) markings in accordance with 14 C.F.R part 45,

Subpart C if the markings are as large as practicable."

14 CFR § 61.113 (a) and (b); 61.3 (c,2­v): Private Pilot Privileges and Limitations,

Medical Certificate:

E.C. Flyer LLC seeks exemption from 14 C.F.R § 61.113, which restricts private pilot certificate holders

from flying aircraft for compensation or hire, and which would also require a second class medical

certificate for possible future PICs. The purpose of this section is to ensure the skill and competency of

any PIC where the aircraft is carrying passengers or cargo for hire. In this case, while the UAS will be

operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of

Exemption in FAA Docket No. FAA­2014­0352, the FAA determined that the unique characteristics of

UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant

with requiring the PIC to have a commercial pilot certificate and class II medical certificate. Additionally,

instead of having a second or third class medical, we suggest that the PIC exercise the privileges similar

to that of a sport pilot, requiring only a valid US driver’s license.

Safety Mitigation:

Petitioner seeks to ensure safe operation by ensuring that any PIC is thoroughly versed in airspace and

communication issues pertaining to all aircraft operators but also in the unique aspects of UAS flight. The

owners and all current PICs of E.C. Flyer LLC have commercial pilot’s license, however, the experience

obtained beyond a sport pilot certificate in pursuit of a commercial pilot certificate in manned flight does

not necessarily aid a pilot in the operational environment proposed. To that end, E. C. Flyer LLC will

require a PIC to have at a minimum completed sport pilot ground school, pass a FAA sport pilot

knowledge test and adhere to the SOPs listed in Appendix B.
We find that the combination of aeronautical knowledge, UAS airmanship skills, and verification through

remaining current is a sufficient method to evaluate a pilot’s qualifications, given that operations will be

conducted within the limitations outlined in this petition.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness:

E.C. Flyer LLC seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in

airworthy condition to be operated. The FAA has stated (Regulatory Docket No. FAA­2014­0352) that no

exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft:

Given its size, configuration, and load capacity, the VulcanUAV and DJI UAS have no ability to carry

such a manual on the aircraft, not only because there is no pilot on board, but because there is simply no

room or capacity to carry such an item on the aircraft.

Safety Mitigation:

The safety related purpose of this manual requirement can be equally satisfied by maintaining the UAS

Manuals at the ground control point where the crew flying the UAS will have immediate access to it.

Accordingly, we request an exemption from § 91.9(b) (2)'s flight manual requirements, on the condition

that VulcanUAV and DJI UAS flight manuals be available at the control point during each operation.

14 C.F.R. § 91.103: Preflight Action

E.C. Flyer LLC seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to become familiar

with specific information before each flight, including information contained in the FAA­approved Flight

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely

conduct the flight, an exemption is requested to the extent that an FAA­approved Flight manual is

required.

Safety Mitigation:

An equivalent level of safety will be provided by following the Aircraft Operations Manual and flight

manual provided by the manufacturer. The PIC will take all required preflight actions­ including

performing all required checklists and reviewing weather, flight requirements, battery charge, landing and

takeoff distance, aircraft performance data, and contingency landing areas ­ before initiation of flight. The

Operators Manual and SOPs will be kept at the ground station with the operators at all times.

14 C.F.R. § 91.109(a): Flight Instruction

E.C.Flyer LLC seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "no person may

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that

aircraft has fully functioning dual controls." UAS and remotely piloted aircraft, by their design, do not

have functional dual controls. Instead, flight control is accomplished through the use of a device that

communicates with the aircraft via radio communications.

Safety Mitigation:
Given the size and speed of the UAS employed by E.C. Flyer LLC, an equivalent level of safe training

can still be performed without dual controls because no pilot or passengers are aboard the UAS and all

persons will be at a safe distance away in the event that the UAS encounters any difficulties during flight

instruction. In addition, we will conduct flight training at our Research and Development test sites, which

are located on its own property. These training flights will be conducted in a sterile area and will

otherwise comply with the provisions in the Operator’s Manual for flights at the R&D facility. The FAA

has stated (Regulatory Docket No. FAA­2014­0352) that no exemption is required.

14 C.F.R. § 91.119: Minimum Safe Altitudes

E.C. Flyer LLC requests an exemption from the minimum safe altitude requirements of 14 C.F.R. §

91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate,

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in

non­congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at

less than those minimum altitudes when it can be operated "without hazard to persons or property on the

surface," provided that "each person operating the helicopter complies with any routes or altitudes

specifically prescribed for helicopters by the FAA."

