1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Modernizationand Reform Act 

of2012, 49 U.S.C. § 44701 (f), and Part 11 ofthe Federal Aviation Regulations 

Dear Sir or Madam: 

Aeroterra, LLC. ("Aeroterra"), pursuant to Section 333 ofthe FAA Modernization and Reform Act of 

2012 (the "Refonn Act") ("Section 333"), Subsection (f) of49 U.S.C. § 44701, and 14 C.F.R. Part 11, is requesting an exemption from the Federal Aviation Regulations ("F ARs") listed below and discussed in 

Appendix A to allow Aeroterra to conduct commercial operations with Tuffwing UA V mapper Unmanned Aircraft System ("UAS") (the "Tuffwing") to provide surveying and energy development services, which are primarily located in remote unpopulated areas with minimal air traffic. These 

services include obtaining still photographs, real-time video, and other data taken by onboard sensors to monitor operations, environmental conditions, and forestland security. Performing these services with a UAS is in the public interest for several reasons, which are detailed further herein and include: (1) minimizing safety risks inherent in manned operations, both in the air and on the ground; (2) inspecting locations where humans are not able to go; (3) enhancing capabilities to utilize the UAS to assist first 

responders on safety or environmental incidents; (4) improving access control/security to sites; and (5) monitoring environmental conditions. 

The battery-powered Tuffwing weighs 54 ounces and has a flight time of 40-45 minutes depending on operating conditions. It employs a self-stabilizing aircraft configuration with stability augmentation avionics that provides ease-of-control and steady video imagery. Its high- perfonnance design leverages advanced composite materials, innovative electronics, and cutting-edge sensor technology to increase mission capabilities and make Tuffwing a reliable and accurate solution to meet a variety of industry needs. 

Operations under the exemption will be conducted under the limitations and conditions set forth in 

Appendix Band as may be modified by the FAA as required by Section 333.2. Use of the Tuffwing in Aeroterra's operations as proposed herein, would provide significant public safety benefits over existing inspection and survey operations, while operating safely within the National Airspace System ("NAS"). 

Use ofUAS offers numerous safety benefits for operations on the ground. First, the use ofUAS would alleviate the need for personnel to perform difficult and dangerous manual inspections of remote, hazardous, or inaccessible locations along pipelines or facilities. Second, UAS will be able to more 

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services will reduce the need to operate manned aircraft in a difficult environment and reduce the 

environmental impact of conventional aircraft operations. In addition, the small, lightweight, and easily 

controllable operating characteristics of the Tuffwing provide for safe operations over the remote or 

uninhabited locations of gas development and timberland. This feature would also be beneficial in 

surveying from above in detail features of facilities that it would be too dangerous to fly manned aircraft 

close to. Our clients also maintain strict control over access to their facilities, require all personnel to 

wear personal protective gear, including hard hats and safety glasses, and attend site-specific safety 

hazard briefings to be onsite, so these proposed operations would not endanger workers onsite. 

Although the Tuffwing can be operated by one person, Aeroterra's flight operations will always involve 

at least two people as required by the FAA: a vehicle operator ("VO") and a mission operator ("MO"). 

The VO is responsible for flying the UAS, monitoring its status and flight dynamics, while keeping the 

flight within the manufacturer's specified operational limits to ensure safe operation of the vehicle. MOs 

will be responsible for monitoring the airspace for other aircraft and hazards and advising the VO before 

and during flight of all such observed risks. In addition to completing Aeroterra's training, the VO will 

hold at least a state-issued motor vehicle driver's license. 

While Aeroterra has modeled its request off of Part 333 Exemption grants as of the date of its 

application, Aeroterra requests that the FAA treat Aeroterra's application as requesting the most lenient 

relief granted to similar applicants at the time of adjudication. Additionally, should the FAA modify any 

of its UAS operating conditions through exemptions or otherwise after adjudicating Aeroterra's 

application, Aeroterra requests blanket approval to operate it's UAS in accordance with the more lenient 

operating conditions. Aeroterra reserves the right to supplement or amend its application. 

Applicant Information: 

The name of the applicant is: Aero terra, LLC. 

The primary contact for this application is: Shelley Head, 301 W. Broadway Street, Gainesville, TX 

76240; 940-665-9105 

Email: Shead(@.Songratus.com 

Exemptions Requested: 

Aero terra, LLC requests exemptions from the following regulations: 14 C.F .R. Part 21; 14 C.F .R. 

61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 

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

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operational capability and proximity to airports and populated areas of the particular UAS. In all cases, 

an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in 

the restricted environment and under the conditions proposed herein will be at least as safe, or safer, 

than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without 

the restrictions and conditions proposed. 

The Tuffwing is a more recently developed system. It does, however, utilize industry- standard sensors 

and controls, which provide numerous fail safes. The Tuffwing is equipped with automated features for 

safe takeoff, flight, and landings in varying conditions. The shorter flight times and very high 

maneuverability will dictate that this system will be used in close proximity to the operator and at lower 

altitudes, which will increase the safety of the system. Tuffwing Operator's Manual will be provided. 

