UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

UNUSUAL ATTITUDES, LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF 3DR X8+ 

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on December 10, 2015
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TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS...................................................................................3 

SUMMARY...........................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4 

BACKGROUND....................................................................................................................6 

BASIS FOR PETITION.........................................................................................................6 

NAME AND ADDRESS OF PETITIONER.............................................................9 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH UNUSUAL 

ATTITUDES SEEKS EXEMPTION.................................................................9 

THE EXTENT OF RELIEF UNUSUAL ATTITUDES SEEKS AND THE 

REASON UNUSUAL ATTITUDES SEEKS THE RELIEF.........................13 

THE REASONS WHY GRANTING UNUSUAL ATTITUDES’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .........................................................16 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......33 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT UNUSUAL ATTITUDES’S REQUEST.........34 

SUMMARY....................................................................................................................34 

APPENDICES........................................................................................36
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Unusual Attitudes, LLC (“Unusual Attitudes”) seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft 

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Unusual Attitudes to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of 

construction sites, real estate, special events, film sets, and landscape over certain areas of 

the United States. Unusual Attitudes will reserve two (1) Special Registration Number 

with the FAA to ensure that their UASs are properly registered with the FAA

INTRODUCTION AND INTERESTS OF THE PETITIONER

Dr. Malay Ghose-Hajra of Metairie, Louisiana is the President of Unusual 

Attitudes. Dr. Ghose-Hajra holds a doctorate degree in Civil Engineering and is a 

registered Professional Engineer (P.E.) in multiple states including Louisiana. He also 

holds a private pilot certificate in single engine airplane (SEA land) and possesses 

Instrument rating in single engine airplane (land). Dr. Ghose Hajra has over 250 hours of 

total flight time in single engine airplane (land). 

Over the past several months, members of Unusual Attitudes have garnered much 

attention as hobbyists using their UASs to capture aerial imagery in a safe, FAA approved 

manner. Unusual Attitudes has logged hundreds of hours flying their 3DR Robotics X8+ 

UAS with a main focus always being on the safety of those on the ground and in the air 

alike. Unusual Attitudes has participated in UAS seminar courses and has collaborated 
5

with other organizations such as Dart Drones to spread the word on the proper use of 

UASs in the national airspace. 

Based in Metairie, Louisiana, Unusual Attitudes now seeks to use their experience 

in the area of UAS aerial image capturing and knowledge of US National Airspace System 

to bolster the economic climate of USA. The objective of Unusual Attitudes is to provide 

private and government entities business with high quality imaging for a variety of 

commercial, public, and residential uses, specifically targeting: 

 Aerial survey of coastal areas using remote sensing and photogrammetry

 Industrial aerial inspections (powerline, railway line, oil pipeline, excavation site 

mapping)

 Construction site monitoring

 Aerial monitoring of hurricane and extreme storm events

 Motion Picture filming for use in various businesses media campaigns.

 Improving Local News Outlets access to high quality aerial imagery.

 Aerial acquisitions of public and private structures for use by realtors and property 

buyers alike.

 Increase public knowledge of UAS and promote safe UAS operations.

 Search and Rescue operations.

 Volunteering their services to aid the efforts of First Responders.
6

BACKGROUND

Unmanned Aircraft Systems: 3DR Robotics X8+ UAS

Unusual Attitudes seeks an exemption to operate 3DR Robotics systems for 

compensation or hire within the National Airspace System (NAS). The 3DR Robotics X8+ 

is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) utilizing electronic tablet or smart phone systems. The 3DR Robotics X8+ 

has a maximum gross weight of approximately 7.7 pounds, while having a length of 20.1 

inches width of 13.7 inches, height of 11.8 inches, and a maximum speed of approximately 

25 mph. The The 3DR Robotics X8+ is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. 

The The 3DR Robotics X8+ will be operated by Malay Ghose Hajra, who holds a 

FAA private pilot certificate (instrument rating). He will serve as the Pilot in Command 

(PIC) during the operation of the UAS. Unusual Attitudes will reserve one (1) Special 

Registration Number with the FAA in accordance with 49 U.S.C. 44103, Registration of 

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

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

BASIS FOR PETITION

Pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) 

and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules 

for Certain Unmanned Aircraft Systems, the petitioner, Unusual Attitudes, hereby petitions 

the Administrator to commercially operate the 3DR Robotics X8+ UAS in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 
7

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Unusual Attitudes’ operation of The 3DR 

Robotics X8+ UAS meets the conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Unusual Attitudes requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Unusual Attitudes submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Unusual Attitudes will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

using the methods, techniques, and practices prescribed in the operating documents (i.e., 

Monthly Maintenance Log, and The 3DR Robotics X8+ user manual). Furthermore, 

Unusual Attitudes will document and maintain all maintenance records for the 3DR 

Robotics X8+ UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Unusual Attitudes to the 

extent necessary to allow a Pilot in Command (PIC) who has demonstrated that the PIC is 

able to safely operate the 3DR Robotics X8+ UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. An individual will ensure that the 

UAS remain in direct live-of-sight at all times that the PIC is flying the UAS.
8

Unusual Attitudes seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the 3DR Robotics X8+ UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Unusual Attitudes 

submits that it will ensure that the 3DR Robotics X8+ UASs are in an airworthy condition, 

prior to every flight, by determining that the UASs are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and 3DR Robotics X8+ user manual), and that 

the aircrafts are in a condition for safe flight. 