Safety Mitigation:

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed

herein, and given the lack of flammable fuel, any risk associated with these operations is far less than

those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given

the size, weight, and speed of the UAS, as well as the location where it is operated. In order to avoid any

risk to aircraft, flight operations will be restricted to 400' AGL or below. Prior to conducting UAS

operations, all persons not essential to flight operations (nonparticipating persons) shall remain at

appropriate distances. In open areas, the UAS shall remain 500 feet from all persons other than essential

flight personnel (i.e. PIC, PO, operator trainees or essential persons). If barriers or structures are present

that can sufficiently protect nonparticipating persons from the UAS or debris in the event of an accident,

then the UAS may operate closer than 500 feet to persons afforded such protection. The UAS operator

shall also ensure that nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations shall

cease immediately. When considering how to immediately cease operations, the primary concern is the

safety of those nonparticipating persons. In the event that operations must be conducted closer than 500

feet to vessels, vehicles and structures the PIC shall receive permission from the owner/controller of any

such vessels,vehicles or structures and the PIC shall make a safety assessment of the risk of operating

closer to those objects and determines that it does not present an undue hazard.

14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the

departure airport or barometric pressure. An exemption is required to the extent that the UASs do not

have a barometric altimeter, but rather a GPS altitude read out.

Safety Mitigation:
The FAA has stated that an equivalent level of safety can be achieved if the UAS will be operated at 400'

AGL or below and within visual line­of­sight in addition to GPS based altitude information relayed in real

time to the operator. See Grant of Exemption to Astraeus Aerial, Docket No. FAA­2014­0352. As the

attached Operations Manual indicates, the chosen UAS meets these requirements, and a zero altitude

initiation point will be obtained prior to flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

E.C. Flyer LLC requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming

normal cruising speed ­

(1) During the day, to fly after that for at least 30 minutes; or

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

Here, the technological limitations on UAS battery power means that no meaningful flight operations can

be conducted while still maintaining a 30 minute reserve. E.C. Flyer LLC proposes that all flights comply

with this requirement by mandating that the aircraft be safely landed with no less than 25% of battery life

remaining.

Safety Mitigation:

The FAA has stated that an equivalent level of safety is provided if the UAS flight is terminated with at

least 25% reserve battery power still available. See Grant of Exemption to Astraeus Aerial, Docket No.

PAA­2014­0352. The Operations Manual conforms to this limit, providing an equivalent level of safety.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required

The regulation provides that an airworthiness certificate, with the registration number assigned to the

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew."At a maximum gross weight of less than 30 pounds, the UASs are too small to carry

documentation, do not have an entrance, and are not capable of carrying passengers or crew. To obtain an

equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate

for this aircraft by the FAA will be co­located with the crew at the ground control station and available for

inspection upon request. The FAA has stated (Regulatory Docket No. FAA­2014­0352) that no exemption

is required.

14 C.F.R. 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) Maintenance Required

E.C. Flyer LLC seeks an exemption from the maintenance inspection requirements contained in 14

C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance

and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. § 91.405(a) (stating that

each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this
part and shall between required inspections...have discrepancies repaired as prescribed in part 43 of this

chapter"). An exemption from these regulations is needed because Part 43 and these sections only apply

to aircraft with an airworthiness certificate, which the UASs will not have.

Safety Mitigation

An equivalent level of safety will be achieved because maintenance and inspections will be performed in

accordance with the Operators Manual. As provided in the Operators Manual, flights will not be

conducted unless a flight operations checklist is performed that includes all of the aircraft's components.
Appendix B

Standard Operating Procedures (SOPs):

1. The unmanned aircraft systems (UASs) will weigh less than 30 pounds, including energy source(s) and

equipment.

2. The UAS will not be flown at a ground speed exceeding 30 MPH.

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

by the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL.

4. The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the

PIC to be able to use human vision unaided by any device other than corrective lenses.

5. All operations will utilize a Payload Operator (PO). The PO may be used to satisfy the VLOS

requirement, when not using video goggles, as long as the PIC always maintains VLOS capability. The

PO and PIC must be able to communicate verbally at all times.

6. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the

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

operating until the necessary maintenance has been performed and the UAS is found to be in a condition

for safe flight. The Ground Control Station(GCS), if utilized, will be included in the preflight inspection.