Pre- and post-flight inspections and systems checks will precede and follow each flight following a 

prescribed protocol. Test flights are conducted following any upgrades to system software, firmware, or 

hardware to ensure safety of operations. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

Aeroterra pursuant to the Safety Checklist's requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of operation as is now 

done with conventional aerial mapping and surveying. These safety enhancements, which already apply 

to civil aircraft operated in connection with mapping and surveying operations, provide a greater degree 

of safety to the public and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Application of these same criteria demonstrates 

that there is no credible threat to national security posed by the UAS, due to its size, speed of operations, 

location of operation, lack of explosive materials or flammable liquid fuels and inability to carry a 

substantial external load. 

Operating Conditions: 

Aeroterra requests an exemption subject to the conditions listed in Appendix B, which are substantially 

similar to the operating conditions required for the FAA's previous grants of exemptions under Section 

333. In accordance with the conditions approved in previous exemption grants, Aeroterra is requesting 

authority to operate the Tuffwing within visual line of sight and below 200 feet AGL. The area of 

operations would include those lands owned or leased by Aeroterra's clients in the ranching, natural gas, 

oil, utilities, wildlife, or timberland management industries across the United States. Given that the 

operating sites are often not flat, Aero terra will use the elevation of the highest predominant terrain 

within 1 mile of the launch point and within the visual line of sight as a ground reference point to 

establish the 200 feet ceiling. In other words, Aeroterra will not operate the Tuffwing any higher than 

200 feet above the highest point within 1 mile from the launch point, and will only do so provided the 

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operating under Visual Flight Rules ("VFR") fly over ridges with at least 1,000 feet clearance. Pilots 

flying under instrument flight rules ("IFR") over mountainous areas must fly at "an altitude of2,000 feet 

above the highest obstacle within a horizontal distance of 4 nautical miles from the course to be flown. 1 

Given the locations of our projects and FAA minimum flight altitudes, the Tuffwing will be able to 

operate below altitudes in use by manned aircraft. 

Third, the VO will operate the Tuffwing from higher elevations in regard to project area when possible, 

allowing the MO to maintain full visibility of the airspace over the project to avoid conflict with any 

manned aircraft. Aero terra will use a MO who will stay in radio contact with the VO if the terrain 

warrants it. 

Fourth, Aeroterra's operational procedures will require VOs to deconflict by suspending all VAS 

operations when a manned aircraft operates within airspace infringement boundaries, greatly reducing 

the risk to any manned aircraft. The VO will be able to immediately land the VAS when the VO or MO 

spot another manned aircraft within the planned area of operations or safety personnel direct 

cessation ofUAS operations. 

Fifth, Aeroterra maintains contact with any personnel onsite, requiring all personnel to wear personal 

protective gear, including hard hats and safety glasses, and mandates site specific safety training as 

required by clients. Non-participant Aeroterra employees will carry radios and be alerted before UAS 

operations begin. These safeguards, along with the VAS's light weight, provide an equivalent level of 

safety for non-participants to be closer than 500 feet. 

Sixth, the Tuffwing is equipped with visible strobe lights that will alert any manned aircraft in the area 

to its position. 

Seventh, the Turffwing flight software, Pixhawk Mission Planner manufactured by 3D Robotics, 

provides many built-in functional and safety features to assist the VO in safe and reliable operation. 

Both systems can operate autonomously in "Navigation" mode. In Navigation mode, the VO selects 

waypoints, rally points, and a landing area before launching. The VAS then uses GPS navigation to 

follow the pre-selected flight path. The UAS also can be flown in a semi-autonomous mode in which the 

UAS flight software maintains a preset altitude and airspeed and the VO controls heading. Additionally, 

the flight software allows the VO to set certain fail safes, i.e. actions the VAS will take in response to 

1 FAA Aviation Safety Program, Tips on Mountain Flying, available at 

https:/Jwww.faa.gov/regulations policies/handbooks mam .. alslavjationlmedia/tips on mountain flyjng.{Xlf. Pilots operating 

under VFR also must operate at an altitude that would allow them to make an "emergency landing without undue hazard to 

persons or property on the surface." 14 C.F.R. § 9 J.ll9(a). 6 FAR 91.177(a)(2)(i). 

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nonparticipating employees without barriers or structures to protect them, provided they wear customary 

safety gear (e.g. hard hats). An equivalent level of safety is provided because the VAS's weight, 

materials, and reliability, along with the required operator training and operating environment, prevent 

these systems from posing a serious risk to clients/employees wearing personal protective gear. 