Unusual Attitudes also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the 3DR Robotics X8+ UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the 3DR Robotics X8+ 

will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GPS for active 

monitoring of the flight path. This altitude information, combined with Unusual Attitudes’ 

operation of the 3DR Robotics X8+ UASs within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Unusual Attitudes seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Unusual 

Attitudes submits that safety will not be affected by operation of the 3DR Robotics X8+ 

UASs during daylight hours in visual meteorological conditions (VMC) under visual flight 

rules (VFR), with enough battery power to fly for a total duration of approximately 14 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 
9

In accordance with 14 C.F.R. § 11.81, Unusual Attitudes provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Unusual Attitudes, LLC

2 Fairfield Court

Metairie, LA 70001

Point of Contact:

First name: Malay

Last name: Ghose Hajra

Phone: (504) 905-8447

Email: malay.ghosehajra@gmail.com

B. The Specific Sections of 14 C.F.R. From Which Unusual Attitudes Seeks 

Exemption. 

1. Unusual Attitudes Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Unusual Attitudes Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 
10

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

3. Unusual Attitudes Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Unusual Attitudes Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

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

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

5. Unusual Attitudes Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—
11

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Unusual Attitudes Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. Unusual Attitudes Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Unusual Attitudes Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 
12

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 
13

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Unusual Attitudes Seeks Relief And The Reason Unusual 

Attitudes Seeks The Relief. 

1. Extent Of Relief Unusual Attitudes Seeks And The Reason Unusual 

Attitudes Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC to 

conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, Unusual Attitudes submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the 3DR Robotics 

X8+ UASs unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate the 3DR Robotics X8+ UASs in a 

manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures.

Further, Unusual Attitudes submits that all flights of the 3DR Robotics X8+ UASs, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to 
14

Unusual Attitudes’ business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Unusual Attitudes Seeks And The Reason Unusual 

Attitudes Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Unusual Attitudes to determine that the 3DR Robotics X8+ UASs 

are in airworthy condition prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., the Unusual Attitudes Aerial Operations Manual, 

Monthly Maintenance Log, and 3DR Robotics X8+ UASs user guide). 

Unusual Attitudes seeks the requested relief because the 3DR Robotics X8+ UASs 

do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Therefore, Unusual Attitudes will ensure that the 3DR Robotics X8+ UASs are in 

airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and 3DR Robotics X8+ Instruction Manual) prior to every 

flight, and further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below.

3. Extent Of Relief Unusual Attitudes Seeks And The Reason Unusual 

Attitudes Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the 3DR Robotics X8+ UASs, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UA to the PIC at the ground control station (GCS). Since the 

FAA requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Unusual Attitudes seeks the 

requested relief because the 3DR Robotics X8+ UASs altimeter may be set on the ground 
15

to zero feet AGL, rather than the local barometric pressure or field altitude, before each 

flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the 3DR Robotics X8+ UASs are equipped with a barometric pressure 

sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Unusual Attitudes Seeks And The Reason Unusual 

Attitudes Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered 3DR 

Robotics X8+ UASs during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. Unusual Attitudes seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered 3DR Robotics X8+ 

UASs will severely constrain the practicality of any aerial video or still photo flight 

operations that Unusual Attitudes proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the 3DR Robotics 

X8+ UAS operating documents, and Unusual Attitudes’ proposed operating limitations, 

ensure that Unusual Attitudes will safely operate the battery powered 3DR Robotics X8+ 

UASs during daylight hours in visual meteorological conditions (VMC), under visual 
16

flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 4.5 minutes.

5. Extent Of Relief Unusual Attitudes Seeks And The Reason Unusual 

Attitudes Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Unusual Attitudes requests relief 

from these Sections because the 3DR Robotics X8+ UASs do not require airworthiness 

certificates. As set forth more fully below, the 3DR Robotics X8+ UASs meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Unusual Attitudes will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the Unusual Attitudes Aerial 

Operations Manual, Monthly Maintenance Log, and 3DR Robotics X8+ Instruction 

Manual). Furthermore, Unusual Attitudes will document and maintain all maintenance 

records for the 3DR Robotics X8+ UASs. 

D. The Reasons Why Granting Unusual Attitudes’ Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Unusual 

Attitudes to safely, efficiently, and economically perform aerial video and photography of 

construction sites, engineering project sites, real estate, special events, film sets, and 

landscape over certain areas of the United States.

Additionally, use of the 3DR Robotics X8+ UASs will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the 
17

benefits of Unusual Attitudes’ proposed operation of the 3DR Robotics X8+ UASs will be 

realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The 3DR Robotics X8+ UASs are battery powered and serve as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, 

an exemption allowing the use of 3DR Robotics X8+ UASs would reduce the amount of 

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of 

life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

3DR Robotics X8+ UASs do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The 3DR 

Robotics X8+ UASs

Conducting aerial acquisitions with the 3DR Robotics X8+ UASs, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and 

noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the 3DR Robotics X8+ UASs 

produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 20-30 gallons per hour of 
18

leaded aviation fuel. The 3DR Robotics X8+ UASs, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine. 

By using the 3DR Robotics X8+ UASs to perform aerial acquisitions, substantial 

risk to life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be considerably reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

3DR Robotics X8+ UASs (weighing approximately 2 pounds 11 ounces at their maximum 

gross weights with length of 16 inches and width of 16 inches and with no fuel on board), 

has less physical potential for collateral damage to life and property on the ground, and in 

the air, compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length 

of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations with the 3DR 

Robotics X8+ UASs will benefit The Economy. 

In addition to being safe and efficient, the 3DR Robotics X8+ UASs are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the 3DR Robotics X8+ UASs will allow United States based companies, 

like Unusual Attitudes, to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered 3DR Robotics X8+ UASs is one such 

technology that not only allows companies greater operational flexibility compared to 
19

manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the 3DR Robotics X8+ UASs, companies such as Unusual Attitudes, 

can remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial use of 

the 3DR Robotics X8+ UASs, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest 

in research and development in order to remain competitive both in the United States and 

abroad. 

4. Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Unusual Attitudes’ proposed operation of the 3DR Robotics X8+ UASs will not 

implicate any privacy issues. Specifically, the 3DR Robotics X8+ UASs will be operated 

only in compliance with operating documents (i.e., the Unusual Attitudes Aerial 

Operations Manual, Monthly Maintenance Log, and 3DR Robotics X8+ UASs Instruction 

Manual) which requires property owner involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Unusual Attitudes Seeks Exemption. 