All maintenance,alterations and software upgrades will be properly documented in the aircraft records.

7. If the UAS has undergone maintenance, alterations or software upgrades that affect the UAS operation

or flight characteristics, e.g. replacement or upgrade of a flight critical component, the UAS will undergo

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

test flight will make an entry in the UAS aircraft records of the flight. The requirements and procedures

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

8. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/

overhaul, replacement, and inspection/maintenance requirements will be established and identified in the

operator’s manual. At a minimum, requirements for the following will be included in the operator’s

manual:

a. Actuators / Servos;

b. Powerplant (motors);

c. Propellers;

d. Electronic speed controller;

e. Batteries;

f. Remote command and control;

g. Ground control station (if used); and

h. Any other components as determined by the operator;

9. The Pilot­In­Command (PIC) will have passed a FAA private pilot’s knowledge test
and have a valid driver’s license. The PIC will also meet the flight review requirements specified in 14

CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate, if applicable.

10. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of 200 flight cycles or 25 hours of total time as a UAS pilot and at least ten hours

logged as a UAS pilot with a similar UAS type (single blade or multi­rotor). Prior documented flight

experience that was obtained in compliance with applicable regulations may satisfy this requirement.

Training, proficiency, and experience­building flights can also be conducted to accomplish the required

flight cycles and flight time.

11. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for

operations and three take­offs and three landings in the preceding 90 days. Training, proficiency,

experience­building, and take­off and landing currency flights can be conducted to accomplish the

required flight cycles and flight time.

12. The UAS may not be operated directly over any person, except authorized and consenting personnel,

or below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure

or emergency.

13 The operator will ensure that no persons are allowed within 500 feet of the area except those

consenting. This provision may be reduced if barriers or structures are present that can sufficiently protect

nonparticipating persons from the UAS or debris in the event of an accident.

14. The UAS PIC will abort the flight in the event of unpredicted obstacles or emergencies in accordance

with the operator’s manual.

15. Each UAS operation will be completed within 60 minutes flight time or with 25% battery power

remaining, whichever occurs first.

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

Authorization (COA) prior to conducting any operations. This COA will also require the operator to

request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior

to the operation.

17. All aircraft operated in accordance with regulations will be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N­Number) markings in accordance with 14

CFR part 45, Subpart C. Markings must be as large as practicable.

18. Each UAS operated will comply with all manufacturer Safety Bulletins.

19. The radio frequency spectrum used for operation and control of the UAS will comply with the Federal

Communications Commission (FCC) or other appropriate government oversight agency requirements.

20. At least three days before scheduled flight, the operator will submit a written Plan of Activities to the

local FSDO with jurisdiction over the area of proposed flight area. The 3­day notification may be waived

with the concurrence of the FSDO. The plan of activities must include at least the following:
a. Dates and times for all flights;

b. Name and phone number of the operator

c. Make, model, and serial or N­number of UAS to be used;

d. Name of UAS PIC involved

e. A statement that the operator has obtained permission from property owners and/or local officials to

conduct the flight operations; the list of those who gave permission must be made available to the

inspector upon request;

f. Signature of exemption­holder or representative; and

g. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or

state over which flights will be conducted and the altitudes essential to accomplish the operation.

22. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground

Control Station of the UAS any time the aircraft is operating.

23. The UAS will remain clear and yield the right of way to all other manned operations and activities at

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

gliders, etc.).

24. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules

(SVFR) are not authorized. Special authorization may be requested for night operations by government

agencies in emergency situations on a case by case basis.

25. The UAS will not be operated by the PIC from any moving device or vehicle.

26. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from cloud.

27. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The

UAS may not operate within 5 nautical miles of the geographic center of a non­towered airport as denoted

on a current FAA­published aeronautical chart unless a letter of agreement with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as required by the

operator’s COA. The letter of agreement with the airport management must be made available to the

Administrator upon request.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the

operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office

(AFS­80) within 24 hours.
Appendix C ­ Mission Briefing/ Pilot Checklists

UAS Mission Briefing Guide

Date:

Briefing Time:

Aircraft #/Flight Title:

Crew Positions:

PIC:

PO:

GC:

Airspace (E) Altitude Time

Weather: (call local AWOS)

Time (ZULU):

Winds ­Direction:

­Speed:

­Gusts:

Visibility:

Skies:

Temp/Dew Pt.:

Altimeter:

Density Altitude:

Thunderstorm info:

Forecast:

NOTAMS:​​https://www.notams.jcs.mil/

Previous Gripes on Aircraft/GCS:

A/C

GCS

MAFS Signed (Y/N): Who?

