September 21, 2015

Exemption No. 12945

Regulatory Docket No. FAA−2015-2554

Mr. Michael Bruk, Esq.

The Law Office of Michael Bruk

Counsel for Lappert Smith Technologies LLC

138 West 25th St, 10th Floor, Suite C1001

New York, NY 10001

Dear Mr. Bruk:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the docket July 6, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Lappert Smith Technologies LLC (hereinafter petitioner 

or operator) for an exemption. The petitioner requested to operate an unmanned aircraft 

system (UAS) to conduct aerial imaging and inspection of power infrastructures.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI S800 and DJI Inspire 1.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection.

1

The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Lappert Smith Technologies LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

Conditions and Limitations

In this grant of exemption, Lappert Smith Technologies LLC is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S800 and DJI 

Inspire 1 when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

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

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

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

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
4

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

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

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
5

government. The PIC must also meet the flight review requirements specified in 

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

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

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

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

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

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

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

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

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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 
7

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _____ _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

LAPPERT SMITH TECHNOLOGIES LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 91.9(b), 91.203(a), 91.203(b), 45.23(b), 21.185, 45.27(a), 91.7(a), 91.103, 

91.109(a), 91.119, 91.121, 91.151(a), 91.405(a), 91.407 (a)(1), 91.409 (a)(2), 91.147 (a), 

91.147(b), and 61.113 

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM 

OVER RURAL AREAS OF THE UNITED STATES 

PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012 

MICHAEL BRUK, ESQ. 

THE LAW OFFICE OF MICHAEL BRUK 

138 W. 25TH ST, lOTH FLOOR, SillTE ClOOl 

NEW YORK, NY, 10001 

Tel: (212) 203-9303 

Fax: (347) 710-1791 

Attorney for Petitioner 
Contents 

GLOSSARY OF ABBREVIATIONS ....................................................................................... iii 

I. SUMM"ARY ..................................................................................................................... 1 

II. INTRODUCTION AND INTERESTS OF THE PETITIONER ........................................ 1 

III. BACKGROUND OF THE Dll S800 OCTOCOPTER ...................................................... 2 

IV. BASIS FOR APPROVAL OF LAPPERT SMITH PETITION ......................................... 3 

A Approval is Warranted Based on the UAS's Size, 

Weight, Speed, and Operational Capability ............................................................................. 4 

B. Approval is Warranted Based on the Operational 

Restrictions Set Forth in the Operations Manual .................................................................... 5 

V. THE EXTENT OF RELIEF LAPPERT SMITH SEEKS 

AND THE REASON LAPPERT SMITH SEEKS THE RELIEF ........................................ 7 

VI. DRUG AND ALCOHOL PROGRAM ........................................................................... 18 

VII. REASONS WHY GRANTING LAPPERT SMITH'S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ................................................. 18 

A The Public Will Benefit From Decreased Congestion 

Of The NAS, Reduced Noise and Air Pollution, and 

Safety of Life and Property, and Air Traffic Control's Responsibilities ............................. 18 

B. Aerial Inspections with the Dll S800 Hexacopter UAS will Benefit the Economy ........... 19 

C. No Privacy Issues Exists ........................................................................................................ 19 

VIII. OPERATIONS AND MANUFACTURER'S MANUALS .......................................... 20 

IX. Any Other Conditions The FAA May Prescribe For Safe Operation ............................... 20 

X. A Summary That Can Be Published In The Federal Register ......................................... 21 

XI. CONCLUSION .............................................................................................................. 22 

ii 
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

ATC Air Traffic Control 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

NAS National Airspace System 

Section 333 FAA Modernization and Reform Act of2012, Section 333 

SMS Safety Management System 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VMC Visual Meteorological Conditions 

iii 
I. SUMMARY 

Lappert Smith Technologies LLC, through its counsel and by this petition, seeks 

exemption that would permit Lappert Smith to operate an Unmanned Aircraft System ("UAS") 

over certain rural areas of the United States, while keeping the required regulatory documents 

readily accessible to the pilot in command at the ground control station. This exemption will also 

permit all required markings regarding the operational status of Lappert Smith's UAS to be 

displayed on the fuselage of the unmanned aircraft. 

II. INTRODUCTION AND INTERESTS OF THE PETITIONER 

Lappert Smith Technologies LLC (hereinafter referred to as ("Lappert Smith") seeks the 

requested exemptions to permit it to offer imaging and inspection of various power 

infrastructures to determine whether said lines are in need of repair. In addition, Lappert Smith 

seeks authority to conduct training and maintenance flights in a sterile area free from hazards and 

persons. 

Various utility providers strive to deliver reliable resources to manufacturers, commercial 

enterprises, and residential customers. These utility constantly seek newer, more-efficient, costeffective, and reliable means by which to perform safety checks of their equipment. These 

companies also realize that a portions of the infrastructure in the United States is aging and in 

need of repair or replacement. The Lappert Smith team has developed a remote piloted aerial 

system that safely and efficiently provides customers with low cost, comprehensive aerial 

inspection. 

Lappert Smith acknowledges and appreciates that UAS operations are part of a complex 

and interconnected system that make up the national airspace (NAS). Lappert Smith personnel 

have extensive experience in conducting U AS flights and are conscious of the special safety 

issues that arise from working in this environment. The Lappert Smith Team is comprised as 

follows: 

1. Walter Lappert, Chief Design Engineer. B.S. in Mechanic Engineering and A.A. in 

Unmanned Aircraft Technology; Community College of the Air Force degree in 

1 
Aircraft Armament Systems; 1 0+ years of USAF service, served as Weapons Load 

Team Chief, trained and qualified 51 service personnel on 18 GPS and laser-guided 

munitions system; Military Rank of Staff Sergeant (Disabled Veteran); Active 

SECRET Clearance (Department of Defense); 238 Missions with Objective; 750+ 

hours of UAS operation without objective. NCATT (National Center for Aerospace 

and Transportation Technology) Certified. 

2. Alex Hinkle, Lead Pilot- B.S. in Aviation Management from Kansas State 

University; Pilot's License with Instrument Rating; Class 1 Medical; 178 Missions 

with objective, 250+ hours ofUAS operation without objective 

3. Peter Kalaitzidis, Co-Pilot and Lead Observer- A.A. in Applied Sciences; A.A. in 

Electrical Engineering, Community College of the Air Force degree in Aircraft 

Armament Systems; Military Rank of Staff Sergeant (Disabled Veteran, Retired); 

Class 2 Medical Clearance; 88 Missions with objective, 625+ hours ofUAS operation 

without objective. 

4. Parker Freeman, Co-Pilot/Observer. Private Pilot's License; Class 2 Medical 

Clearance; 2013 AUVSI (Association for Unmanned Vehicle Systems International) 

Safety Award Recipient; 50 UAS missions as PIC totaling 150 single engine PIC 

flight time hours; 120 UAS missions as co-pilot/observer. 

5. Bretten Smith- Chief Operating Officer. B.S. in Applied Science and MBA with 

focus on Program Management, Kansas State University; Led Weapons System and 

Tech Crews in USAF; Military Rank of Staff Sergeant (Disabled Veteran); Active 

SECRET Clearance (Department ofDefense). 

ill. BACKGROUND OF THE DJI SSOO OCTOCOPTER 

2 
Lappert Smith seeks an exemption to operate a Dll S800 hexacopter UAS1

, for compensation 

or hire within the national airspace system ("NAS"). The Dll S800 hexacopter UAS is 

comprised of an amphibious unmanned aircraft and a transportable ground station. The Dll S800 

hexacopter UAS has a maximum gross weight of approximately thirty (30) pounds, a 360 

millimeters (14.173 inches) length of each wing, and base a length of 500 millimeters (19.685 

inches). The Dll S800 hexacopter unmanned aircraft is equipped with 6 propellers driven by a 

Lithium Polymer battery powered electric motor. 