1. Reasons Why 3DR Robotics X8+ UASs Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 
20

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, Unusual Attitudes’ operation of the 3DR 

Robotics X8+ UASs meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Unusual Attitudes submits that the 3DR Robotics X8+ 

UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: 
21

(a) the characteristics of the 3DR Robotics X8+ UASs; (b) the specific operating 

limitations. 

a. The Specifications Of The 3DR Robotics X8+ UASs Demonstrate Its Safe 

Characteristics.

The 3DR Robotics X8+ UASs do not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, speed, 

and operational capability. 

i. Technical Specifications Of The 3DR Robotics X8+ UASs

The technical specifications of the 3DR Robotics X8+ UASs are set forth by the 

3DR Robotics X8+ UASs Specifications and Data Sheet, attached hereto as Appendix A.

ii. The 3DR Robotics X8+ UASs Autonomous Flight And Navigation 

Modes Enable The UASs To Remain Within A Defined Operational 

Area. 

The 3DR Robotics X8+ UASs may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and navigational modes of 

the 3DR Robotics X8+ UASs in the user Manual, attached in Appendix A. 

iii. The 3DR Robotics X8+ UASs Are Designed For Automatic Return 

To Home Point Or Hover In The Event Of Loss Of The Control 

Link Or Navigation. 

When the Control Link is lost, the 3DR Robotics X8+ UASs will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the 3DR Robotics X8+ UASs do not 

reacquire control link data from the GCS, the UAs will assume that the Control Link is lost 

and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will 

descend to the takeoff position and shutdown. 

iv. The 3DR Robotics X8+ UASs GCS And Its Operation.
22

A complete description of the operation and specifications of the 3DR Robotics 

X8+ UASs and flight control software is provided in the User Manual 

b. Flight Operations Of 3DR Robotics X8+ UASs Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer. 

Unusual Attitudes will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the 3DR Robotics 

X8+ UASs. Additionally, a safety observer will assist all pilots during flight time. 

c. Flights Of 3DR Robotics X8+ UASs Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, Unusual Attitudes proposes to commercially operate 

3DR Robotics X8+ UASs for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: 3DR Robotics X8+ Unmanned Aircraft 

Systems. Proposed operations of any other aircraft will require a new petition or 

a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground 

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UAs must 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, as specified on the PIC’s FAA-issued airman 

medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.
23

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that 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 must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 
24

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published 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. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 
25

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. 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. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 
26

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Unusual Attitudes submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR 

Robotics X8+ UASs unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate the 3DR Robotics X8+ 

UASs in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Considering Unusual Attitudes’ proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the 3DR Robotics X8+ UASs, Unusual 
27

Attitudes submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for Unusual 

Attitudes’ specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Unusual Attitudes will not allow any PIC to operate the 3DR Robotics X8+ UASs 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 

3DR Robotics X8+ UASs that the PIC is able to safely operate the 3DR Robotics X8+ 

UASs in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Unusual Attitudes’ proposed operations. The 
28

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Unusual Attitudes will ensure safe operations by not allowing any 

PIC to operate the 3DR Robotics X8+ UASs unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

3DR Robotics X8+ UASs in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Unusual Attitudes will ensure that the 3DR Robotics X8+ 
29

UASs is in an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the 3DR Robotics X8+ UASs will be provided to the 

PIC via GPS equipment and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Unusual Attitudes’ operation of the 3DR Robotics X8+ UASs 

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point 

is automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the 3DR 
30

Robotics X8+ UASs; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, Unusual Attitudes will ensure that 

it will safely operate the battery powered 3DR Robotics X8+ UASs during daylight hours 

in VFR conditions, with enough battery power to fly for a total duration of 14 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the 3DR Robotics 

X8+ UASs; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b). Furthermore, safety will be ensured as the 3DR Robotics X8+ UASs 

provide audible and visual warnings to the PIC at the GCS when the UAs experiences low 

battery voltage, the first warning occurring at approximately 33% remaining battery power, 

and again at approximately 10% remaining battery power. At the critically low battery 

level, the 3DR Robotics X8+ UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 
31

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, Unusual Attitudes submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because Unusual Attitudes will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the UASs using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the Unusual Attitudes Aerial Operations 

Manual, Monthly Maintenance Log, and 3DR Robotics X8+ UASs construction Manual). 

Furthermore, Unusual Attitudes will document and maintain all maintenance records for 

the 3DR Robotics X8+ UASs.

Since the 3DR Robotics X8+ UASs will be inspected as prescribed by the operating 

documents, Unusual Attitudes will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 3DR Robotics X8+ 

UASs User Manuals are attached hereto in Appendix A; a copy of the 3DR Robotics X8+ 

UASs Maintenance LOG is attached hereto as Appendices C and D. 

Likewise, the exemption sought will not adversely affect safety because Unusual 

Attitudes will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

3DR Robotics X8+ UASs will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. 
32

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Unusual Attitudes’ proposed operating limitations, the 

operating documents, and the technical aspects of the 3DR Robotics X8+ UASs, Unusual 

Attitudes submits that safety will not be adversely affected by granting exemption from 14 

C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). 

The FAA has previously granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Unusual Attitudes requests 

that the FAA prescribe special conditions for the intended operation of the 3DR Robotics 

X8+ UASs, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, 

and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 
33

forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the 3DR Robotics X8+ UASs, since the airworthiness regulations 

of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the 

novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, 

states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Leading Edge’s intended operation of the 3DR 

Robotics X8+ UASs, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Unusual Attitudes Seeks Exemption: 

Unusual Attitudes seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 
34

A Brief Description Of The Nature Of The Exemption Unusual Attitudes 

Seeks: 

This exemption will permit Unusual Attitudes to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support 

Unusual Attitudes’ Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Unusual Attitudes’ request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as 

set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, Unusual Attitudes will operate the 3DR Robotics X8+ 

UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security. 