Aircraft Inspection (Y/N): Who?

GCS Inspection (Y/N): Who?

Safety Checklist Signed (Y/N): Who?

Mission

Description:

Special Needs/Special Communication:

Go/No Go Criteria:

A/C; Wx
Frequencies:

Downlink:

Uplink:

ORM/Gotcha’s/Personal Issues:

Safety Brief­​FOD, Ears, No Cell phones/Cameras, EP Cables, Eyes on AC, Prop, Chatter, Where to Stand

Flight Details​​(for Flight Database)

Takeoff Time:

Land Time:

Total Time:

Phone Numbers:

Emergency: 911

CEO: xxx­xxx­xxxx

Operations: xxx­xxx­xxxx

Safety: xxx­xxx­xxxx

FSDO: (205) 876­1300
Pilot Checklists

Preflight Updated: 7Aug2015

GPS Antenna

Extend and lock into place. Check

antenna disk for security

Props Check for cracks or fraying

Motors

Check for security and smooth

movement

Arms Check for rotation or movement

Electronic components Check for security

Video transmitter

Check security, verify antenna is

securely screwed on and pointed

vertically down

Transmitter Install antenna

Transmitter

Check all switches up/aft, throttle

full done (idle)

Transmitter

Verify power button next to

antenna is set to low

Power‐up

Vulcan UAV

Place in takeoff spot, verify

takeoff area is clear overhead

Note: the UAV will return to

this spot in an emergency,

make sure it can land without

hitting anything

Transmitter

Power on via two plugs on back of

radio, verify "Vulcan Mantis"

displayed on screen

Note: verify camera controller

is also turned on at this time

Transmitter

Verify all switches up/aft, throttle

full down (idle)

Camera

lens cap remove, power on Verify Set "A", "MF" single

shot

Battery Plug in BOTH batteries

Before Flight

LED indicator

Verify working, should be flashing

purple/red or just purple

Check all other LEDs as well

Camera

Verify LED on bottom front left of

camera gimbal is flashing yellow.

Camera

Have camera person rotate

camera aft and down, press

record button once to bring up

menu, then a second time to start

recording.
Camera

verify record counter on display is

counting UP

LED indicator Verify blinking Purple with no red. GPS mode switch full up

LED indicator

Switch Mode to ATTI, verify

blinking Orange with no Red

ATTI mode switch middle

LED indicator

Switch Mode to Manual, verify no

lights illuminated

MAN mode switch full down

LED indicator

Switch back to ATTI, re‐verify

blinking Orange with no Red

ATTI mode switch middle

Takeoff

Crew

Verify camera person is ready for

takeoff

Area Visually clear

Motor start

Push sticks in lower opposite

corners, after motors start

smoothly apply power to 1/4

throttle

Pre‐liftoff

Wait for white LED to change back

to Orange or Purple, verify

smooth sounding motors

Liftoff

Slowly and steadily apply power

until lift off

Post liftoff

Climb to approx. 30 feet, hover,

raise landing gear. Verify all looks

good, continue smooth climb out

Note: don't just feel for the

landing gear switch, look

down and verify you have the

correct one before moving it.

Landing

Descent

Slowly descend to approx. 60ft,

hover and lower landing gear.

Note: don't just feel for the

landing gear switch, look

down and verify you have the

correct one before moving it.

Touchdown

Touch down at the slowest rate

possible with no side movement

Postflight

Camera

Have camera person rotate

camera 90 degrees down, press

record button. Verify recording

stops

Battery Disconnect batteries

Camera Turn off

Transmitter Turn off
Motors

Feel motors for temperature

differences, if one or more motors

are hotter than the others note

which one it is. DO NOT FLY AGAIN

Electronic Speed

Controllers

Feel ESCs for temperature

differences, if one or more ESCs

are hotter than the others note

which one it is. DO NOT FLY AGAIN

GPS antenna Lower and lock into place

Equipment

Return to case or change batteries

and start preflight over again

Ground Station Setup Updated: 7Aug2015

Antenna tripod setup Verify battery is installed

Video receiver

Place on tripod, verify

antenna is securely screwed

on and vertical

Case Battery (orange) Plug into battery red lead

Goggle video transmitter

Place on Velcro on front of

case, extend antenna

vertically, plug battery lead

into 3s port

Goggles

Remove from case, screw

on antenna

Monitor

Turn on, verify mode is on

AV2

Video splitter

Verify on AV2, press "Mute"

button to silence beeps.

