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 , 20152 TABLE OF CONTENTS

Page

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

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

INTRODUCTI ON 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 EXEMP TION.................................................................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 TH E 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........................................................................................363 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 Ru les
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing4 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 a n 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 h olds 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 e ngine 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 imager y 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 collaborated5

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 i mage 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, a nd 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 monitori ng 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

Unusua l 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) util izing 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 serv e 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 Registrati on , 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 petition s
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 se t 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 p ersonnel 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). Fur thermore,

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 b y 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 mai ntaining 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 airw orthy 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 Attit udes 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 th e 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 require ments 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 po wer 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 follow ing
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 Exempti on 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 certifi cate 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 P IC 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 l evel 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 , sub section (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 disc repancies 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 (in cluding the airframe) and12 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 o n 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 a re 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 o perator 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) T he 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 retaine d 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 Unus ual 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 op erations 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 main tained 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 to14

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+ UAS s 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+ U ASs 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 op erations 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 requ ires 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 ground15

to zer o 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 witho ut 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 visual16

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 cruis ing 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 for th 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 mainte nance 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 Attitude s 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 s ets, 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, the17

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 ser ve 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+ U ASs 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,

conge stion 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 us ing 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 aer ial video and photography, while burning approximately 20

- 30 gallons per hour of18

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 batte ry
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 mann ed 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 weigh ts 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 add ition 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 Un usual 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 op erated 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 to19

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 stab ility 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

s pending; 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 Aviati on 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+ UA Ss 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 th e 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 comp letion 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 o peration 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 Secr etary 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 D emonstrate 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, s peed,
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 t he 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

a nd 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 Co mmand 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

p hotography 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 we ighing 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 t o 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 r equires 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 text ing 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 doc uments.
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 petit ions 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 inspect ion 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 i ncluded 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 air craft 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.

1 6. 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 medi cal 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 exemp tion, 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 o f 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 f or 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 n ot 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 fro m 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 pre

determined 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 Authorizatio n (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 shal l 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 numb er, 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 us ed 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 PI C 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 avia tion 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, opera tor 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 such26 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 s tructures 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 p ersons 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 w ill 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, incl uding 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 pr ivate 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, Unusual27

Attitudes submits that the additional manned airma nship 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 hou rs 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 tak eoffs 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 dur ing Unusual Attitudes’ proposed operations. The28

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 m odel 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 t he 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

- ho ur 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 complia nce 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

- b uilding 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 Ro botics 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 maneuver s 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, 11 112,

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 maint ained
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 Re quirements 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 3DR30

Robotics X8+ UAS s; (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 specific ations 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 a s 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 p ower. 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 ch aracteristics 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 previous ly 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 Atti tudes 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 operati ng
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 X 8+
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 U AS 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

3 DR 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 est ablished 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 purpo se of conducting aerial video and photography
over certain areas of the United States for compensation or hire. FMRA Section 333 sets33

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 Ad ministrator 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 un usual 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, aircra ft 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 thi s 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 F MRA 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 eq uivalent 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 a reas 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 fo rth 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 Att itudes 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 limite d purpose of conducting aerial video and
photography over certain areas of the United States. By granting this Petition, the FAA35

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

Reform Act of 2012, while also advancin g 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 phot ography 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, 201536 Appendices