IV. BASIS FOR APPROVAL OF LAPPERT SMITH PETITION 

Petitioner, Lappert Smith, through its undersigned counsel and pursuant to the provisions 

ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform 

Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator for an exemption from the requirements of 14 C.F.R. §§ 91.9(b), 

91.203(a), 91.203(b), 45.23(b). 

In the alternative, and in accordance with Federal Aviation Regulation ("FAR") Section 

21.16, entitled Special Conditions (14 C.F.R. § 21.16), Lappert Smith respectfully requests that 

the Administrator prescribe special conditions for the intended operation of the Lappert Smith 

Dll S800 hexacopter UAS that contain such safety standards as the Administrator finds 

necessary to establish a level of safety equivalent to that established by the restricted category 

airworthiness certification standards specified in 14 C.F.R. § 21.185. Lappert Smith provides the 

following information in support of its petition for exemption: 

N arne And Address Of The Petitioner. 

Lappert Smith Technologies LLC 

1205 S. Tryon St. Unit 1106 

Charlotte, NC 28203 

1 Lappert Smith has reserved registration numbers N 8HJLS, .nn,s, and .326LS and will submit an Aircraft 

Registration Application upon the grant of the exemptions sought by this Petition. 

3 
The point of contact for this Petition and specific contact information is as follows: 

Michael Bruk, Esq. 

The Law Office of Michael Bruk 

138 W. 25th St, lOth Floor, Suite ClOOl 

New York, NY, 10001 

Tel: (212) 203-9303 

Fax: (347) 710-1791 

Email: mb@bruklaw.com 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

Lappert Smith will employ the Dll S800 hexacopter for infrastructure inspection 

operations, with a maximum take-off weight of 3 0 pounds, and whose flight speed will not 

exceed 30 miles per hour. In addition, no UAS will be flown in controlled airspace absent written 

consent of a local regulatory agency or office, nor at an altitude that exceeds 400 feet AGL, and 

in such a way that operations can be safely terminated with a reserve battery power of 30% 

maximum charge. The Dll S800 does not carry any flammable propellant or fuel and possesses 

redundant motor capabilities. In addition, the UAS can maintain flight in the event one or more 

motors fail unexpectedly, and is capable of compensating for engine loss automatically. The Dll 

S800 also possesses the ability to alert the PIC to the possibility of a lost link before it occurs. In 

the event a control link is unexpectedly lost, the UAS is equipped with failsafe setting which 

returns the vehicle to a pre-determined, emergency alternate landing zone. 

In the absence of UAS operations, and particularly in rural areas, many of these 

inspections would have to be carried out by a helicopter or by technicians performing the 

4 
inspection manually. Helicopter inspections are carried out at high speed, and carry a greater risk 

of a wire strike or other collision than do UAS operations. Moreover, conducting helicopter 

inspections at certain locations, such as substations where several utility lines converge, carry 

additional risks to helicopters. Finally, due to the low altitude of utility line inspection flights, the 

ability of a helicopter pilot to successfully conduct an autorotation in the event of an engine 

failure may be limited or impossible. Given the small size of the selected UAS and the restricted 

environment within which it will operate, this petition for exemption falls within the equivalent 

level of safety which Congress directed the FAA to permit commercial UAS operations by 

exemption pending completion of formal rulemaking. 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manual 

The Lappert Smith Operations Manual, along with the Dll manufacturer's manual, 

contain all of the procedures and limitations necessary to successfully and safely perform 

inspections of infrastructure. Below is a summary of operational limitations and conditions 

which will ensure an equivalent or higher level of safety for operations conducted under current 

regulatory guidelines: 

1. The UAS will weigh 30 pounds or less. 

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

3. Maximum total flight time for each operational flight will be limited to the lesser of 25 to 

30 minutes or the amount of time the UAS can be flown and still maintain a reserve 

battery power of no less than 30%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL and will not be 

conducted within navigable airspace. 

5. Flights will be operated at a lateral distance of least 500 feet from any inhabited 

structures, buildings, vehicles or vessels, or from people not associated with the operation 

who have not given permission in advance of the operation. 

5 
6. Minimum crew for each operation will consist of the UAS Pilot, one or more Visual 

Observers as necessary to safely conduct the mission, and a Sensor Operator if required, 

all of whom possess class 2 Medical 

7. The Pilot will have a private pilot's license, be instrument rated, and have completed 64 

hours of training and instruction on the Dll 800 prior to any flight in accordance the 

Operations Manual, will have conducted at least three (3) take-offs and three (3) landings 

90 days immediately preceding the date of any proposed commercial operation. 

8. The UAS will operate in accordance with the safety and operational requirements ofthe 

Operations Manual. 

9. Prior to the operation, a Mission Plan will be created setting forth the limitations for the 

flight as well as contact and hazard information provided by the utility. 

10. A NOT AM will be issued not more than seventy-two (72) hours in advance of flight, but 

not less than twelve (12) hours before flight. 

11. Pilot, Visual Observer and Sensor Operator will at all times be able to communicate by 

vmce. 

12. Prior to any flights, a Certificate of Authorization will be obtained specifying the 

geographic over which operations will be conducted. 

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

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

agencies. 

14. The operator will coordinate all flights with the appropriate Flight Standards District 

Office. 

15. If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the operational area and land. 

16. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer. 

17. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

18. The Dll S800 UAS shall be operated pursuant to Day Visual Flight Rules (VFR) in 

visual meteorological conditions (VMC). The Dll S800 UAS shall be operated only 

during daylight hours (i.e. between the end of morning civil twilight and the beginning of 

6 
evening civil twilight, as published in the American Air Almanac, converted to local 

time). 

19. The Dll S800 UAS shall operate from on-site takeoff/landing locations directly next to 

the pilot in command and co-located safety observer. If the operation is from a watercraft, 

the pilot in command and safety observer shall remain co-located on the same watercraft. 

20. Operation ofthe Dll S800 UAS with any inoperative instruments or equipment shall be 

prohibited. 

21. The Dll S800 UAS shall be maintained m accordance with the Manufacturer's 

Maintenance Manual. 

22. The Dll S800 UAS shall be operated pursuant to 14 C.F.R. Part 91, operating 

requirements. 

23. For the proposed flight operation, only one Dll S800 UAS shall be airborne at any given 

time. 

24. Prior to flight operations, Lappert Smith shall coordinate and establish two way 

communications with the nearest Air Traffic Control facility. 

25. For any flight operations over U.S. Government or state managed lands, Lappert Smith 

shall coordinate with the appropriate authority and ensure that the property owners have 

at least twelve (12) hours of advance notice prior to the proposed flight operations. 

Coordination shall include anticipated periods of operation, purpose of the flights, and 

contact information for the operator should questions or issues arise. 

V. THE EXTENT OF RELIEF LAPPERT SMITH SEEKS AND THE REASON 

LAPPERT SMITH SEEKS THE RELIEF. 