Operator Requirements: 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PICs operating the UAS to have a private pilot's license rather than a 

commercial pilot's license to operate the UAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the UAS is remotely-controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Safety 

Checklist. The level of safety provided by the requirements included in the Safety Checklist exceeds 

that provided by a single individual holding a commercial pilot's certificate operating a conventional 

aircraft. The risks associated with the operation of the UAS are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, that allowing operations 

of the UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 

14 C.F.R. §61.1 13(a) and (b). 

Public Interest: 

Aeroterra respectfully submits that its use of the UAS in lieu of manned operations, which are currently 

conducted with conventional fixed wing and rotary aircraft, offers a net safety benefit and will achieve 

an enhanced level of safety, as mandated under Section 333(c) ofthe Reform Act. Approval ofthis 

application also will benefit the public interest by allowing better, safer, and more cost efficient 

information gathering for the ecosystem services and energy development industries. Conventional 

aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles that 

must transit to the operational location and carry significant quantities of combustible fuels and a multiperson crew in piloting and observation roles. These operations become even more difficult in the 

energy and forestry industries due to the terrain. By contrast, the Tuffwing weighs 3.375 lbs., including 

its payload, uses a battery for power, is carried to and from the area of activity, removes the need for 

airborne pilots and observers, and poses less risk to people and infrastructure on the ground, as well as 

other aircraft. Additionally, no national security issue is raised by the grant of the requested exemptions 

due to the VAS's small size and load-carrying capacity, as well as its operational limitations and absence 

of flammable fuel. On the other hand, the use of these systems is likely to enhance national security 

through better and more accurate monitoring of critical national infrastructure. The grant of the 

requested exemption is in the public interest based on the clear direction in Section 333 and 49 U.S.C. § 

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leased, and access controlled by Aeroterra's clients. Access to these areas is generally restricted to 

employees and authorized personnel only. No privacy issues are raised by this application. 

Federal Register Summary: 

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the Federal 

Register, should the FAA detennine that publication is needed: 

Docket No.: No. F AA-20 15- Petitioner: Aero terra, LLC 

Section of 14 C.F.R.: Part 21, § 61.113(a) and (b),§ 91.7(a), § 91.119(c), § 91.121, § 91.151(a), § 

91.405(a), § 91.407(a)(1), § 91.409(a)(2), § 91.41 ?(a) and (b). 

Description of Relief Sought: Aeroterra is seeking an exemption to conduct commercial operations 

using a small unmanned aircraft (55 pounds or less) in remote areas of the United States. 

Aero terra requests that the FAA not request public comment on its application because it would not set a 

precedent and because the relief requested is identical to exemptions granted previously. 14 C.F.R. § 

11.87. 

2 Under 49 U.S.C. § 4470 I (f), the "Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections 44702-44716 of [Title 49) if the Administrator finds the 

exemption is in the public interest." 

, See Exemption Nos. 11109, 11110, 11136, 11172. 

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that may technically apply to the operation of the Tuffwing UAS: 

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

Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by§ 91.203(a)(1 ). Given the size and weight of the 

aircraft, the operating conditions, design safety features, and the proposed conditions and limitations, it 

is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve 

or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of 

safety under Part 11 and Section 333. Section 333 and 49 U.S.C. § 44701(f) both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the UAS 

involved. 

In this case, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The Tuffwing weighs 3.375 

pounds fully loaded. It will not carry a pilot, passenger or flammable fuel. These UASs operate 

exclusively within a controlled area pre- disclosed and in compliance with conditions set forth herein. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored 

by the VO and observer(s), pursuant to the conditions set forth in Appendix B, the Operator's Manual, 

and local public safety requirements. The lack of flammable fuel and the fact that the aircraft is carried 

to the location and not flown there all establish the equivalent level of safety. The UAS provides at least 

an equivalent level of safety to that of such operations being conducted with conventional aircraft that 

would be orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel. 

14 C.F.R. §§ 61.113(a) & (b): Commercial Pilot Privileges 

Sections 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the Tuffwing is remotely controlled with no 

passengers or property of others on board. The area of operation is controlled and restricted, and all 

flights are planned and coordinated in advance as set forth in the Operator's Manual. In conjunction with 

the required training of the VO and observers, the level of safety provided by the requirements included 

in the Operator's Manual exceeds that provided by a single individual holding a commercial pilot 

certificate operating a conventional aircraft. The proposed operations will achieve at least an 

equivalent level of safety. 

14 C.F.R. § 91.7(a): Minimum Safe Altitudes 

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Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 91.119( c) 

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Because some of the aerial inspection 

and survey work must be accomplished at altitudes less than 500 feet AGL and nonparticipating 

employees will be working within 500 feet of the VAS, an exemption from Section 91.l19( c) is needed. 

The equivalent level of safety will be achieved because Aeroterra's employees and the client's onsite 

employees are required to wear personal protective gear and because the VAS, given its size, weight, 

speed, and materials, does not pose a serious risk. Also, every flight will be conducted over land owned 

or controlled by Aeroterra's clients. Compared to aerial inspection operations conducted with aircraft or 

rotorcraft weighing far more than 3.375 pounds (for the Tuffwing) and carrying flammable fuel, any risk 

associated with these operations will be far less than those currently allowed with conventional aircraft 

operating at or below 500 feet AGL. 

14 C.F.R. § 121: Altimeter Setting 

Section 121 requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set "to the elevation of the departure airport or an appropriate altimeter setting available 

before departure." As the VAS may not have a barometric altimeter, but instead a GPS altitude read out, 

an exemption is required. An equivalent level of safety will be achieved by the operator, pursuant to the 

Operator's Manual, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight. 