Video receiver

Plug into battery red lead,

extend tripod to highest

level.

warning: in windy

conditions weigh tripod

down or secure to ground

DVR recorder

Plug Red Pushbutton switch

into AV OUT port on top of

DVR

Camera controller

Verify all switches aft,

throttle (left stick) full down
Camera controller

Turn on, verify "Vulcan

Mantis Cam" reading on

screen

Ground Station Operation

Vulcan UAV powered on

Verify clear picture on

monitor

Vulcan UAV powered on

Center camera after auto

calibration is complete

Vulcan UAV powered on

Rotate camera down 90

degrees, pilot starts

recorder

DVR

Press and hold big red

button for 2 sec then let go.

Verify screen turns on, red

REC is displayed

Goggles

Plug in battery, place on

head

Post Flight

Camera

Rotate 90 degrees down for

pilot to end recording

Goggles

Remove from head,

disconnect battery and

unscrew antenna, place

back in box

Transmitter Turn off

DVR

Press and hold big red

button for 2 sec then let go.

Verify screen turns off

Battery

Disconnect battery from red

connector and goggle

receiver from 3s port

Goggle receiver

remove from front of case,

place back in case

Video receiver

Lower tripod, disconnect

battery, place receiver back

in case, top left slot.

Note: be careful not to

damage blue cloverleaf

antenna

Case

Tuck all cables away nicely,

place goggle box on top. Lay

fancy blue cover over top,

close and lock case

Troubleshooting
Poor video quality in goggles

Check antenna position on

goggles and goggle video

transmitter. Both should be

vertical.

Poor video quality in goggles

Check no obstructions

between goggle antenna

and goggle video

transmitter antenna

No picture on goggles

Verify battery is plugged in

on goggles and on goggle

video transmitter

No picture on monitor

verify battery is plugged in.

Verify Mode is AV2

Video picture quality poor

Verify clear Line of Site to

UAV video transmitter

Note: video quality will be

poor when UAV is directly

overhead video receiver

due to antenna radiation

pattern

No video, just fuzzy

Verify video splitter is set to

AV2

No video, just fuzzy

Press red button on top of

video receiver until video is

displayed on monitor

Note: there are 8

channels on the video

receiver. Pressing red

button steps through each

channel. If you go past 8

button clicks and still no

video, that is not the

problem

No video

Verify camera is on and

green light is illuminated

underneath camera

Note: if red light

underneath camera is

illuminated power camera

down and back on. If that

doesn't work power down

entire UAV then power

back up.

Emergency Procedures Updated: 7Aug2015

EMERGENCY VISUAL CLUE ACTION

Loss Link

Landing gear auto extends,

FS displays in Mode position

Switch transmitter

power to High, If
on monitor, aircraft not

responding to control inputs

control not

reestablished aircraft

will execute return

home profile. Note ‐

once AV regains signal

it will enter whatever

mode is selected.

Loss of motor or

Prop inflight

Aircraft will spin

uncontrollably

Switch to Intelligent

Orientation Control

mode ‐ Home (IOC

switch full down). Fly

home while still

spinning, when within

10m of home point

switch to Coure Lock

(switch middle), land in

grass.

Uncontrollable

descent

Aircraft will descent quickly,

high throttle will not arrest

descent

Throttle Full. Switch to

MANUAL Mode (switch

full down). Lower

landing gear. Climb,

when at safe altitude

switch back to ATTI

mode.

Transmitter

battery low

Transmitter will beep loudly

and fast

RTB ASAP (aircraft will

go into loss link if tx

battery fails)

Loss of orientation

Pilot can not tell orientation

of aircraft (too far away)

Switch to Intelligent

Orientation mode

(switch full down), pull

aft on right stick to fly

home

Aircraft low

battery

LED flashing YELLOW very

fast

RTB ASAP

Aircraft battery

critical

LED flashing RED very fast Lower landing gear,

RTB ASAP. May have to

land away from base. If

in unsafe area to land

switch Mode to

MANUAL, fly to safe

area and land.