A. ReliefFrom Section 91.9(b). 

Lappert Smith seeks an exemption from 14 C.F.R § 91.9(b). Section 91.9, Civil aircraft 

flight manual, marking, and placard requirements, of which subsection (b) states: 

(b) No person may operate a U.S.-registered civil aircraft (1) for which an Airplane or 

Rotorcraft Flight Manual is required by§ 21.5 ofthis chapter unless there is available in the 

7 
aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for 

in§ 121.141(b); and (2) For which an Airplane or Rotorcraft Flight Manual is not required 

by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane 

or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof 

Equivalent Level of Compliance 

The Dll S800 hexacopter UAS is unmanned and has a maximum gross weight of 

approximately thirty (30) pounds. Therefore, it is unable to carry Airplane Flight Manuals 

onboard. Lappert Smith proposes the following conditions and limitations to its request for 

exemption from Section 91.9(b): 

The approved Airplane Flight Manual shall be kept at the ground control station, 

immediately available for reference by the PIC, or inspection by any FAA, DOD, or other 

law enforcement official, any time during operation of the U AS. In addition, the Flight 

Manual shall be made available within 10 days to any law enforcement official upon request. 

B. Relief From Section 91.203(a) and (b). 

Lappert Smith seeks an exemption from 14 C.F.R § 91.203(a) and (b). Section 91.203 

entitled Civil aircraft: Certifications required, subsections (a) and (b) state the following: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it 

the following: 

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, a 

copy of the applicable operations specifications issued under § 21.197(c) of this 

chapter, appropriate sections ofthe air carrier manual required by parts 121 and 135 

of this chapter containing that portion of the operations specifications issued under § 

8 
21.197 (c), or an authorization under § 91.611) must have on it the registration 

number assigned to the aircraft under part 47 of this chapter. However, the 

airworthiness certificate need not have on it an assigned special identification 

number before 10 days after that number is first affixed to the aircraft. A revised 

airworthiness certificate having on it an assigned special identification number, that 

has been affixed to an aircraft, may only be obtained upon application to an FAA 

Flight Standards district office. 

(2) An effective U.S. registration certificate issued to its owner or, for operation within 

the United States, the second copy of the Aircraft registration Application as provided for 

in§ 47.31(c), or a registration certification issued under the laws of a foreign country. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 

Equivalent Level of Compliance 

The Dll S800 hexacopter is unmanned, has no cabin, cockpit, pilot station, or other 

entrances. The aircrew is located at the ground control station and no passengers are carried at 

any time. Lappert Smith proposes the following conditions and limitations to its request for 

exemption from Sections 91.203(a) and (b): 

The documents required by §§ 91.203(a) and (b) shall be kept at the ground control 

station, immediately available for reference by the PIC, or inspection by any FAA, DOD, 

or other law enforcement official, any time during operation of the UAS. In addition, 

these documents shall be made available within 10 days to any law enforcement official 

upon request. 

9 
C. ReliefFrom 14 C.F.R. § 45.23(b). 

Lappert Smith seeks an exemption from 14 C.F.R § 45.23(b). Section 45.23 entitled 

Display of marks; general, subsection (b), states the following: 

(b) When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

Equivalent Level of Compliance 

As the DJI S800 hexacopter UAS is unmanned, it has no cabin, cockpit, pilot station, or 

entrances thereto. Therefore, Lappert Smith proposes that, the FAA N numbers be prominently 

displayed on DJI 800 be displayed prominently displayed on the fuselage with markings that are 

as large as practicable., on both sides of the DJI S800 hexacopter UAS. 

D. Relief From 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R 

§91.203(a)(1) 

Lappert Smith respectfully requests the FAA finds, under the Reform Act, that the DJI S800 

UAS provides a level of safety equivalent to that of aircraft normally used for the same 

application. If such a finding is made, no exemption is needed. If, however, the FAA determines 

that there any characteristics of the U AS fail to meet the requirements of the Reform Act, an 

exemption is requested. 

Equivalent Level of Compliance 

The DJI S800 UAS will operate safely taking into account its size, weight, speed, and 

operational capability. The UAS has a maximum take-offweight of30 pounds, will be flown at 

less than 30 miles per hour and completely outside controlled airspace. 

10 
Utility line inspections are currently performed by helicopters, which weigh thousands of 

pounds, carry large loads of fuel, and do not possess the ability to compensate for unexpected 

engine failure. Taken together with the low altitudes needed to conduct these inspections, 

helicopters cannot conduct operations as safely as a UAS. In addition, damage to critical 

infrastructure resulting from a helicopters coming into contact with a utility line or substation is 

far greater than if that of a small UAS. Thus, a UAS operated in a restricted environment, within 

line-of-sight of the PIC, and under the conditions proposed, will be at least as safe as a 

conventional rotorcraft operating. 

E. Relief From 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

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

normal category rotorcraft. To the extent the Petitioner's UAS would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards 

for the same reasons identified in the exemption request from 14 C.F.R. Part 21, Subpart H. 

F. Relief From 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

Petitioner Lappert Smith seeks an exemption from the aircraft marking and identification 

requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). • 14 C.P.R.§ 91.9(c), 

Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may 

operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 

of this chapter. 

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: When marks include only the 

Roman capital letter "N" and the registration number is displayed on limited, restricted or 

light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport, "experimental," or "provisional," as applicable. • 14 

11 
C.P.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that 

rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by§ 45.23. 

Equivalent Level of Safety 

As the Dll 800 is a hexacopter with an unconventional shape, Lappert Smith will apply for a 

Letter of Alternative Marking to allow the registered N-number to be prominently displayed on 

the fuselage with markings that are as large as practicable. 

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

C.F.R § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by§ 21.5 

ofthis chapter, unless there is available in the aircraft a current approved airplane or 

Rotorcraft Flight Manual, approved manual material, markings and placards, or any 

combination thereof Pursuant to 14 C.F.R. § 91.203(a) and (b):(a) Except as provided 

in§ 91.715, no person may operate a civil aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness certificate. 

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued under § 

91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

Equivalent Level of Compliance 

Lappert Smith does not request an exemption from this section but instead notifies the 

FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the 

12 
UAS flight manual, registration certificate and other documentation will be kept at the control 

station with the PIC during flight. The Chief Counsel's Office has held that for all UAS 

operations, this alternate method constitutes full compliance with the regulations. 

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

Petitioner seeks an exemption from 14 C.P.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

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

Accordingly, Petitioner request that the requirements for Section 91.7 are treated in accordance 

with Section V(A), supra. 

I. Relief From 14 C.F.R. § 91.103: Preflight Action 

Petitioner seeks an exemption from 14 C.F .R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight manual is required. 

Equivalent Level of Compliance 

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

Manual and flight manual provided by the manufacturer. The PIC will take all required preflight 

actions- including performing all required checklists and reviewing weather, flight battery 

requirements, landing and takeoff distance, aircraft performance data, and contingency landing 

areas - before initiation of flight. The Aircraft Operations Manual and manufacturer's flight 

manual will be kept at the ground station with the operator at all times. 

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

13 
Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 

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

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. 

Equivalent Level of Compliance 

Given the size and speed of the U AS, an equivalent level of safe training can still be 

performed without dual controls because no pilot or passengers are aboard the UAS, and all 

persons will be a safe distance away in the event that the UAS experiences any difficulties during 

flight instruction. In addition, Petitioner has established a flight training program that will be 

administered by a certified flight instructor. That training program includes both classroom 

instruction as well as supervised flight training employing the same aircraft that will be used 

operationally to conduct power infrastructure inspections. Accordingly, Lappert Smith's 

proposed method of operation provides superior levels of safety. 