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

This regulation prohibits an individual from beginning "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." The Tuffwing batteries 

provide approximately 40-45 minutes of powered flight. Without an exemption from 14 C.F.R. § 

91.151, the Tuffwing flights would be limited to approximately 10 minutes in length because the VO 

would require the last 30 minutes to satisfy section 91.151(a). 

Aeroterra believes that an exemption from 14 C.F.R. § 91.151 (a) provides an equivalent level of safety 

4 Exemption Nos. 11156, 11158, 11159. 

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more, would be more than adequate to return the UAS to its planned landing zone from anywhere in its 

limited operating area. 5 

14 C.F.R. §§ 91.405(a), 91.407(a)(1 ), 91.409(a)(2), and 91.417(a): Maintenance Inspections 

Section 91 .405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. 11 

Section 91.407 similarly makes reference to requirements in Part 43. Section 91.409(a)(2) requires an 

annual inspection for the issuance of an airworthiness certificate. Section 91.417( a) requires the owner 

or operator to keep records showing certain maintenance work that has been accomplished by 

certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for 

return to service. 

Pre-flight checks will be performed by a qualified person prior to each flight and at predefined intervals 

as part of the maintenance schedule. 

The pre-flight checklist includes: 

1. Visual inspection of the airframe; 

2. Visual inspections ofpropeller(s); 

3. Verify GPS acquisition; 

4. Plan and upload mission; 

5. Camera and payload check; 

6. Controls check; 

7. Gyro/control surfaces check; 

8. Throttle check; 

9. Check sensors; and 

10. Verify failsafes are set correctly. 

An equivalent level of safety will be achieved because the UAS will operate only in restricted 

predetermined areas, and at low altitudes. In addition, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance that is performed. Test flights will be conducted prior to operations following adjustments 

to UAS hardware, software, or firmware. Moreover, the operator is the person most familiar with the 

aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent 

5 Exemption I 0673 (allowing Lockheed Martin Corporation to operate without compliance with 91 .151 (a)); see also 

Exemptions 2689F, 5745, I 0673 and I 0808 

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e UAS shall not be flown at a ground speed exceeding 60 kts. 

3) The UAS will not be operated at an altitude more than 200 feet above the highest 

predominant terrain except as may be provided by FAA Air Traffic Control ("ATC") 

via GOA. The highest predominant terrain is defined as terrain within 1 mile of the 

launch point and within the visual line of sight of the VO. All altitudes reported to 

ATC shall be in feet AGL. 

4) All operations must use a MO. The MO and VO must be able to communicate 

verbally at all times. The VO must be designated before the flight. The VO must 

ensure that the MO can perfonn the functions prescribed in the operating documents. 

5) The operating documents and this grant of exemption must be accessible during UAS 

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

between the conditions and limitations in the exemption and the procedures outlined 

in the operating documents, the conditions and limitations in the exemption take 

precedence and must be followed. Otherwise, Aeroterra must follow the procedures as 

outlined in its operating documents. Aeroterra may update or revise its operating 

documents. It is Aeroterra's responsibility to track such revisions and present updated 

and revised documents to the Administrator upon request. Aeroterra must also present 

updated and revised documents if it petitions for extension or amendment to this grant 

of exemption. 

6) Prior to each flight the VO must inspect the UAS to ensure that it is in a condition for 

safe flight. The VO shall not operate the aircraft if the inspection reveals a condition 

that affects the safe operation of the UAS until the necessary maintenance has been 

perfonned and the UAS is found to be in a condition for safe flight. The Ground 

Control Station, if utilized, must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records. 

7) 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 in accordance with the Operator's Manual. The VO who 

conducts the functional test flight must make an entry in the aircraft records of the 

flight. The requirements and procedures for a functional test flight and aircraft record 

entry shall be included in the Operator's Manual. 

8) The pre-flight inspection must account for all discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

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ent/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the person authorized to return the UAS to service. 

11) Each VAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

12) The VO must possess at least valid state-issued motor vehicle driver's license. The 

VO must also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an 

aircraft in which the VO is rated on his or her pilot certificate. 

13) Aeroterra may not permit any VO to operate unless the VO 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 this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures.6 VO qualification flight hours and currency 

must be logged in a manner consistent with 14 C.F.R. § 61.51 (b). The VO must 

ensure that the MO is trained appropriately in order to fulfill his or her duties. A 

record of training and qualification must be documented and made available upon 

request by the Administrator. Flights for the purposes of training the operator's VOs 

and MOs (training, proficiency, and experience-building), 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 VO must operate the UAS with appropriate distance from nonparticipants in 

accordance with these operating conditions. 

14) 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"). 

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

15) The UAS may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart. 

16) The VAS 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 VO. 

6 Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this 

requirement. 

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20) The radio frequency spectrum used for operation and control of the UAS must 

comply with Federal Communication (FCC) or other appropriate government 

oversight agency requirements. 

21) The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to 

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

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

official upon request. 

22) The UAS must remain clear and yield the right of way to all other manned 

operations and activities at all times. 

23) The UAS may not be operated from any moving device or vehicle. 