Appendix A

 3DR Robotics X8+ Checklist

 3DR Robotics X8+ Operation Manual

Appendix B

 Routine Maintenance Procedures

Appendix C

 Monthly Maintenance LogX8+Operation ManualRead beforeflying!IMPORTANTMeet 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 informationportal at3DR.com/X8/info.Happy flying!ContentsParts2Setup4Assembly4Ground Station5Power Management7Charging8Safety8Controller Battery9Powering the X810Connecting to a Ground Station11Flight Basics12Safety12Operating Limits13Controls14Modes17Return to Launch19Failsafes20Status Indicators22Flight Procedures24Takeoff24Landing26Monitoring27Missions28Planning29Saving30Initiating31Ending31Appendix32Troubleshooting32Maintenance32Specs33Resources342PartsUSB adapterGround Station RadioPropeller wrenchAndroid adapterSF propellers (4)SFP propellers (4)Charger and accessoriesGuard bagPixhawk micro-SD cardadapterRC ControllerBattery KitTool KitPropellersFlight ChecklistFlight batteryRadioFlight ChecklistLEDMotors inactive, safe tohandleLow battery, automatic landingLoss of RC signal, automatic landingPre-arm safety check failureLoss of GPS signal, switch to manualInitializing, hold the X8 levelAcquiring GPS, please waitAutopilot ready, GPS lockedArmedSafety ButtonMotors active, deactivate beforehandling (see reverse)Flight ModesReturn to launch**RTL**land at the launch pointStabalizeAltitude HoldLoiterFull AutonomyReturn to LaunchStandard position(altitude hold mode)**STD**fly manuallyStabalizeAltitude HoldLoiterFull AutonomyReturn to LaunchLoiter mode**LTR**hoverStabalizeAltitude HoldLoiterFull AutonomyReturn to Launch!Stand back!46The motors arenow active.Hold left stick down-right until motors spin.21Power on controller;set to STD and RTL OFF.Armmotors.Press and hold safetybutton until solid red.Connectcharged battery.Choose a clear launchpoint, and face the X8away from you.5CheckLED.3Place the X8 atlaunch point.Go outside toan open area!See the OperationManual for completeinstructions.Auto mode**AUTO**fly a missionStabalizeAltitude HoldLoiterFull AutonomyReturn to Launch©2014 3D Robotics. vA. DCT0005 All rights reserved.Control gimbal**TILT**tilt the camera down and upLand**CH7**land at the current positionStabalizeAltitude HoldLoiterFull AutonomyReturn to LaunchStabalizeAltitude HoldLoiterFull AutonomyReturn to LaunchStabalizeAltitude HoldLoiterFull AutonomyReturn to LaunchX8+Hold the X8 stilland level whilepowering on.3Micro-USB port (not pictured, sideof Pixhawk)X8+Front arms (blue)Rear arms (black)GPS mastPixhawk autopilotSafety buttonStatus LEDAntenna4Setup:AssemblyThe X8 arrives in travel configuration. Completethese steps to prepare the X8 for flight.1 Unfold Arms12Remove 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).12X8 Assembly: Unfold Arms52 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 PropellersThe X8 uses SF and SFP propellers. Labels are found on the individualpropeller packages and on the propellers themselves. The diagrambelow shows which motors require SF or SFP propellers. Accurateassembly of SF and SFP propellers is critical for the X8 to fly correctly.To attach each propeller, remove the nut and washer from the motor,and add the correct type of propellerwith the writing on the propeller facingthe sky. (This is a tight fit; apply pressure and twist the propeller onto themotor.) Replace the washer over the propeller, and use the propellerwrench to tighten the nut on top.12X8 Assembly: Unfold Legstop motor:SFbottom motor:SFPbottom motor:SFtop motor:SFPX8 Propeller Ordertop motor:SFbottom motor:SFPtop motor:SFPbottom motor:SFX8 Propeller Assembly!Ensure that the writing on allpropellers faces the sky.6Ground 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 visit3DR.com/download_softwareto installthe application.WindowsMission PlannerOS XAPM PlannerAndroidDroidPlanner 2Important 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 thecalibrations on theInitial Setupscreen, including the mandatory hardware configurationsand setup wizard, can adversely affect the performance of your aircraft.iOS?There are currently no ground station applications available for iOS.7Power ManagementThe X8 is powered by a rechargeable lithium polymer (LiPo) battery. When fullycharged, the battery provides up to 15 minutes of flight time depending on payload,environmental conditions, and flying style. Flying with a gimbal, GoPro, and FPVsystem can reduce flight time by up to 5 minutes. Flying aggressively or in high windscan affect power consumption and reduce flight time. Monitor power consumptionusing the flight data display on the controller (press and hold theDNbutton).When the battery reaches the low voltage limit, the X8 initiates a low battery failsafeand lands automatically at the current position. (See page 20 for more informationabout failsafes.) To avoid a low battery failsafe, regularly check the controller’s flightdata display to monitor battery voltage, and end your flight before the battery reachesthe low voltage limit.ControllerPress and hold theDNbutton to view flight data.flight battery mAh consumed since armedAnother way to monitor power consumption is by using milliamp-hours (mAh).Monitor the mAh on the controller, and ensure that consumption does notexceed 8,000 mAh (80% of the battery’s available capacity). Exceeding 8,000mAh can render the battery permanently unusable.Do not exceed 8,000 mAh for a fully charged X8+ battery.flight battery levelFull battery:16.8 VLow battery limit:14 VEnd your flight at 14.1 V.!Controller Flight Data Display: Screen 1!8ChargingCharge the battery before your first flight!1Connect the charger to the power adapter cableand plug the adapter cable into a wall outlet.Connect the red cable to the + port and the blackcable to the - port.+–2Set the charger to LiPo and 3A.LiPo3A3Connect the battery’s white connector to thecharger’s 4S port, and join the two yellowconnectors together.4S4Secure the battery inside the guard bag,and charge until the status indicatordisplays green.ChargingCompleteCharger with power cable andsplit-wire charging cableCharger settingsFlight battery charging wiringCharging in process!Flying with a low battery is a safetyrisk and can render the batterypermanently unusable. Always flywith a fully charged battery.Charge the battery using a designatedLiPo balance charger only. Alwaysmonitor the battery while charging.Protect the battery from extremeheat, extreme cold, puncturing, andflammable surfaces. Always transport,charge, and store the battery in theguard bag.Inspect the battery for damage beforeand after flying. If you observe anyswelling of the package or the batteryceases to function, do not use thebattery. Do not dispose of the batteryin the trash; dispose of the battery atlocal battery recycling center. In theUS and Canada, visit call2recycle.orgto find a location.Safety9Controller BatteryThe controller is powered by 8 AA batteries (included). The controller’sflight data display allows you to monitor the voltage of the controller.When fully charged, the controller displays 12 V; when completely outof charge, the controller displays 9 V. Replace the batteries when thecontroller displays 9.1 V.ControllerPress and hold theDNbutton to view flight data.controller battery level (9-12 V)Replace controller batteries at 9.1 V.Controller Flight Data Display: Screen 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 Return to Launch