K. Relief From 14 C.F.R. § 91.119: Minimum Safe Altitudes 

Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may 

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C .F .R. § 91.119( c). Section 91.119( d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

Equivalent Level of Compliance 

14 
Compared to flight operations with rotorcraft weighing far more than the maximum U AS 

weight proposed herein, and given the lack of flammable fuel, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, and speed of the UAS, as well as the 

location where it is operated. In order to avoid any risk to aircraft, flight operations will be 

restricted to 400' AGL or below. As set forth in the Manual, the U AS will be operated in a 

restricted area, away from persons or structures not involved in the operation. 

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

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

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required to 

the extent that the UAS does not have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Compliance 

The FAA has stated that an equivalent level of safety can be achieved if the U AS will be 

operated at 400' or below and within visual line-of-sight in addition to GPS based altitude 

information relayed in real time to the operator. As the attached Operations Manual indicates, the 

chosen U AS meets these requirements, and a zero altitude initiation point will be obtained prior 

to flight. 

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

Conditions 

Petitioner requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight 

in VFR conditions. Section 91.151 states: 

15 
(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed 

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

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

Equivalent Level of Compliance 

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

flight operations can be conducted while still maintaining a 30 minute reserve. The FAA has 

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

25% reserve battery power still available. Lappert Smith proposes that all flights comply with 

this requirement by mandating that the aircraft be safely landed with no less than 30% of battery 

life remaining. 

N. Relief From 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

Petitioner seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections . . . have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS will not have. 

Equivalent Level of Compliance 

16 
An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the UAS Manufacturer's Manual, as referenced in the 

Operations Manual. As provided in the Operat ons Manual, flights will not be conducted unless a 

flight operations checklist is performed that includes all of the aircraft's components. The 

Operations Manual also sets requirements for maintenance log books and record keeping as well 

as routine and post-flight maintenance. The Manual sets requirements for both annual 

maintenance and preventative maintenance based on hours of flight. 

0. Relief From 14 CFR § 61.113: Private Pilot Privileges And Limitations 

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate 

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

medical certificate. The purpose of Part 61 is to ensure the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot carries passengers or cargo for hire. In this case, while the UAS will be operated as 

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

Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique 

characteristics ofUAS operation outside of controlled airspace did not warrant the addition cost 

and restrictions attendant with requiring a PIC to have a commercial pilot certificate and class II 

medical certificate. 

Equivalent Level of Compliance . 

Regardless, Lappert Smith will employ only licensed private pilots as PIC for their 

operation. The restrictions Lappert Smith has placed on its U AS operations meet or exceed the 

restrictions similarly imposed on Astraeus Aerial in FAA Docket No. F AA-2014-0352. Lappert 

Smith will operate in a sterile area way from persons and property not involved in the inspection. 

It will be flown based on VLOS and below 400' AGL. A NOT AM will be issued between 12 

and 72 hours before the flight is to occur, and the flight will be coordinated with the applicable 

FSDO. 

17 
VI. DRUG AND ALCOHOL PROGRAM 

Lappert Smith is committed to a drug-free work place and the right ofthe flying public it 

serves to safe and efficient air transportation. All employees of Lappert Smith who perform 

safety sensitive and/or security related functions are prohibited from performing work if they 

have alcohol or a prohibited drug in their system. 

VII. REASONS WHY GRANTING LAPPERT SMITH'S REQUEST WOULD BE 

IN THE PUBLIC INTEREST 

Lappert Smith submits this Petition to provide safe, efficient, and economical aerial 

inspection and research throughout rural areas of the United States, in support of government 

entities, agriculture, scientific studies, wildlife monitoring, forestry, the oil and gas industries, 

and other utilities and commercial operations that require aerial inspection. The specific 

operations that Lappert Smith will perform with the Dll S800 hexacopter UAS demonstrate how 

the requested exemption will directly benefit these industries, as well as the public. 

A. The Public Will Benefit From Decreased Congestion Of The NAS, Reduced Noise 

and Air Pollution, and Safety of Life and Property, and Air Traffic Control's 

Responsibilities 

Compared to the cabin class, six-cylinder internal combustion twin engine aircraft that 

that use 20-30 gallons per hour of leaded aviation fuel, the Dll S800 hexacopter UAS uses 

battery power and an electric motors, which produce no air pollution, thereby reducing the 

carbon footprint of aerial inspections and eliminating noise pollution. The Dll S800 motor is 

barely audible during take-off, and cannot be heard when operating more than 100 feet above 

ground level. The Dll S800 hexacopter UAS is a safe, efficient, and economical alternative to 

the manned aircraft traditionally utilized to obtain aerial imagery. 

18 
The Dll S800 hexacopter UAS, which weighs approximately thirty (30) pounds at its 

maximum gross weight, a 360 millimeter (14.173 inch) length of each wing, and base a length of 

500 millimeters (19.685 inches) and has no fuel on board. Thus, the potential for collateral 

damage to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct aerial inspection will be substantially reduced or completely eliminated. 

An exemption allowing the use of a Dll S800 hexacopter UAS would decrease NAS 

congestion and provide a substantial benefit to the public in the form of reduced quantity and 

size of manned aircraft, reduce noise and air pollution, increase the safety of life and property in 

the air and on the ground, and reduce air traffic control's responsibilities regarding ground, 

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

B. Aerial Inspections with the DJI SSOO Hexacopter UAS will Benefit the Economy 

With the rising cost of aviation fuel and the EPA actions phasing out leaded fuels, U.S. 

companies are searching for alternative technology to remain competitive. The Dll S800 

hexacopter UAS is an economically sound alternative to manned aircraft and will allow U.S.-

based companies to remain competitive, provide greater job stability to employees and 

contractors, and ultimately contribute to the growth of the U.S. economy. 

Improved financial performance ofU.S. companies, through commercial use ofthe Dll 

S800 hexacopter UAS, provides a stable workforce that increases consumer spending, thereby 

increasing tax revenues for local, state, and federal governments, 

C. No Privacy Issues Exists 

The Dll S800 hexacopter UAS will operate only in rural areas, and in accordance with 

all Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 

91.119. In addition, the Dll S800 hexacopter UAS will not be operated closer than 500 feet to 

any third-person, vessel, vehicle, or structure, except when necessary for takeoff or landing. 

19 
VIII. OPERATIONS AND MANUFACTURER'S MANUALS 

A copy of the Lappert Smith's Operations Manual and Dll' s Manufacturers Manual, 

which are proprietary information, are attached hereto as Exhibits A and B, Petitioner requests, 

pursuant to 14 C.F.R. § 11.35(b), that all Exhibits attached to petition be held in a separate file as 

they are proprietary information, and in accordance with 14 C.F.R. 11.35(b), are not to be 

included in the Federal Docket Management System (FDMS). 

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

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

14 C .F .R. § 21.16 entitled Special Conditions, Lappert Smith requests that the FAA prescribe 

special conditions for the intended operation of the Dll S800 UAS, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by Section 21.185, and which will permit safe operation of the Dll S800 UAS for the 

special purpose of conducting aerial inspection over rural areas of the United States. Section 333 

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

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

authority for such U AS to operate without airworthiness certification in accordance with any 

requirements that must be established for the safe operation of the aircraft systems in the NAS. 

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

§ 21.16, for operation ofthe Dll S800 UAS, since the airworthiness regulations of 14 C.F.R. Part 

21 do not contain adequate or appropriate safety standards, due to the novel or unusual design 

features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

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

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

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

he prescribes special conditions and amendments thereto for the product. The special 

20 
conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations." 