SUMMARY

As set forth herein, Unusual Attitudes seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the 3DR Robotics X8+ UASs commercially, without 

an airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA 
35

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing Unusual 

Attitudes to safely, efficiently, and economically operate the 3DR Robotics X8+ UASs 

commercially within the NAS. 

More importantly, granting Unusual Attitudes this exemption will allow for New 

Orleans and the rest of Louisiana to advance its economy and provide a new and refreshing 

business to the area. Granting Unusual Attitudes’ exemption will be granting Louisiana 

the right to believe that there is hope on the horizon in the form of a modernization of 

business practices.

In accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, Unusual Attitudes respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b), and permit Unusual Attitudes to operate the 3DR X8+ UAS 

commercially for the purpose of conducting aerial video and photography over certain 

areas of the United States.

Respectfully submitted,

Malay Ghose Hajra, Ph.D., P.E.

Unusual Attitudes

2 Fairfield Court

Metairie, LA 70001

Dated: December 15, 2015
36

Appendices

Appendix A

 3DR Robotics X8+ Checklist

 3DR Robotics X8+ Operation Manual

Appendix B

 Routine Maintenance Procedures

Appendix C

 Monthly Maintenance Log

X8+

Operation Manual
Meet the X8

+

Thank you for purchasing an X8+! The X8 is a powerful octocopter platform for aerial video. Review this manual in its entirety before your first flight. Additional instructions can be found in the X8 information portal at 3DR.com/X8/info. Happy flying!
Contents

Parts 2Setup 4Assembly 4Ground Station 5Power Management 7Charging 8Safety 8Controller Battery 9Powering the X8 10Connecting to a Ground Station 11Flight Basics 12Safety 12Operating Limits 13Controls 14Modes 17Return to Launch 19Failsafes 20Status Indicators 22

Flight Procedures Takeoff Landing Monitoring Missions Planning Saving Initiating Ending Appendix Troubleshooting Maintenance Specs Resources 
Parts

USB adapter

Ground Station Radio

Android adapter

SF propellers (4)SFP propellers (4)

Charger and accessoriesGuard bag

RC Controller Propellers Battery Kit 

Flight battery Radio
X8+
Setup: AssemblyThe X8 arrives in travel configuration. Complete these steps to prepare the X8 for flight.1 Unfold Arms

12

Remove the bolts and thumbnuts near the two folded black arms (1). Unfold the black arms, re-insert the bolts, and secure with the thumbnuts (2).12

X8 Assembly: Unfold Arms
2 Unfold LegsRemove the bolts and nuts to the inside of the folded legs (1), unfold the legs, re-insert the bolts, and secure with the nuts (2).

3 Attach PropelleThe X8 uses SF and SFP propeller packages and below shows which motassembly of SF and SFP To attach each propellerand add the correct type the sky. (This is a tight fit; motor.) Replace the waswrench to tighten the nu

12

X8 Assembly: Unfold Legs

top motor: SF

bottom motor: SFP

bottom motor: SF

top motor: SFP

X8 Prop
Ground StationA ground station is a laptop or tablet running an ArduPilot-compatible mission control application. In the field, a ground station helps you monitor the X8 during flight, plan missions, and troubleshoot issues. We recommend using a ground station at all times with the X8. To set up a ground station, choose a platform below and visit 3DR.com/download_software to install the application.

Windows

Mission Planner

OS X

APM Planner

Android

DroidPlanner 2

Important Note About Vehicle Setup in Mission Planner and APM Planner:Your X8 has been pre-configured at the factory and is ready to fly. Re-performing the calibrations on the Initial Setup screen, including the mandatory hardware configurations and setup wizard, can adversely affect the performance of your aircraft.iOS? There are currently no ground station applications available for iOS.
Power ManagementThe X8 is powered by a rechargeable lithium polymer (LiPo) battery. When fully charged, the battery provides up to 15 minutes of flight time depending on payload, environmental conditions, and flying style. Flying with a gimbal, GoPro, and FPV system can reduce flight time by up to 5 minutes. Flying aggressively or in high winds can affect power consumption and reduce flight time. Monitor power consumption using the flight data display on the controller (press and hold the DN button).When the battery reaches the low voltage limit, the X8 initiates a low battery failsafe and lands automatically at the current position. (See page 20 for more information about failsafes.) To avoid a low battery failsafe, regularly check the controller’s flight data display to monitor battery voltage, and end your flight before the battery reaches the low voltage limit.

Press a

button to 

flight battery mAh consumed since armeAnother way to monitor power consumption Monitor the mAh on the controller, and ensuexceed 8,000 mAh (80% of the battery’s avmAh can render the battery permanently un

Do not exceed 8,000 mAh for a fu

flight battery level Full battery: 16.8 VLow battery limit: 14 V

End your flight at 14.1 V.

!

Controller Flight Data Display: Screen 1

!
ChargingCharge the battery before your first flight!1 Connect the charger to the power adapter cable and plug the adapter cable into a wall outlet. Connect the red cable to the + port and the black cable to the - port.

+

–

2 Set the charger to LiPo and 3A.

LiPo 3A

3 Connect the battery’s white connector to the charger’s 4S port, and join the two yellow connectors together. 

4S

4 Secure the battery inside the guard bag, and charge until the status indicator displays green.

Charging

Complete

Charger with power cable and split-wire charging cable

Charger settings

Flight battery charging wiring Charging in process
Controller BatteryThe controller is powered by 8 AA batteries (included). The controller’s flight data display allows you to monitor the voltage of the controller. When fully charged, the controller displays 12 V; when completely out of charge, the controller displays 9 V. Replace the batteries when the controller displays 9.1 V.