Stabalize Altitude Hold Loiter Full Autonomy Return to Launch

X8: Connect battery, keep level while initializing Stabalize Altitude Hold Loiter Full Autonomy Return to Launch

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 Dat a 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 icon12Flight Basics:SafetyTo ensure safe and successful flying, always fly in accordancewith 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 instabilityin flight, switch to standard mode and land the X8 manually.The X8 cannot avoid obstacles on its own, including duringmissions. As the operator, it’s your responsibility to recognize andavoid obstructions while flying. Always be ready to regain manualcontrol of the X8 in the event of an unsafe situation.visual lineof sight400 ft(120 m)100 ft (30 m)5 miles (8 km)Always fly at least 100 feet (30 m)away from people, vehicles, andbuildings. Make the safety of peopleand property your first priority!Always fly below 400 ft (120 m) and within yourvisual line of sight. Don’t let the X8 get too faraway from you; make sure you can always see itsorientation. Don’t fly in low light, high winds, rain, orother conditions that might impede visibility.Always fly at least 5 miles (8 km)away from airports and other areaswhere pilots operate manned aircraft.visual lineof sight400 ft(120 m)100 ft (30 m)5 miles (8 km)visual lineof sight400 ft(120 m)100 ft (30 m)5 miles (8 km)Spinning propellers can cause serious injury. The safetybutton indicates the status of the motors to help youprevent hazardous contact with the X8’s high-speedpropellers.•When the X8 is powered on, the safetybutton blinks red, indicating that themotors are inactive and the propellers aresafe to handle.•When you’re ready to fly, press and hold thesafety button until it shows solid red. Thisindicates that the motors are active and thepropellers can spin if armed. To make thepropellers safe to handle again, press andhold the safety button until it blinks red.visual lineof sight400 ft(120 m)100 ft (30 m)5 miles (8 km)visual lineof sight400 ft(120 m)100 ft (30 m)5 miles (8 km)LocationPropellers13Operating LimitsAlways fly within the X8’s operating limits.Maximum altitude*100 m (328 ft)Range*300 m (984 ft) from launch pointGPS lockGPS lock required at all timesMaximum estimated flight time15 minPayload capacity800 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

Throttle15 Flight Tip When adjusting orientation, move the left stick horizontally without changing its vertical position. 