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

special conditions for Lappert Smith's intended operation of the DJI S800 UAS, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by Section 21.185, and which will permit safe operation of the DJI 

S800 UAS for the special purpose of conducting aerial inspection over rural areas of the United 

States. 

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

From Which Lappert Smith Seeks Exemption: 

Lappert Smith Technologies LLC seeks exemption from the requirements of 14 C.P.R.§§ 91.9(b), 

91.203(a), 91.203(b), 45.23(b), 21.185, 45.27(a), 91. 7(a), 91.103, 91.109(a), 9J.Jl9, 91.121, 

91.151(a), 91.405(a), 91.407 (a)(J), 91.409 (a)(2), 91.147 (a), 91.147(b), and 61.113 

A Brief Description Of The Nature Of The Exemption Lappert Smith Seeks: 

This exemption will permit Lappert Smith to operate an Unmanned Aircraft System over certain 

rural areas of the United States, while keeping the documents required by the regulations at the 

ground control station and immediately accessible to the pilot in command Furthermore, the 

exemption will relieve Lappert Smith from the airworthiness certificate standards and the 

requirement to have a certificate of airworthiness for its Unmanned Aircraft System. This 

exemption will also permit any required markings concerning the operational status of the UAS 

to be displayed on the fuselage of the unmanned aircraft. 

21 
XI. CONCLUSION 

As set forth above, Lappert Smith seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe 

operation of the Dll S800 UAS commercially, for the special purpose of conducting aerial 

inspections over certain rural areas in the United States. By granting this Petition, the FAA 

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

Reform Act of2012, while also advancing the interests ofthe public, by allowing Lappert Smith 

to safely, efficiently, and economically operate the Dll S800 UAS commercially within the 

NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Lappert Smith respectfully requests that 

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

91.9(b), 91.203(a), 91.203(b), 45.23(b), 21.185, 45.27(a), 91.7(a), 91.103, 91.109(a), 91.119, 

91.121, 91.151(a), 91.405(a), 91.407 (a)(l ), 91.409 (a)(2), 91.147 (a), 91.147(b ), and 61.113 

Dated: New York, New York 

June 5, 2015 

Respectfully submitted, 

22 

Michael Bruk, Esq. 

Attorney for Petitioner, 

Lappert Smith Technologies LLC 

The Law Office ofMichael Bruk 

138 W. 25th St, lOth Floor, Suite ClOOl 

New York, NY, 10001 

Tel: (212) 203-9303 

Fax: (347) 710-1791 

Email: mb@bruklaw.com 
Spreading Wings S800 

User Manual 

v 1.7 

2012.12.24 Revision 
©2012 OJ! Innovations. All Rights Reserved. 1 

www.d ji-in novations.com 
©2012 OJ! innovations. All Rights Reserved. 2 

Disc I a i me rRead this disclaimer carefully before using Spreading Wings S800. By using this product, 

you hereby agree to this disclaimer and signify that you have read them fully. Spreading Wings S800 is an excellent 

multi-rotor. With a good autopilot, it will offer tremendous flight features. Despite the controller of DJI autopilot operate 

in the safest manner when the main power battery is connected, we strongly recommend customers to remove all 

frame arms, and keep children away during system calibration and parameter setup. 

As DJIInnovations has no control over use, setup, final assembly, modification (including use of non-specified DJI 

parts i.e. motors, ESCs, propellers, etc.) or misuse, no liability shall be assumed nor accepted for any resulting 

damage or injury. By the act of use, setup or assembly, the user accepts all resulting liability. 

DJIInnovations assumes no liability for damage(s) or injuries incurred directly or indirectly from this product usage. 

DJI Spreading Wings is registered trademark of DJI Innovations. Names of product, brand, etc., appearing in this 

manual are trademarks or registered trademarks of their respective owner companies. This product and manual are 

copyrighted by DJI Innovations with all rights reserved. No part of this product or manual shall be reproduced in any 

form without the prior written consent or authorization of DJIInnovations. No patent liability is assumed with respect to 

the use of the product or information contained herein. 
©201 2 OJ I Innovations. All Rights Reserved. 3 

5800 ProfileoJI Spreading Wngs ssoo is a multi-rotor designed for AP. It simplifies users' 

installation and enables quick disassembling. Frame arm integrates with ESC and motor. Wth DJI VVKM autopilot 

system, it can achieve hovering, cruising and other flight elements. S800 can be applied for aerial photography and 

other aero-modeling activities. 

mm(t.enghth) 

©2012 DJIInnovations. All Rights Reserved. 4 

ContentSoisdaimer 2 

S800 Profile 3 

Contents 4 

Product Usage Cautions 5 

In Box 6 

Tools Needed 6 

Center Frame Wiring 7 

Mount Center Frame 8 

Mount Frame Arms 9 

Mount Bi-pod 11 

Assembly 13 

ESC Sound 14 

Specifications 14 

Appendix 16 

Mount Battery Bracket 16 

Trouble Shooting 17 

Spare Parts Listing 18 
©2012 OJ! Innovations. All Rights Reserved. 5 

product Usage Cautio nSWhen flying, the fast rotating propellers of 5800 may 

cause serious damage(s) and injuries. Therefore, please fly with a high safety in mind at all time. 

Mount Attention 

Mount GPS with a bracket, to avoid interference from the power board of center frame. 

For IMU position, make sure the arrow direction marking is pointing to the aircraft nose. 

The receiver is recommended strongly to be installed under the bottom board of center frame, and the 

head of antenna is downward without any obstacle. The aircraft will be out of control, since the 

wireless signal may be lost by the obstacle. 

Mount the arms correctly. 

e .. e 

®.... ® 

Center frame ArmCenter frame Arm 

For removing screws in the bottom board, please proceed with cautious, avoiding damages. Do not 

remove any other screws fixed with glue. 

Notice matching the indications is very important, please pay attention to them. 

Flight Attention 

With DJI WKM autopilot system, make sure the output signal of WKM F1-F2 and M1-M6 are all normal, 

to avoid serious damage(s) and injuries. 

Keep flying multi-rotor a distance from people, building, high-voltage lines, etc. 

Make sure to use 6S LiPo power battery. 

Do not get close to or touch the working motors and propellers, which will cause serious injury. 

Do not over load the multi-rotor. 

Make sure the propellers and the motors are installed correctly and firmly before flying. 

Make sure all parts of 5800 are in good condition before each flight Do not fly with wore or broken 

parts. 

Strongly recommend you use DJI parts as much as possible. 

Others 

If you have any problem you cannot solve, please contact agents or DJI customer service. 
©2012 OJ! Innovations. All Rights Reserved. 6 

In Box 

Center Frame 800CFx1 Frame Ann 800FAx6 

I 

I 

H Frame SOOHF x1 T Frame 800TFx2,Aiuminum Ring 800ARx2 

Base Pipe 800BPx2 Bi-pod Drawbar 800BDx4 

Silicone Rubber Damper 800SRDx4 Nonslip Damper 800NDx4 

I 

I 

3-PIN Servo Cable SOOSC x1 Screw Package SOOSP x1 

Hexagonal screws: M3x8_ M2.5x5 

Hexagonal socket head cap screws: HC-M3.0x22 .. HC-M2.5x5 HC-M2.5x8 HC-M3x8. T2x9 

Adhesive Velcro SOOAV x1, Battery Band SOOBB x2 

Tools Needed 

2.0mm Hex Wrench, 2.5mm Hex Wrench For mounting screws. 