Press a

button to v

controller battery level (9-12 V)

Controller Flight Data Display: Screen 1 Replace controller batteries at 9.1 

!
10

Powering the X8

Follow these steps to power the X8.

2

To power on the X8, join the yellow connector on the battery with 

the yellow connector on the X8. Keep the X8 still and level while 

it powers on and initializes the sensors. When the status LED 

displays blinking blue, the sensors have completed initialization and 

you can move the X8.

It is important to establish 

communication before powering 

on the X8. Always turn on the 

controller before connecting the 

battery. When powering off the 

X8, disconnect the battery before 

turning off the controller.

1

Turn on the controller. Ensure that the switches 

are set to CH 7 OFF, STD, and RTL OFF.

RC controller

Stabalize

Altitude Hold

Loiter

Full Autonomy

Stabalize

Altitude Hold

Loiter

Full Autonomy

X8: Connect battery, keep level while initializing

Stabalize

Altitude Hold

Loiter

Full Autonomy

CH 7 switch Mode switch RTL switch

Initializing, keep still and level

Initializing complete

Status LED indicators:

3

When the initialization process is complete, turn over 

the X8 and secure the battery to the underside of the 

vehicle using the velcro straps.

X8: Secure battery

!
11

Connecting to a Ground Station

To connect the X8 to a ground station, connect the ground station radio to 

your laptop or tablet and power the X8.

Tablet (DroidPlanner)

1 

Connect the ground station radio to your 

laptop using the USB adapter. Open 

Mission Planner or APM Planner.

3

Select Flight Data to view live data from the X8.

2

Select AUTO and 57600, then select CONNECT. 

(When connecting directly to Pixhawk’s 

micro-USB port, set the rate to 115200.)

Ground station laptop with radio connected

Mission Planner Connect tool (top-right corner)

Mission Planner Flight Data tab: connected to aircraft

Laptop (Mission Planner/APM Planner)

1

Connect the blue end of the Android adapter 

to your device and the black end to the radio.

2

Select Connect.

Ground station tablet with radio connected DroidPlanner: Connect icon
Flight Basics: Safety

To ensure safe and successful flying, always fly in accordance with your location regulations and these best operating practices.Before you fly, determine the boundaries of your safe flying area. If the X8 moves outside the designated area or exhibits instability in flight, switch to standard mode and land the X8 manually.The X8 cannot avoid obstacles on its own, including during missions. As the operator, it’s your responsibility to recognize and avoid obstructions while flying. Always be ready to regain manual control of the X8 in the event of an unsafe situation. 

visual line of sight 

100 ft (30 m) 

Always fly below 400 ft (120 m) and within your visual line of sight. Don’t let the X8 get too far away from you; make sure you can always see its orientation. Don’t fly in low light, high winds, rain, or other conditions that might impede visibility.

visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 

visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 km)

Spinnbuttopreveprope•    •     

visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 km)

visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 km)

Location

Propellers
Operating LimitsAlways fly within the X8’s operating limits.

Maximum altitude* 100 m (328 ft)Range* 300 m (984 ft) from launch pointGPS lock GPS lock required at all timesMaximum estimated flight time 15 minPayload capacity 800 g (1.7 lbs)

X8+ Operating Limits*While geofence enabled (default)
14

Maneuver the X8 in flight using the 

controller’s two joysticks.

left stick:

throttle

& yaw

right stick:

pitch

& roll

Left Stick

Left Stick

Move the throttle 

stick below center to 

decrease altitude. 

Set the throttle stick 

to center to maintain 

the current altitude.

left stick

Left Stick

Left Stick

Move the left stick vertically to control altitude.

Set the throttle stick 

fully down to land 

once the X8 is a few 

inches above the 

ground.

Left Stick

To take off and to 

gain altitude, push the 

throttle stick slightly 

above center position. 

Left Stick Left Stick

Controls

Throttle
15

Flight Tip

When adjusting orientation, move the left stick horizontally without changing its 

vertical position.

ver + Land

wer just slightly

hover

ft Yaw

Left

Righ

ght Yaw

activate

d until propellers

p spinning

ver + Land

wer just slightly

hover

ft Yaw

Left

Righ

ght Yaw

activate

ld until propellers

p spinning

Move the stick to 

the left to rotate 

counterclockwise.

Move the stick 

to the right to 

rotate clockwise.

left stick

Left Stick

Release the stick to 

stop rotating and 

maintain the current 

orientation.

Move the left stick horizontally to rotate the X8 and change orientation. 

For a slow rotation, move the stick slightly away from the center

in either direction. Moving the stick farther from the center creates 

a faster rotation.

Left Stick

Yaw
16

Left

Back

Forward

Right

Left

Back

Forward

Right

Move the right 

stick forward 

to fly forward.

right stick

Move the right 

stick back to fly 

backward.

The right stick allows you to control the X8’s position in the air. Move the right stick to tell the 

X8 to move in that direction: forward (toward the blue arms), back (toward the black arms), 

left (toward the left arms), or right (towards the right arms). How far you move the stick from 

the center before releasing it tells the X8 how fast to move. 

Left

Back

Forward

Right

Left

Back

Forward

Right

Move the right 

stick left to fly 

left.

Move the right 

stick right to fly 

right.

Flight Tip

The X8 moves according to its orientation. The blue arms face forward, and the black 

arms face backward. Before using the right stick, use yaw to keep the X8 facing in 

outward orientation so that the black arms face towards you and the blue arms and face 

away from you.

Pitch and Roll
17

!

Standard (altitude hold mode)

STD

fly manually

Start your flight in standard to select altitude hold mode, 

and fly manually using the controller.

Loiter mode

LTR

hover

Select loiter to hover in place automatically. Use the controller 

to adjust the X8’s position then release the sticks to hold 

that position. Loiter is a great way for beginners to learn how to fly! 