24) The UAS may not be operated over congested or densely populated areas. 

25) Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, structures, and public access roads unless: 

a. The nonparticipating persons are authorized to access the client's site and are 

wearing personal protective gear; 

b. For non-participants who do not qualify as client employees, barriers or 

structures are present that sufficiently protect them from the UAS and/or debris 

in the event of an accident. The operator must ensure that nonparticipating 

persons who are not client employees remain under such protection. If a 

situation arises where nonparticipating persons who are not client employees 

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

must cease immediately; or 

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

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

and the VO has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard. 

26) Operations nearer than 500 feet to the VO, MO, operator trainees or essential 

persons as defined in the operating documents are permitted if those operations do not 

present an undue hazard to those persons per§ 91.119(a) as determined by the VO. 

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VAS Operating Overview - Tuffwing: 

The Tuffwing is a fixed-wing aircraft constructed of EPP foam and rugged carbon fiber composite. It 

has fully autonomous operation for takeoff, navigation, and landing. 

Parameter Wingspan 48 in 

Length 18 in 

Weight fully loaded 54 oz (well below the 4.4 bl FAA proposed 

requirement for Micro UAS 

Weight, with EO side-look payload 3.375 lbs 

Payload Wireless Range 5- 15 krn LOS 

Cruise Speed (Best) 26 kts (30 mph) 

Endurance (Dash speed) 52 kts (60 mph) 

Stall Speed 25 kts {29 mph) 

Max wind 20 kts sustained, 30 kts gusting 

Precipitation None 

Fl!ght Rate 40-45 mins 

Climb Rate Launch 500 ftlmin @ 2,000 AMSL 

Launch Hand launch, no catapult 

Landing Autonomous or manual 

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espond with a set command (one such option being to fly back to a 

preselected rally point and land). Faults that can be detected include: loss of communication, loss of 

GPS, and low battery levels. In addition, the operator can create no fly zones, and the system will 

visually and audibly warn the operator if the planned flight path would enter the no fly zone. 

Operator's Manual -The Tuffwing Operator's Manual will be provided under separate cover with a 

request for confidential treatment. 

Power - The Tuffwing and its ground control station are both powered by a Lithium polymer 

rechargeable battery pack. A new battery has a fully charged voltage of approximately 12.4V. A "fullpack" has a capacity of 4 Amp-hours. An additional "half-pack" can be installed for extended operation. 

A new "half-pack" has a fully charged voltage of 12.4V and a capacity of2 Amp-hours. The Tuffwing's 

battery charge is displayed in real-time on the ground control terminal, ensuring maximum flight 

duration and safety. 

Takeoff and Landing style/type - The Tuffwing is hand launched. The Tuffwing lands by returning to a 

pre-determined rally point and beginning a spiral descent. Once it reaches a preselected altitude, it heads 

toward the landing waypoint, descending until it lands and skids to a stop or it can manually landed. 

Navigation System- Specific maps can be downloaded to the display screen (such as air sectional and 

geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and 

during flight operation creating specific locations and sequences for the aircraft. 

Defmed "Keep Out" Areas - The navigation software allows for preplanning Keep Out Areas that allow 

the operator to designate airspace he or she does not want the Tuffwing to enter. If defined flight paths 

pass through an area designated as keep-out, the individual waypoints and waypoint connection 

segments tum red as a warning. Additionally, if a mission is uploaded and intersects with a keep out 

area, a warning is presented to the user. Also, if an aircraft in flight is navigated into a designated keep 

out area, an audible warning is sounded. 

Maintenance - The Tuffwing UAS needs very little maintenance, and operators may perform most 

required maintenance in the field with the field repair kit. 

Command and Control Systems -The UAS Ground Control Station (GCS) allows the operator 

simultaneous control over aircraft and payloads. The display screen provides all essential flight data to 

the operator. Telemetry data is transmitted to the command station at least once per second. 

Displayed on GCS: 

• Current position 

• Registered home position 

Page 16 
• Communication strength 

• Range from home 

• Bearing from home 

• Duration of current mission 

• Rate of climb 

• Mode of the aircraft 

• Battery level 

Emergency Procedures and System Failures 

Loss of Link- The UAS does not need constant signal from the GCS to continue flying. 

Communications outages are detected by the system and are reported to the VO. During the 

communication outage, the VAS continues on its pre-determined flight path until a failsafe is triggered. 

Once a failsafe is triggered, the UAS will perform in accordance with the failsafe conditions uploaded 

before launch. This is accomplished without input from the operator. 

Security 

The system and communication links are spread spectrum. 

Pperational Characteristics 

!Characteristic jYes/No 

Lights Out Operation No ~FR Operations !Yes 

IFR Operations No 

Day Operations ~es Night Operations No 

Avionics Equipment 

Equipment ~es/No PPS ~es Moving Map Indicator ~es ifracking Capability !No 

[TCAIMCAS Collision A voidance No 

EL T (Falcon Tracker) Yes 

Transponder No 

Page 17 
, 

, 

y 

levels. 