Screw Glue For fastening screws. 

Nylon Cable Tie 

Scissors For binding devices and wires. 

Diagonal Cutting Pliers 

Foam Double Sided Adhesive Tape For fixing receiver, controller and other modules. 
©2012 DJIInnovations. All Rights Reserved. 7 

Center Frame Wi ri ngTop board is power distribution board, and the bottom board is for 

loading autopilot system components. 

------- Bottom Boan 

---- ___ cSlot 

Top Board 

lMU mount position 

Notices: 

For IMU position, make sure the arrow irection marking is pointing to the aircraft nose. 

Tap Board Maar number 

Connect the motor 3-pin connector (M1-M6) from VvKM M.C. to ESC signal socket (M1-M6) on 

C signal outlet 

center frame markings accordingly. 

(VvKM M.C. M1 

Botto 

ESC signal scket M1, 

Slot 

, VvKM M.C. M6 

To imbal 

ESC signal socket M6) 

Mak 

Tips: Main battery 

power leads, gimbal and 

PMU leads are on the 

bottom surface of the 
top board. XT60 Male 

Markings and stand for the propeller rotation direction. means clock-wise, and means 

counter clock-wise.lf you need other lead connector, please cut the original connector and solder on the new 

connector. (But not Recommend) 
©2012 DJIInnovations. All Rights Reserved. 

Mount Center Frame 

Remove Screws Fix Screws 

~OOCF 

M2.5X5 

Step1: Mount IMU module into IMU position in the center frame. Ensure IMU casing is out of touch the top board 

edge, as vibration can cause IMU mal-function. 

8 

Step2: Please mount DJI Autopilot System parts onto the bottom board (not including GPS modules). Please remove 

all the screws from the bottom board first if necessary. 

Step3: Connect Autopilot System and receiver. Please refer to OJI WKM User Manual for details. Step4: 

Please mount the screws to bottom board, and use adequate screw glue. 

StepS: Mount the GPS on the top board with a bracket. 

Step6: Configure Autopilot System. Please refer to DJI WKM User Manual. 

Notices: 

Tips: 

Make sure to mount the IMU module at the IMU position first. 

Mount the GPS with a bracket, to avoid interference from center frame power board. 

Ensure the USB port of the M.C. outwards for easy access. 

Please wire neatly. Make sure wires will not be cut by the edge of frames. 

Install screws with appropriate strength to prevent damage threads. 
©2012 OJ! Innovations. All Rights Resetved. 

Mount Frame Arms 

Step 1 

over ~---.!i 

ilotor---1<+"""'~ 

sc----".,:'""~~ 

.ED------

Red 

Green 

Step1: Check arms. 

Copper contacts 

Motor rotation direction 

Clock-wfse 

Coul\1er clock-wrse 

Step 2 

Step 5 

(1) Make sure copper contacts are in good condition without bend or severe wear. n 

(2) Make sure propellers are without crack, and screws in propeller cover tight 

(3) Make sure motors are mounted firmly, and rotate freely. 

9 

(4) Distinguish LED indicator on the ESC bottom. Wth a red point in is red LED, others are green LED. We 

recommend you mount arms with red LED to M1 and M2. 

(5) Distinguish marks and on the arms. 

Arm Center frame 

Arm Center frame 

Step2: Insert frame arm into center frame vertically. x1800FA 

Step3: Slowly rotate the frame arm upward until positioned completely. 

Step4: Press down the buckle to lock the arm. Make sure the arm does not move. 

StepS: Make sure the buckle is pressed down correctly, about 35° under normal circumstances. 
Notices: • Please add some lubricant at the position (1) if it is hard to press down the buckle. 
• Slowly rotate the frame arm to prevent from breaking the copper contacts. 

Please refer to {2) to ensure the arm is perfectly positioned. 

Make sure use appropriate strength to press down the buckle correctly. 

Do not hot plug arms. 

If the motor mount loosens, please tighten it by following the procedures in trouble shooting of Appendix. 

Tips: 

LED is on after motor start. 

Examination 

©20'12 OJ! Innovations. Ali Rights Reserved. 

Arms( D®are aircraft nose direction, arms®® are aircraft tail. See from top, motors on 

arms(D®® rotate counter dockwise; motors on arms®®® rotate clockwise. 

t6) 

10 
I' 

Mount Bi-pod 

Step1 

SOOHF 

tiOIJIID 

SOitAA 

HC-M2.5XS 

I MZ.SD 

HC..M3.ox22 

Step3 

Xl 

X4 

X2 

X8 

x4 

x2 

Step2 (Fix, but not tighten screws) 

800TF 

800BP 

800SRD 

80DND 

©2012 OJ! Innovations. All Rights Reserved. 

Step1: Mount T frame BOOTF and base pipe 800BP. 

···+ 

(1) Put nonslip damper 800ND through the base pipe. 

(1) Put the base pipe into T frame until the head of nonslip damper is embedded into T frame. 

(2) Embed the other nonslip damper into the T frame. 

(2) Put silicon rubber damper 800SRD onto both sides of the base pipe. 

Step2: Mount H frame800HF and bi-pod drawbars 80080. 

11 

(1) Fix (but not tighten) hexagonal socket head cap screws~ (Fig. {D) to H frame and bi-pod drawbar 

(Fig. (D). 
(2) Adjust drawbar and T frame, and fix (but not tighten) hexagonal socket head cap screw~ 

(Fig.@) to drawbar and aluminum ring 800AR. 
©2012 OJ I Innovations. All Rights Reserved. 12 

StepJ: Mount H frame and T frame. 

(1) Insert T frame through aluminum ring until it plugs into H frame. 

(2) Fix T frame notch into H frame bulges outwards, make sure T frame will not move. 

(3) Put the bi-pod on the flat floor to adjust H frame and T frame. 

(4) Tighten all hexagonal socket head cap screws (including and@). 

Notices: 

Put bi-pod on the flat floor to finish mounting smoothly and correctly. 

Please mount the screws and use adequate screw glue. 

Separate the bi-pod by disconnecting the H frame to make for easy carriage. 

Completed 

Quick Disassembly 
©2012 OJ! Innovations. ,l\11 Rights Reserved. 13 

Assembly 

Assembly 

Step1: Align all knobs on the H frame to the marks; refer to fig (1). 

Step2: Ue frame and bi-pod horizontally, insert knobs into arms@ and® first, and then adjust to insert others into 

the arms. 

Step3: Rotate the knob to the end, as fig (2) shown. 

Notices: 

@ 

® . Ensure all knobs on the H frame aligned to the marks, and they would go through the arms successfully . 

Tips: 

() . It is convenient for you to carry S800 by quick disassembly (Frame, Bi-pod, Frame and Bi-pod) . 
©2012 OJ I Innovations. All Rights Reserved. 

ESC Sound 

ESC State 

Ready 

Throttle stick is not at bottom 

Input signal abnormal 

Input voltage abnormal 

Tips: 

Sound 

/1234567 

888888 ... 

8 8 B ... 

88-88-88-88 ... 

14 

DJI ESCs are specially designed for multi-rotors. \Mien use with DJI autopilot systems, you do not have to setup 

any parameters or calibrate travel range. 