If you’re new to flying, start your first flight in loiter instead of standard.

Stabalize

Altitude Hold

Loiter

Full Autonomy

Stabalize

Altitude Hold

Loiter

Full Autonomy

Return to Launch

mode switch

The X8 includes three flight modes: manual flight 

(STD-altitude hold), hover mode (LTR-loiter), and 

mission flight (AUTO). Use the switch on the 

right side of the controller to select a flight mode.

To avoid sudden changes in altitude, set the throttle 

stick to center position before switching modes, 

including in the event of a GPS failsafe. See page 20 

for more information about failsafes.

Modes
18

Auto mode

AUTO

fly a mission

Select auto mode to fly an autonomous mission. The X8 

automatically flies the series of waypoints saved to the autopilot. 

See the Missions section on page 28 for instructions on planning and flying missions.

Altitude Hold

Loiter

Full Autonomy

Return to Launch

Gimbal control

TILT

tilt the camera up and down

Connect a Tarot Gimbal (sold separately), and use the TILT knob to control the 

angle of the camera in flight. Visit 3DR.com/X8/info for instructions. Stabalize

Altitude Hold

Loiter

Full Autonomy

Land

CH 7

land at the current position

Set the CH 7 switch to ON to end your flight and land at the current position. 

Once you activate land, set the throttle stick fully down, and the X8 

automatically disarms after landing. The X8 does not disarm automatically 

unless the throttle stick is set fully down.

Reposition during landing: During landing, use the right 

stick on the controller to adjust the X8’s position.

! Do not activate auto mode unless you have saved 

a mission to the X8 using a ground station application.
19

land at the launch point

Set the RTL switch to ON to end your flight and return the X8 to 

the launch point automatically. Once you activate RTL, set the 

throttle stick fully down, and the X8 automatically disarms after 

landing. The X8 does not disarm automatically unless the throttle 

stick is set fully down.

When commanded to RTL, the X8:

1 Achieves minimum altitude of 15 m (50 ft) or maintains current altitude 

 if above 15 m.

2 Moves to launch point and loiters for 5 seconds.

3 Lands at launch point. Wait for a few seconds until the X8 disarms 

automatically.

launch point

1 15 meters 2

3

hover 5 seconds

Altitude Hold

Loiter

Full Autonomy

Return to Launch

Return to Launch

Reposition during landing: During landing, use the right 

stick on the controller to adjust the X8’s position.

! RTL returns the X8 to the location where it was armed. 

Always arm the X8 at a safe, unobstructed launch point.
20

Failsafes

400 ft

(120 m)

400 ft

(120 m)

Low Battery Failsafe

Environmental conditions, payload, and flying style can affect power 

consumption. Use the controller’s flight data display to monitor the 

voltage of the battery during flight.

If the battery reaches 14 V, the X8 lands automatically at the current 

position, indicated by a blinking yellow status LED and a quick 

repeating tone.

The X8 is programmed with a set of failsafe behaviors to prevent a crash in 

the event of a loss of one of the data or communication channels required for 

flight. Although certain failsafes have assigned LED indicators and tones, it is 

unlikely that you will be able to see these at a distance. Monitor the ground 

station for failsafe indications. If a failsafe is triggered, the assigned behavior 

activates. To override the failsafe behavior, use the controller to switch to 

standard mode and regain manual control. 

RC Controller Signal Failsafe

Physical obstructions and interference from nearby wireless signals can affect 

the X8’s connection with the controller. 

If the X8 loses contact with the controller, it returns to the launch point and lands 

automatically, indicated by a blinking yellow status LED.
21

GPS Failsafe

The X8 requires GPS lock before takeoff. Enclosed areas, physical 

obstructions, and lack of available satellites can affect GPS strength. If 

the X8 loses GPS lock in flight, it triggers a GPS failsafe—indicated by 

a blinking blue and yellow LED with a high-high-high-low tone—and 

automatically switch to manual control (standard - altitude hold mode). 

Always be prepared to regain manual control at any time while flying and 

choose an unobstructed flying area to improve GPS signal strength. When 

flying a mission, we recommended changing the GPS failsafe behavior to 

land. (Visit 3DR.com/X8/info for more information about configuring the 

GPS failsafe.)

Altitude Failsafe

The X8 has a 100 m (328 ft) altitude geofence enabled by default. If the 

geofence is breached, the X8 automatically switches to RTL.

400 ft

(120 m)

manual 

control

100 m

(328 ft)

Range Failsafe

The X8 has a 300 m (984 ft) horizontal geofence enabled by 

default. If the X8 travels farther than 300 m from the launch point, 

it automatically returns to the launch point and lands. If you plan to 

fly a mission that exceeds this range, you will need to disable the 

horizontal geofence. (Visit 3DR.com/X8/info for instructions.) The 

range failsafe is disabled in the event of a GPS failsafe.
22

Status Indicators

Low battery, automatic landing

Loss of RC signal, automatic landing

Pre-arm safety check failure—connect to a ground station 

and see the troubleshooting section

Loss of GPS signal, switch to standard mode (altitude hold)

Initializing, hold the X8 still and level

Acquiring GPS, please wait

Armed

Autopilot ready, GPS locked

Status LED

The Pixhawk LED indicates the status of the X8. During flight, the LED won’t 

be visible; instead, use a ground station to view the status of the X8. Visit 

3DR.com/X8/info to listen to Pixhawk’s status tones.

X8 Status LED

LED
23

Safety Button

The safety button indicates the status of the motors 

to allow you to arm and disarm the X8 safely.

Safety button

X8 Safety Button

Motors inactive, safe to handle

Motors active, deactivate before handling
24

Flight Procedures: Takeoff

Follow these steps to take off.

» Propellers are attached tightly to the motors in the correct order and 

 the GPS mast is oriented vertically.

» The X8 is powered with the battery secured to the underside of the 

 vehicle. (Remember to hold the X8 still and level while the sensors 

 initialize.)