Page 18 
Got Questions? 830-446-1500 Talk or Text 

TuffWing LLC 

Boerne, Texas USA 

www .tuffwing.com 
7. Coroplast hatch 

8. Coroplast winglets 

9. Coroplast servo covers for wing bottom 

10. Coroplast wing cut fillers (2) 

11. 4mm Coroplast center wing ribs 

12. Coroplast accessory mounts (2) 

13. 10mm x 30.75" carbon fiber tube- center 

wing spar (1) 

14. 10mm x 25.9" carbon fiber tube- leading 

edge wing spars (2) 

15. 4 mm x 19.5" carbon fiber tube - elevon 

spars (2) 

16. Control rod with Z bend (2) 

17. Control rod quick connect (2) 

1 B. Velcro set 

19. 3mm x Bmm motor mount screws (4) 

20. Servo extensions, 12" 

21. Assembly manual 

Building materials - Not included 

• Medium CA. Foam safe NOT required. 

• CA accelerator. 

Electronics- Not included 

• Brushless outrunner motor-Turnigy SK3-

3530·1340KV. 

• 40 plus amp brushless speed control with 

3.5mm female bullet connectors. (Turnigy 

Plush 40) 

• APC 9x4.5E electric propeller. 

• Servos (2) Spektrum A5040 or Corona 

OS329MG. 

• PixHawk autopilot with airspeed sensor and 

telemetry radios. (30R or HKPilot). 

• Spektrum transmitter with Elevon/Delta 

mixing and satellite receiver. (Taranis or 

Futaba with S.Bus are fine) 

• 6000 mAh 3S LiPo battery 

• Male and female XT60 connectors. 

• LiPo battery charger 

• Canon Powershot S110 

• Pixhawk to Canon camera trigger cable. 

(tuffwing.com) 

1. Fit the black Coroplast center cut filler into the 

cut on the EPP center wing. 

2. Align the parts by sliding the 10mm x 30.75" 

carbon fiber spar through the parts. 

3. Apply CA to both sides of the coroplast center 

cut filler. Avoid getting CA on the center spar. It's 

just there for alignment. Press the parts together 

and CA accelerator on 

4. scuff both sides of the 4mm 

Coroplast center wing ribs. 

5. Apply medium CA to coroplast center rib side 

facing the foam. Do not glue spars. 

6. Spray CA accelerator on the foam. 

7. Align rib using leading edge and center spars, 

then press pieces together. 

8. install both center wing ribs. Do not glue spars. 

/ 

Slide a wing half onto the center spar. Leave a 1" 

gap. 

10. Apply CA to foam. 

11 . Spray CA accelerator on the Coroplast center 

rib. 

C 2015. Tuf!Wing LLC. All rights reserved. 
flush with wing root, then push wing root 

flush with center rib. Align pieces by pushing 

leading edge spar all the way into the center 

section. 

2. Press pieces together tightly until CA cures. 

Do both wings. 

3. Liberally drip medium CA into leading edge 

and center spar grooves. Spray with CA 

accelerator. 

Glue Coroplast to center section 

Note camera lens opening right of center while 

plane is upside down. 

1. Test fit the Coroplast main center section so the 

camera circle is offset right when looking at the 

bottom of the plane - see photo. 

2. Lay the wing upside down. 

3. Liberally apply medium CA to the foam center 

section. 

4. Spray Coroplast center wing panel wrap with CA 

accelerator. 

5. Carefully and quickly align Coroplast center 

wing panel wrap with motor mount opening and 

Coroplast center wing ribs. 

6. Press until theCA cures. 

center section. 

13. Spray Coroplast top center wing panel wrap with 

CA accelerator. 

14. Carefully and quickly align the Coroplast top 

center wing panel with motor mount opening 

and Coroplast center wing ribs. Press very 

firm until CA cures. 

accessory on wing. 

Panel with hole goes on right wing. 

16. Line up V-notch on panel with V-notch cut on 

root end of wing. See red circle in photo above. 

17. Scuff bottom side of Coroplast with fine 

sandpaper. 

18. Liberally apply CA to bottom side of coroplast. 

Spray CA accelerator on foam . Align and firmly 

press Coroplast to wing. 

= 2015. Tuf!Wing LLC. Al1 rights reserved. 2 
1. Poke hole in foam 

Coroplast panel. The hole lines up with the 

servo wire groove below. 

2. Feed Pixhawk ann switch wire through hole and 

into the main bay. 

Glue control horn 

1. Drip medium CA into the control horn gap. 

2. Quickly press the control horn into the gap. 

3. Spray with CA accelerator. 

4. Do both sides. 

Glue servo base cover 

1. Apply medium CA on the foam wing 1/2" 

wide around the perimeter of the servo 

cutout hole. 

2. Spray CA accelerator on the servo cover. 

3. Leave a 1/4" gap between the two cut outs 

to allow the servo lead to pass through. 

4. Do both sides 

medium CA to the 

mount plate. 

2. Spray CA Accelerator on the wing top. 

3. Line up the servo mount plate and press firmly. 

4. Do both sides. 

1. quick connect on tip 

of the wing as shown. Press the black nylon 

washer on with pliers. 