Specifications 

Frame 

Diagonal Wheelbase 

Frame Arm Length 

Frame Arm Weight 

(Including Motor, ESC, Propeller) 

Center Frame Diameter 

Center Frame Weight 

Bi-pod Size 

Bi-pod Weight 

Total Weight 

Motor 

Stator Size 

KV 

Max Power 

Weight 

ESC 

800mm 

350mm 

304g 

240mm 

365g 

500mm(length )x415mm(\Mdth)x320mm(Height) 

(Topwidth: 145mm) 

428g 

2.6Kg 

41x14mm 

320rpmN 

360W 

147g 
©20i 2 OJI Innovations. All Rights Reserved. 

Current 

Signal Frequency 

Drive PWM Frequency 

Weight 

Propeller 

Material 

Size 

Weight 

Flight Parameters 

Takeoff Weight 

Load Weight 

Power Battery 

Max Power Consumption 

Hover Power Consumption 

Hover Time 

40A OPTOVoltage 

30Hz- 450Hz 

24KHz 

18g 

Carbon Fiber 

15x04in 

15g 

5.0Kg- 7.0Kg 

OKg -2.5Kg 

6S LiPo 

LiPo (6S_ 10000mAh-15000mAh. 15C(Min)) 

2100W 

720W(@ Takeoff Weight 6Kg) 

Max: 16 min (@10000mAh&6KgTakeoff Weight) 

15 
©2012 OJ! Innovations. All Rights Reserved. 16 

AppendixMount Battery Bracket 

Step1: Mount the retaining clip and the bracket, fix screws (but not tighten). 

Step2: Place the mounting board and adjust its position, and then tighten all screws. 

'arallel ...... ~~~--..... Pa=riiJ=Iel.-'j'!iliOilf' .. "- -~l 
Step1 For arms For arms 

Step3 For arms For arms 

©2012 OJ! Innovations. All Rights Reserved. 17 

Tro ubI e S h ooti n Qltthe motor mount loosens, please tighten it by following the procedures. 

Step2 

Step1: Remove. Please unscrew the screws on the top. 

Step2: Tighten. Retighten the motor mount screws on the back to make the motor firmly attached. Step3: 

Remount. Remount the screws on the top. 

Notices: 

Shim should be mounted in the correct position, as shim mount position of arm is different from arm . 

Tips: 

Please use adequate screw glue. 
Install screws with appropriate strength. 
Spare Parts Listing 

If SBOO needs part replaced, please refer to the following diagram to identify the part with the NO. and components, 

and then make a purchase. Each package includes screws needed. 

~-----'<~~r 

___ .._.llj 

NO. Name Components 

2 

15'Propeller CCW S8010101A I I 15'Propeller CW 1sso1o1o1s 

Components 
©2012 DJIInnovations. All Rights Reserved. 18 

3 4114 Motor 320KV 58010301, 58010302, 58010303 

58010401A, 58010402, 58010403, 58010404 

5 Frame Arm (Clockwise) 580104018, 580104o2, 58010403, 58010404 

6 ESC (Red LED) I 58010601, 58010602R 

Frame Arm (Counter Clockwise) 

$ 

4 

7 ESC (Green LED) 58010601 ,, 58010602G 

8 Frame Arm w/ Propeller& Motor& ESC 5. 

1. CCW&RedLED 1, 3, 4, 6 

2. CCW &Green LED 1,3,4,7 

3. CW&RedLED 

4. CW & Green LED 2,3,5,6 

2,3,5,7 
Notices:@ 

The diagram is only for counter clockwise rotation propeller and frame arm. For 

clockwise propeller and frame arm, it is 580101018 and 580104018. 
8021 

Bollur 01 

©2012 DJIInnovations. All Rights Reserved. 19 

Ensure to solder thick wires and fine wires correctly, when solder ESC to frame arm. Clockwise and counter dockwise 

motor should be soldered to ESC correctly by different color order. 
For arms 

For arms 

Enamel Wire 

Shield Wire 

Red 

Black ----------:~'¥---,F-=-, 

~d--------------~~~ 

Black-----------,,......; 

Biu~e ~~~~~~~ Thick. wire,--"'j'"-->~----#.11"'--:!hfn. 

Fm11 wire,---±~~.,..fi!q-il~"-

~irl~wi~·~z 

Thick wire..:::::::=~~~~;._:x_ 
©2012 DJI Innovations. All Rights Reserved 

NO. Name Components 

9 Arm Mounting Bracket 58020901.58020902.58020903. 

10 Center Frame Support Pillar 58021001 

11 Center Frame Top &Bottom Board 58021101.58021102 

12 Top Board Cover for Arm Mounting Bracket 58021201 

l{)l-----------, 

102-----------, 

iOl---ft IQB~--------------------S~l~ 

ll2'---.... ·S~lW.!> 

os-----

:oa:---"1' 

03-----flt 

:xs----r--:.~ 

:Qoll------.#il 

~='----------S8032201 

=:t:l::J~Jlr-~;fll---(l~er------;;:o~-----S8032202 

xs:----· "',CJr'""--~-_;L,..d-=::------ S8031507 

i0&-----"1<------' "" .......... ~ 

-01.---------'1~;"-""-~~ 

.02'--------t\_ 

.031-----------~~ 

:X&::----------

~1--------~ 

58032201 

~~--S8032203 

=-~........;;:=--.- S8032204 

~I 

(1) IVJ 

(~~[10il~ 

t=J l~J <:lD 

5~1402 

(I 

20 

58020904 

Note1: All unlabeled screws are HC-M2.5X5.() 

Note2: ( 1) Left and right T -frames are different; (2) Left and right bi-pod top mounting hubs are different; (3) Left set, 

middle set and right set of bi-ped carbon tube bracket are different 

·NO., I Name 

13 H-Frame 

Bi-ped Top Mounting Hub 

215 H-Frame w/Bi-pod Top Mounting Hub 

I I () 

Components 

58031301.58031302 

58031401.58031402 

58031501.58031502.58031503.58031504. 

58031505.58031506.58031507.13.14 
16 

T-Frame(Right) 

58031601, 58031602, 58031603 

58031601 

T-Frame Nonslip Damper (4pcs) 

19 T-Frame Silicone Rubber Damper (4pcs) 

LV I 1::11-pod carbon 1 ube 

21 Bi-pod Drawbar 

I l::!attery 1 ray 

23 Bi-pod Carbon Tube Bracket(Left Set) 

L4 

Bi-pod Carbon Tube Bracket(Middle Set) 

©2012 OJ! Innovations. All Rights Reserved. 

58031801 

58031901 

158032001 

58032101, 58032102(2pcs) , 58032103 

158032201, 58032202, 58032203, 58032204 

58031501, 58031502, 58031503, 58031504, 

58031505 

58031501, 58031502, 58031503, 58031504, 

58031506 

21 

58031501, 58031502, 58031503, 58031504,25 Bi-pod Carbon Tube Bracket(Right Set) 

58031507 

Lti ::;crew t-'acK ML.o.X.o lwpcs 

27 Screw Pack M3X8 lOpes 

::;crew t-'acK ML.o.X.l::i I lopes 
Lappert Smith's Unmanned Aircraft Svstem 

Operations Manual 

Part A 

I. Responsibility and duties of support personnel in the operation of the UAS 

a. Mission Commander 

1. The Mission Commander's main duty during the deployment ofthe UAS 

is to operate the UAS safely while accomplishing the goals of the client. 