» The controller is set to CH 7 OFF, standard (STD) mode (loiter mode for 

 beginners), and RTL OFF.

» The status LED displays blinking green, indicating that the X8 has 

 acquired GPS lock. This can take a few minutes depending on your 

 flying location. 

» The X8 is situated at a safe, unobstructed launch point, facing away 

 from you.

Checklist
25

Arm

After completing the checklist, you’re ready to fly! Arming and disarming are 

important steps that must be completed before takeoff and after landing. 

Use the safety button and the controller to arm the X8.

1

Press and hold the safety button until it 

displays solid red. This indicates that the 

X8 is now active. Stand back!

Motors inactive, safe to handle

Motors active, deactivate before 

handling

2

To arm the motors, hold the left stick 

down/right until the motors spin.

Controller left stick: arming position

Safety button indicators

! The arming and disarming procedures ensure that you can safety start and 

stop motors without risk of injury. The X8’s motors will spin when armed! Make 

sure the propellers are clear of any obstructions, including your hands, before 

arming. Do not handle the propellers or pick up the X8 while the safety button 

is active (solid red).
Landing

1Press and hold the safety button until it blinks red. The motors are now inactive, and the X8 is safe to handle.

2To disarm the motors, hold the left stick down/left until the motors stop.

Disarm

For manual landing in standard or loiter mode:

Motors inactive, safe to handle

Motors active, deactivate before handling

Safety button indicators Controller left stick: disarming position

! Do not handle the propellers or pick up the copter while the safety button is active (solid red). Remember to disconnect the battery before turning off the 

controller when powering off.

If you end your flight using the Ch 7 land command or RTL, the X8 disarms automatically; wait for the motors to stop, and proceed to powering off. Attempting to disarm the X8 in either land mode or RTL mode can cause the cause the copter to flip.
Monitoring

Press and hold the DN button to access the flight data screensPress DN again to toggle between screens.

current flight modecontroller battery leGPS signal strengt

meters from launch point

flight battery level (

connection strength

current latitude

current longitude

altitude in meters

flight time

altitude in meters

GPS status

speed in m/s

flight battery mAh consumed since aEnd your flight at 1Do not exceed 800fully charged X8+ available capacity)

!

Monitor the X8 in flight using the controller’s flight data screens.

Controller

Controller Flight Data Display: Screen 1

Controller Flight Data Display: Screen 2
MissionsThe X8’s Pixhawk autopilot is capable of flying an autonomous mission without operator input. Ensure that you feel comfortable operating the X8 manually before attempting an autonomous mission.Environmental AwarenessBefore you fly, assess the features of your flying area. Determine the boundaries of the safe flying area, and be prepared to recover the copter manually if it goes outside this area. Be aware of any risks at your location, including bodies of water, structures, trees, etc. Designate a few areas as safety zones where you can safely land the copter in case of an unsafe situation.Radio Signal ConditionsFlying behind solid objects, like buildings and trees, blocks radio signals. Always maintain visual contact with the copter to ensure that the radio signal is unobstructed. Radio towers, cell phone towers, and nearby WiFi signals can also cause interference with the radio system and decrease its range. Avoid flying in populated areas to avoid sources of interference. AltitudeSelect an appropriate altitude for your flying location and local regulations. Remember the X8 cannot avoid obstacles during a mission; it completes the mission as planned. Select altitudes that avoid any obstacles, such as trees, and comply with the safety information in this manual.SpeedBy default, the X8 travels at 6.5 m/s (14.5 mph) during a mission. 

PowerAs the operator, it is your with the X8’s operating limaccount the effect of curRegaining Manual ContDuring a mission, keep thregain manual control at mission, switch to standainstability in the X8’s flighdesignated safe flying areautomatically triggers an as a hard recall commanFailsafesThe X8’s default failsafe bautonomous missions, wfor your flying location. F
Planning

Select the DroidPlanner icon, select Editor. Tap to add waypoints, or select the brush tool and draw a path for the X8 to follow.

Select Flight Plan, and clicthe bottom of the screen t

To plan a mission, power the X8 and connect to your ground station. Ground station applications require an Internet connection to access maps.Tablet (DroidPlanner) Laptop (Mission Planner

DroidPlanner: Edit waypoints Mission Planne

Takeoff and LandingBoth ground station applications provide the option to configure automatic takeoff and landing into the mission. Missions without automatic takeoff and landing must be initiated and ended in flight.
SavingSelect the option menu in the top-right corner, and select Send Mission. This command saves the mission 

to the X8.

On the Flight Plan scSelect Save WP File to 

After planning the mission, save the mission to the X8. The Pixhawk autopilot can store one mission at a time. When you initiate the mission, the X8 starts the mission stored to the autopilot at the time. Tablet (DroidPlanner) Laptop (Mission P

DroidPlanner: Send Mission (option menu)

Mission Planner: Flight Pla
Initiating

StabalizeAltitude HoldLoiterFull AutonomyReturn to Launch

Left Stick

For auto-takeoff, raise throttle to start mission.

Once you’ve saved the mission to the X8, follow these steps to fly the mission.

1 Perform a pre-mission test flight.Follow the standard takeoff procedure, and fly a brief test flight to verify that all controls (throttle, yaw, roll, and pitch) are responding normally.

2 Arm in standard mode.When you’re ready to start the mission, arm the X8 in standard (STD) mode.

3 Switch to auto mode.For automatic takeoff, arm the X8 in standard mode. Then switch to auto mode, and raise the throttle to initiate the mission.For manual takeoff, initiate the mission in flight by switching to auto mode.