Install the Servos 

1. nstall a Spektrum A5040 servo in each servo 

mount plate as shown. 

2. Install the pushrod into the second hole from the 

end. 

3. Important! Use thread lock on the servo arm 

screw after you have centered it. 

C> 2015. TuflWing LLC. All rights reserved. 3 
Connect servo extension. 

Tuck servo extension into groove on wing 

bottom. 

6. Push wire through opening into electronics bay. 

7. Tack servo extension to servo groove with hot 

glue. Do not use CA as it will be too permanent. 

Glue the Winglets 

Scuff surface of wing let with fine sandpaper that 

will be glued to the wing tip. 

2. Apply medium CA to a wing tip. 

3. Spray winglet with CA accelerator. 

4. Align front and bottom edges, then firmly press 

together until CA cures. Do both sides. 

Build the motor mount 

1. Glue the sides on with medium CA 

2. Glue the top and bottom with medium CA 

Test fit the motor mount 

of the plane. 

4. Apply medium CA to the motor mount where it 

will contact the plane. Do not us CA accelerator. 

5. Quickly and firmly push the mount in place. Do 

not hesitate as the CA may grab before the 

mount is properly set. 

Install the motor 

1. Install the X mount and prop adapter. Included 

with the Tumigy SK3-3530-1340KV. 

2. Trim the shaft with a rotary tool from the back of 

the motor as seen in the photo. 

C 2015. TuiNVIng LLC. All rights reserved. 4 
3. Mount the motor to the motor mount with the 

four 3mmx8mm screws. 

with zip ties. 

Install Velcro 

Note: Install Velcro hooks on the plane and Velcro 

loops on the components. That way you can easily 

swap damaged components or airframe. 

1. Electronics hatch 

2. Airspeed pilot 

1. Velcro to bottom of components. 

2. Stick components to as shown in previous 

drawing. 

3. Setup the Pixhawk as described at 

http:/lplane.ardupilot.com. 

Center of Gravity 

There is balance hole on the bottom of the Coroplast 

hatch. As long as the plane balances or falls forward 

you're good. Tail heavy will be nearly impossible to 

fly. Nose heavy is fine. Add nose weight for first 

flights without camera. 

Set the control throws 

• 5/8" up 

• 5/8" down 

• Move stick right: Right eleven up, left eleven 

down 

• Move stick left: Left eleven up, right eleven 

down 

• Move stick forward: Both elevens down 

• Move slick back: Both elevens up 

C 2015. Tuf!Wing LLC. All rights reserved . 5 
2. Connect your telemetry radio to a USB port on your PC. 

3. Connect your battery to your UAV Mapper. Do not arm your UAV Mapper. 

4. Start Mission Planner and select the CONNECT button on the top right. 

Note: Complete instructions with trouble shooting. 

Calibrate your compass 

You must recalibrate the compass each time you move your UAV Mapper to a new flight location. /p> 
1. Start Mission Planner, Connect your UAV Mapper to Mission Planner and select Initial Setup> Mandatory H; 

2. Select Pixhawk/PX4, then select Live Calibration. 
3. Select Rotate with each data point and Use Auto Accept. 

4. Rotate your UAV Mapper on all axes until the calibration completes. The final offsets will be displayed (3 nun 

below 250 then you can assume they are good. 

Note: Complete compass calibration documentation. 

Flight modes 

The UAV Mapper is preprogrammed with 3 flight modes- Stabilize, Auto, and Return to Launch (RTL). Flight modes i 

other switches are disabled. 
• Stabilize - Standard RC control with simple stabilization. If you let go of the sticks your UAV Mapper will auto 

• Auto - Your UAV Mapper will follow the waypoints in the mission you have setup and uploaded to the Pixhav 

• RTL (Return to launch)- Your UAV Mapper will return to the location and loiter at 100 meters above where C 

Always connect your UAV Mapper battery where you want it to return. 

Transmitter control check 

Place your UAV Mapper on a level surface, turn the transmitter on, select Stabilize on your transmitter flight modeS' 

press the Arm button. 

Left stick back: Motor off. 
Right stick forward: Both elevens move 5/8" (16mm) down. UAV Mapper pitches down. 

Right stick back: Both elevens move 5/8" (16mm) up. UAV Mapper pitches up. 

Right stick right: left eleven down 5/8" (16mm), right elevon up 5/8" (16mm). UAV Mapper rolls right. 

Right stick left: left eleven up 5/8" (16mm), right eleven down 5/8" (16mm). UAV Mapper rolls left. 

Autopilot response check 
Roll UAV Mapper left: Left elevon down, right eleven up. 

Roll UAV Mapper right: Left elevon up, right elevon down. 

Pitch UAV Mapper down: Both elevons up. 
Pitch UAV Mapper up: Both elevons down. 

Landing site requirements 

The most challenging part about flying a UAV Mapper, or any fixed wing UAV is getting it down. Unlike Pixhawk guide 

fixed wing. A copter can descend straight down, while a fixed wing must approach on a clear glide slope. If you are m 

landing pattern using Mission Planner and upload it to your UAV Mapper. First, make sure your flying site meets the 

create the takeoff and land shown mission below. 