11. The Mission Commander has absolute authority to reject a flight based on 

personnel safety or violation ofF AA regulations 

1. No member of the team, regardless oftitle, shall order an operator 

to make a flight when, in the opinion of the Mission Commander, 

it poses a risk to personnel or is in violation ofF AA regulations 

111. Mission Commanders shall see-and-avoid any obstacle that will lessen 

safety during the mission 

IV. Mission Commander shall be responsive to the requests of the observer in 

order to accomplish the deployment 

b. Pilot in Command 

1. The Pilot In Command (PIC) is responsible for compliance with this 

manual, as well as applicable FAA regulations 

n. The PIC is directly responsible for, and is the final authority over the 

actual operation ofthe UAS 

111. The PIC shall monitor the radio with tower as needed for updates 

c. Visual Observers 

1. Observers shall see-and-avoid any obstacle that will lessen safety during 

the mission and inform the PIC 

u. Observers shall operate any attachments to the UAS, allowing the PIC to 

maintain complete focus on the operation of the UAS. 

111. Observers shall remain alert for suspicious persons or activities on the 

ground and coordinate response by ground units. 

Page lof6 
1v. Observers shall assist the PIC to achieve the main objective of safe 

operation ofthe UAS 

v. Observers shall be responsible for documentation for mission training and 

updating of flight books 

II. Crew health and appropriately fitness prior to conducting any operations. 

a. Medical Factors 

1. Operator and Observers shall only deploy the UAS when rested and 

emotionally prepared for the tasks at hand 

11. Physical illness, exhaustion, emotional problems, etc., can seriously 

impair judgment, memory and alertness 

1. Any operator, pilot, or observer is expected to refrain from 

conducting U AS operations when a problems exists that could 

reasonably be expected to affect their ability to perform flight 

duties 

111. A self-assessment of physical condition shall be made by all members 

during pre-flight activities 

1v. No member shall act as an operator or observer within eight hours after 

consumption of any alcoholic beverage or while under the influence of 

alcohol 

PartE 

I. Operating Documents 

a. This Operations Manual, the U AS manufacturers manual, and a grant of 

exemption and/or Certificate of Authorization (COA), will at all times during the 

UAS's operation be accessible and available for presentation upon request from a 

law enforcement official or other proper authority 

II. Preflight 

a. Prior to each flight, the PIC inspect the UAS to ensure it is safe for operation 

1. No operations shall be conducted until a condition that affects safe 

operation, if one exists, is corrected 

Page 2 of6 
1. Any replacement or maintenance of a flight critical component 

must undergo a functional test flight 

a. Each maintenance event must be documented and signed 

prior to resuming U AS to operations. 

b. Airframe Inspection 

1. Cracks (especially in high stress areas like joints) 

11. Loose or damaged screws I fasteners I bands I straps I ties 

111. Loose or damaged wiring 

IV. Loose or damaged connections (solder, plugs, etc) 

v. Inspect prop mounts, screws and apply slight counter pressure on arms to 

check for loosened construction 

v1. Battery/batteries fully charged (25.2 volts), properly seated and secured 

vu. Remove props and test fail-safe behavior 

vm. Props are smooth and free of damage/defect (blade, surface, & hub) 

IX. Tighten prop adapters 

x. Ensure voltage alarm is connected 

x1. Ensure arming/idle timeout is properly configured 

xu. Check your RC transmitter shows the right range and centering for all 

sticks 

x111. If desired, perform range test Check RC(TXIRX) operation range (on the 

ground!) from time to time (and before 1st flight) 

c. POWER UP PROCEDURE 

1. Batteries charged & secured 

Il. Plan aircraft mission coordinates in accordance with location and possible 

hazards 

m. Position aircraft in a level, safe location for takeoff 

IV. !fusing onboard video recorder (i.e., Gopro), tum on camera 

v. All transmitter controls must move freely in all directions 

v1. All transmitter trims must be in their neutral positions 

vn. All transmitter switches must be in the correct position (Transmitter 

throttle to zero) 

Page 3 of 6 
vm. Turn on radio transmitter on 

1x. Connect/power on battery to airframe 

x. Ensure led indicators & audible tones are all indicating correctly 

x1. Ensure the autopilot has a GPS fix. When switching to Loiter mode, listen 

for a beep or TX to say flight mode 2 

xu. For manual start ensure Loiter and Auto controls are turned off, and set to 

Stabilize 

xn1. Ensure compasses are calibrated and the right setting is loaded. 

x1v. Timer on (if applicable) 

xv. Stand clear- audibly, loudly announce the word "CLEAR!" 

xv1. Arm flight controller 

III. Take-off 

a. Operating limitations and conditions 

1. Minimum Personnel Requirements 

1. The minimum personnel required on ALL missions will be a 

Mission Commander, PIC and at least one (1) Observer. 

a. Under !!Q circumstances will a PIC attempt to complete a 

deployment alone 

b. Certificate of Authorization (COA) 

1. No UAS operations will begin until a COA is obtained for that PIC unless 

1. Otherwise allowed by law or specific FAA exemption 

u. A Notice to Airman (NOT AM) will be requested no more than 72 hours in 

advance, but no less than 12 hours prior to, any planned operation unless 

1. Otherwise allowed by law or specific FAA exemption 

c. Markings: 

1. N-Number markings must be as large as practicable and in accordance 

with FAA guidelines 

d. In flight 

1. NO operations of any kind will be conducted in within a five (5) 

nautical miles vicinity of an airport reference point without written 

consent from the controlling agency, office, or authority 

Page 4 of6 
n. All UAS operation will be conducted a safe distance from people, animals 

and objects 

e. Take-offWeight 

i. The UAS take-off weight must not exceed 30 pounds. 

f Maximum Speed 

i. The UAS will operate at a speed no greater than 30 miles per hour. 

g. Maximum Operational Height in AGL 

1. The UAS will be operated at an altitude of no more than 400ft above 

ground level ( AGL) 

h. Minimum Operating Battery Power Level 

1. All UAS operations will cease when the battery power level reaches 30% 

of full capacity 

1. Pilot in Control (PIC) 

1. ANY AND ALL operations will be conducted by a PIC with a private 

pilot license and who holds at least a Second-Class Medical. 

11. The PIC must be designated prior to take-off 

1. The designation ofPIC cannot be transferred at any time during 

operations 

J. Visual Observer (VO) 

1. No UAS operations will be conducted without at least one (1) visual 

observer 

k. Visual Line of Sight (VLOS) operation 

1. At all times, the UAS will be operated within visual line of sight of the 

vo 

1. Visual Meteorological Conditions (VMC) 

1. UAS operations will be conducted during the daytime only and under 

visual meteorological conditions 

IV. Landing 

a. Tum off the Multi-Rotor first and disconnect the flight battery before turning off 

the transmitter 

Page 5 of 6 
V. Emergency Procedures 

a. Pre-determined landing area 

1. In the event of flight termination due to a critical system failure, the UAS 

must be programmed to land in a pre-determined location. 

VI. After the flight (post-flight Check) 

a. Disconnect the battery 

b. Visually inspect the body and propellers. 

c. Document any damaged or structurally deficient areas. 

Parte 

I. Maintenance 

a. UAS maintenance activities will be conducted in accordance with the procedures 

specified in the Maintenance Manual 

b. Specialist equipment items maintenance activities will be conducted in 

accordance with the respective manufacturers' service manuals by persons with 

technical knowledge and expertise 

II. Maintenance 

a. Each maintenance event must be documented and signed prior to resuming any 

UAS to operations 

b. Records 

1. Maintenance Records shall be kept on file and available for inspection or 

review within a reasonable period of time 

Page 6 of6