### Activate Hold until propellers start spinning.

T

ake-off + Lif t Raise just slightly for take of f

Hover + Land Lower just slightly to hover

Left Ya w Left Back Forward

Right

Right Ya w

Deactivate Hold until propellers stop spinning Activate Hold until propellers start spinning.

T

ake-off + Lif t Raise just slightly for take of f

Hover + Land Lower just slightly to hover

Left Ya w Left Back Forward

Right

Right Ya w

Deactivate Hold until propellers stop 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 Yaw16 

### Activate Hold until propellers start spinning.

T

ake-off + Lif t Raise just slightly for take of f

Hover + Land Lower just slightly to hover

Left Ya w Left Back Forward

Right

Right Ya w

Deactivate Hold until propellers stop spinning Activate Hold until propellers start spinning.

T

ake-off + Lif t Raise just slightly for take of f

Hover + Land Lower just slightly to hover

Left Ya w Left Back Forward

Right

Right Ya w

Deactivate Hold until propellers stop spinning 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.



### Activate Hold until propellers start spinning.

T

ake-off + Lif t Raise just slightly for take of f

Hover + Land Lower just slightly to hover

Left Ya w Left Back Forward

Right

Right Ya w

Deactivate Hold until propellers stop spinning Activate Hold until propellers start spinning.

T

ake-off + Lif t Raise just slightly for take of f

Hover + Land Lower just slightly to hover

Left Ya w Left Back Forward

Right

Right Ya w

Deactivate Hold until propellers stop spinning 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 Roll17 ! 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 Return to Launch

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. 

## Modes18 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. Stabalize

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

Return to Launch 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

15 meters 1 2

3 hover 5 seconds Stabalize

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

visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 km) 400 ft (120 m)

visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 km) 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. visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 km) 400 ft (120 m) visual line of sight 400 ft (120 m)

100 ft (30 m) 5 miles (8 km) 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 LED23 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 handling24 