Controller: mode switch Controller: mode switch Controller: left stick
Appendix: TroubleshootingMaintenancePre-Arm Safety Check Failure`If the status LED displays blinking yellow, the X8 is failing one of the pre-arm safety checks. To determine heads-up display on the ground station for the error message specifying the failed check.Radio Calibration Failure: Perform radio calibration or RC controller re-bindingAccelerometer Calibration Failure: Perform accelerometer calibrationCompass Calibration Failure: Perform compass calibration GPS Failure: Wait for improved GPS signal or move to a more open area (moVideo tutorials for performing calibrations are available at 3DR.com/X8/info.Replacement parts for the X8 are available for purchase at store.3DR.com.Instructions for replacing the wiring, plates, motors, and legs of the X8 are available at 3DR.com/X8/info.
SpecsBattery: 4S 14.8V 10,000 mAh 10CBattery Dimensions: 6.6 in x 2.6 in x 1.4 in (16.7 cm x 6.5 cm x 3.5 cm)Battery Weight: 803 gAutopilot Hardware: Pixhawk v2.4.5Autopilot Firmware: ArduCopter 3.2GPS: 3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update)Ground Station Radio: 3DR Radio v2 (915 MHz or 433 MHz)Motors: SunnySky V2216-12 KV800 IIFrame Type: XPropellers: APC Propeller 11x4.7 SF (4)

APC Propeller 11x4.7 SFP (4)

Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm)Payload Capacity: 800 g (1.7 lbs)Vehicle Weight with Battery: 2.56 kg (5.6 lbs)Maximum Altitude*: 100 m Range*: 300 m from launch point (1 km when geofence disabled)Maximum Estimated Flight Time: 15 min*While geofence enabled (default)
For more information about the X8, 

ur support line at 

8 am to 5 pm PST.
Flight Checklist

LED

Motors inactive, safe to 

handle

Low battery, automatic landing

Loss of RC signal, automatic landing

Pre-arm safety check failure

Loss of GPS signal, switch to manual

Initializing, hold the X8 level

Acquiring GPS, please wait

Autopilot ready, GPS locked

Armed

Safety Button

Motors active, deactivate before 

handling (see reverse)

Flight Modes

Return to launch

RTL

land at the launch point

Stabalize

Altitude Hold

Loiter

Full Autonomy

Standard position 

(altitude hold mode)

STD

fly manually

Loiter mode

LTR

hover

Stabalize

Altitude Hold

Loiter

Full Autonomy

Return to Launch

!

Stand back!

4 6

The motors are 

now active.

Hold left stick downright until motors spin.

1 2 Power on controller;

set to STD and RTL OFF.

Arm 

motors.

Press and hold safety 

button until solid red.

Connect

charged battery.

Choose a clear launch 

point, and face the X8 

away from you. 

5 Check 3 LED.

Place the X8 at 

launch point.

Go outside to 

an open area!

See the Operation 

Manual for complete 

instructions.

Auto mode

AUTO

fly a mission

©2014 3D Robotics. vB. DCT0005 All rights reserved.

Control gimbal

TILT

tilt the camera down and up

Land

CH7

land at the current position

Stabalize

Altitude Hold

Loiter

Full Autonomy

Stabalize

Altitude Hold

Loiter

Full Autonomy

X8+

Hold the X8 still 

and level while 

powering on.
Press and hold until 

blinking red to deactivate.

Hold left stick downleft until motors stop. 

1 2 Disarm 

motors.

Press safety 

button. 3 Disconnect battery. 4Power off 

controller. Postflight

Controller Flight Data

Press and hold the DN button to access the flight data screens. 

Press DN again to toggle between screens.

Lower left stick below 

center to descend.

Set left stick fully down to 

land when near the ground.

Left Stick

Left Stick

Raise left stick above 

center to take off and 

gain altitude.

Move left stick left 

and right to rotate.

Use right stick to fly forward, 

backward, left, and right.

Set left stick to center 

to maintain altitude.

Left Stick

Left Stick

Flight

current flight mode

controller battery level (9-12 V)

GPS signal strength in # of 

satellites

meters from launch point

flight battery level (14-16.8 V)

connection strength

current latitude

current longitude

altitude in meters

flight time

altitude in meters

For customer support, contact us at help@3dr.com

or call our support line at +1 (858) 225-1414 

Monday through Friday, from 8 am to 5 pm, PST.

3DR.com/X8/info 

GPS status

speed in m/s

flight battery mAh 

consumed since armed

End your flight at 14.1 V.

Do not exceed 8,000 mAh for 

a fully charged X8+ battery 

(80% of available capacity).

!
Appendix C

Routine Maintenance Procedures

Before and After each Flight 

1. Check condition of props (run finger along leading and trailing edges, flex both blades to 

check for hairline cracks);

2. Check motor shafts have no free play (missing E clip? Loose bell housing screw? Bad 

bearings?);

3. Check motors move freely when spun by hand;

4. Check condition of battery spade connectors and data pins (level, free movement, clean);

5. Check camera mounts are secure (and any other attachments, e.g. Flytrex core);

6. When powered up and idling confirm no unusual noise or vibration from motors.

Every week or every 10 flights (whichever is sooner)

1. Visual inspection of shell and other plastic components for cracking/damage (landing skids, 

camera mounting plates, etc.);

2. Check tightness of motor retaining screws and shell retaining screws (both 2.0mm hex);

3. Clean data spring pins and battery contact pads with alcohol and swab or proprietary 

electrical contact cleaner and cycle spring pins several times to check for spring weakness 

and full unimpeded travel;

4. Plug in to Vision Assistant and check tx & IMU calibration state and all battery cells have 

good balance (repeat for all batteries);

5. Check batteries for number of cycles and discharge per DJI recommendations if required.
Appendix D

UAS Maintenance Log

Monthly 

Maintenance 

Log

UAS #

Issue Date 

(Discovered)

Date Issue 

Addressed

Maintenance 

Description

Maintenance 

performed by (Name 

and Signature)

Software

Airframe

Engines

Propellers

Camera (Gimbal)

Landing Gear

Vibration

Other