Minimum Size Landing Site 

600 fl (180m) berween approach waypomt and landing waypolnt O'Jer shoot 200 ft (60 m) 

Create a take off and land mission 

1. Start Mission Planner and select Flight Plan. 
2. Click on the map to create WAYPOINT 1. 
3. Click on the map again to create WAYPOINT 2. 

4. Right-click on the map and select Takeoff. Enter lOO(m) for takeoff altitude. Enter 30 (degrees) for takeoff p 

5. Use the Up button to move the TAKEOFF waypoint to the top. Verify Pitch Angle is 30 and Alt is 100. 

6. Set WAYPOINT 2 Altitude to 35m. This is your approach waypoint. 
7. Set WAYPOINT 3 to LAND and Alt to 0. 

8. Select WriteWPs to copy the mission to your UAV Mapper 

IMPORTANT: Any mistake in this mission will result in a crash. You must understand every step of this process. This i! 

the air and safely back to the ground. 

Power up and check LED status. 

Turn on your transmitter and set your flight mode switch to Stabilize. Connect your UAV Mapper battery. The UAV IV 

hole so you can see the Pixhawk status during boot up. Be sure to power up where you want your UAV Mapper to loi 

- - · · Pixhawk is booting up. 

--··Error. Most likely the Pixhawk Micro SO was removed to retrieve the flight log and not replaced. 

eeeePixhawk is waiting on GPS lock. Do not fly until green. 

••• Failsafe error. Do not fly. 

·---Pixhawk has GPS lock and is ready to fly. 

Fly your UAV Mapper 

1. Move to a spot in your flying field with 400ft. (120m) of clear space ahead, into the wind. 

2. Set your transmitter to Stabilize mode, make sure the throttle is down, and press the arm button until its sol 

3. Hold your UAV Mapper like the photo below. Be prepared for the motor to start full throttle. 

4. Have a helper switch the flight mode switch to Auto. This will execute the waypoint mission you have upload 

The propeller will spin immediately. Be prepared. There is no delay. The motor will remain full throttle until take c 

changed to Stabilize. 
5. Pitch and roll your UAV Mapper to make sure control surfaces are properly moving. 

6. Face into the wind and hand launch your UAV Mapper as shown above. The toss should be a few degrees abc 

Note: You can stop the motor and abort the takeoff by switching the flight mode switch to Stabilize. 

Creating aerial photography missions 

Aerial photography missions are trivial once you've mastered takeoff and landing missions. Here's a typical UAV Map 

1. Start Mission Planner, select Flight Plan, right-dick on the map and select Draw Polygon> Add Polygon Poin 
2. Add additional Polygon points to create a border around the area you want to photograph. 

3. Right-click on the map and select Auto WP >Survey (Grid). 
o Flying Speed & Use flying speed: Leave unchecked. If checked it will override the default flying speec 

o Add Takeoff and Land WP's: Check 

o Use RTL: If you need to Auto-land, then leave unchecked. If you prefer to have your UAV Mapper Ret 

complete and land manually, then check. 

5. Select the Grid Options tab and set the following 

o Overshoot [m]: to 80 on both ends. Your UAV Mapper can't turn tight enough to get back on the line 

o Start From: Set this to the furthest downwind corner of your survey area. You want your UAV MappE 

while flying cross wind. This keeps the ground speed low and turns tighter. 

o Overlap(%] 80. This sets how frequently the shutter is triggered. 

o Side lap [%) 80. This sets how close the flight lines are. 

6. Select the Simple tab and then Accept. 
7. Modify takeoff and landing 

o Update TAKEOFF parameters. Pitch angle should be 30 and Alt must be at least 100. 

o You must have an approach WAYPOINT, 35m Altitude, 600ft. (120m), down wind, from your LAND" 

waypoints and use the Up Down arrows to move the waypoints. 

o Note the waypoint command DO_SET_CAM_TRIGG_DIST. It is set to 21.9 in the image above. The Pi 

every 21.9 meters. 

8. Select Write WPs to copy the mission to your UAV Mapper . 

.Taking pictures l 

iThe UAV Mapper includes a Canon 5110 loaded with CHDK and KAP UAV Exposure Control Script on it's SD card. The 

:trigger the Canon 5110 through a special trigger cable. Do the following to take pictures with your UAV Mapper: 

I 
1. Lock your SD card and insert it into the camera. 

2. Insert the camera trigger cable into the Mini USB port on the side of your camera. 

3. Turn your camera on. 

4. Press the blue Play button to load the KAP UAV Exposure Control Script. 

5. Half press the shutter to start the KAP UAV Exposure Control Script. 
6. Your camera is now waiting on a USB signal from your Pixhawk. It will send a signal while it's flying after the l 

7. Always check your camera trigger system before you fly. Go to the FLIGHT DATA screen in Mission Planner. F 

NOW. If everything is setup correctly your Pixhawk will trigger the Canon camera to take a picture and is cap 
see https:Uqithub.com/PX4/Hardware for further information and a copy of the license.