## 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. Checklist25 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).26Landing1Press and hold the safety button until itblinks red. The motors are now inactive,and the X8 is safe to handle.2To disarm the motors, hold the left stick down/leftuntil the motors stop.DisarmFor manual landing in standard or loiter mode:Motors inactive, safe to handleMotors active, deactivate beforehandlingController left stick: disarming positionSafety button indicators!Do not handle the propellers or pick up the copter while the safety button isactive (solid red). Remember to disconnect the battery before turning off thecontroller when powering off.If you end your flight using the Ch 7 land command or RTL, the X8 disarmsautomatically; wait for the motors to stop, and proceed to powering off.Attempting to disarm the X8 in either land mode or RTL mode can causethe cause the copter to flip.27MonitoringPress and hold theDNbutton to access the flight data screens.PressDNagain to toggle between screens.current flight modecontroller battery level (9-12 V)GPS signal strength in # of satellitesmeters from launch pointflight battery level (14-16.8 V)connection strengthcurrent latitudecurrent longitudealtitude in metersflight timealtitude in metersGPS statusspeed in m/sflight battery mAhconsumed since armedEnd your flight at 14.1 V.Do not exceed 8000 mAh for afully charged X8+ battery (80% ofavailable capacity).!Monitor the X8 in flight using the controller’s flight data screens.ControllerController Flight Data Display: Screen 1Controller Flight Data Display: Screen 228MissionsThe X8’s Pixhawk autopilot is capable of flying an autonomous missionwithout operator input. Ensure that you feel comfortable operating the X8manually 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 manuallyif it goes outside this area. Be aware of any risks at your location, includingbodies of water, structures, trees, etc. Designate a few areas as safety zoneswhere 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 signalis unobstructed. Radio towers, cell phone towers, and nearby WiFi signalscan 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 themission 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 responsibility to ensure that all missions complywith the X8’s operating limits, including flight time. Don’t forget to take intoaccount the effect of current wind conditions on power consumption.Regaining Manual ControlDuring a mission, keep the controller easily accessible, and be prepared toregain manual control at any time. To regain manual control during themission, switch to standard mode using the controller. If you observeinstability in the X8’s flight behavior or if the copter moves outside yourdesignated safe flying area, switch to RTL. Turning off the controllerautomatically triggers an RTL and can be used in an emergency situationas a hard recall command.FailsafesThe X8’s default failsafe behaviors are optimized for manual flight. Forautonomous missions, we recommend re-configuring the failsafe settingsfor your flying location. For instructions, visit3DR.com/X8/info.29PlanningSelect the DroidPlanner icon, selectEditor. Tap to addwaypoints, or select the brush tool and draw a pathfor the X8 to follow.Select Flight Plan, and click to add waypoints. Select the green arrows atthe bottom of the screen to configure altitude and change waypoint types.To plan a mission, power the X8 and connect to your ground station. Groundstation applications require an Internet connection to access maps.Tablet (DroidPlanner)Laptop (Mission Planner, APM Planner)DroidPlanner: Edit waypointsMission Planner: Flight PlanTakeoff and LandingBoth ground station applications provide the option to configure automatictakeoff and landing into the mission. Missions without automatic takeoff andlanding must be initiated and ended in flight.30SavingSelect the option menu in the top-right corner, andselectSend Mission. This command saves the missionto the X8.On theFlight Planscreen, selectWrite WPsto save the mission to the X8.SelectSave WP Fileto save the mission to your computer for future use.After planning the mission, save the mission to the X8. The Pixhawk autopilotcan store one mission at a time. When you initiate the mission, the X8 startsthe mission stored to the autopilot at the time.Tablet (DroidPlanner)Laptop (Mission Planner, APM Planner)DroidPlanner: Send Mission (option menu)Mission Planner: Flight Plan31InitiatingStabalizeAltitude HoldLoiterFull AutonomyReturn to LaunchStabalizeAltitude HoldLoiterFull AutonomyReturn to LaunchLeft StickFor auto-takeoff, raisethrottle 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 flyabrief 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 standardmode. Then switch to auto mode, and raise thethrottle to initiate the mission.For manual takeoff, initiate the mission in flight byswitching to auto mode.Controller: mode switchController: mode switchController: left stickAutomatic LandingFor missions configured with a landwaypoint, the X8 disarms automaticallyafter landing.Ensure that the throttlestick is set fully down during landing; theX8 cannot disarm automatically unlessthe throttle stick is set fully down.Manual LandingFor missions without a land waypoint,switch to standard or loiter mode in flightthen land manually.Ending!To avoid sudden changesin altitude when switchingfrom auto mode to standardmode, ensure that the leftstick is set to the centerposition.End the mission according to the type oflanding configured in the mission.32Appendix: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 the specific failure, check theheads-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 calibrationGPS Failure:Wait for improved GPS signal or move to a more open area (most common failure)Video 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 areavailable at 3DR.com/X8/info.33SpecsBattery: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 mRange*:300 m from launch point (1 km when geofence disabled)Maximum Estimated Flight Time:15 min*While geofence enabled (default)ResourcesThank you for being a responsible drone operator. For more information about the X8,visit the pages below.Online information portal:3DR.com/X8/infoTerms and Conditions:3DR.com/termsContact 3DR Support at help@3DR.com or call our support line at+1 (858) 225-1414 Monday through Friday, from 8 am to 5 pm PST.Happy flying!3D Robotics1608 4th Street, Suite 410Berkeley, CA 947103DR.comX8+ Operation ManualDCT0004v.C2014 ©3D Robotics

## 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

Return to Launch Standard position (altitude hold mode)
**STD** fly manually

Stabalize Altitude Hold Loiter Full Autonomy Return to Launch

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 down

right until motors spin. 

# 2 1 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 LED. 

# 3 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 Stabalize

Altitude Hold

Loiter

Full Autonomy

Return to Launch ©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

Return to Launch Stabalize Altitude Hold Loiter Full Autonomy Return to Launch

Stabalize Altitude Hold Loiter Full Autonomy Return to Launch



# 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. 

# 4 Power 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 pow ered 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 ti ghtness 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