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April 7, 2015

Attention: United States Secretary of Transportation

Mr. Anthony R Fox

120 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 1 of the Federal

Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.13 (a) & (b); 91.7

(a); 91.9 (b) (2); 91.103 (b); 91.109; 91.19; 91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a)

(2); 91.417 (a) & (b)

Dear Mr. Secretary,

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

and 14 CFR Part 1, Innovative Imaging and Research (I2R), a research developer and operator of 

Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for 

environmental site monitoring, emergency response, and UAS imaging research hereby applies 

for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its sUASs (Multi-Rotor), so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1)

limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to

the above mentioned application areas currently using conventional aircraft to gather image data. 

Approval of this exemption would thereby enhance safety and fulfil the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the 

safe operation of such aircraft systems in the national airspace system.” Section 333 (c) of the 

Reform Act.
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The name and address of the applicant is:

Innovative Imaging & Research (I2R)

Attn: Richard Brown

Phone: 228-688-1236

Email: rbrown@i2rcorp.com

Address: Bldg 1103 Suite 140C

Stennis Space Center, MS 39529

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.13 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)
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This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 

333 (a) through (c) of the Reform Act. This directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the national airspace system

(NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of UASs do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of 

the following:

The UAS’s size, weight, speed, and operational capability: 

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

Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers. 

Reform Act §333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely 

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

of such aircraft in the national airspace system.” Id. §333 (c).

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

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate. The Administrator may grant an exemption from a requirement 

of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 

of this title if the Administrator finds the exemption in the public interest.

49 U.S.C. §44704; 14 CFR §91.203 (a) (1).
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I2R’s sUASs are rotorcraft weighing 20 or fewer lbs. including sensor payload. The rotorcraft

are operated, under normal conditions at a speed of no more than 30 knots and have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. They will

manually operate only in VLOS and will operate only within the sterile area described in the 

Standard Operation Procedure (SOP) attached in Appendix C. Adherence to the SOP will insure 

that the sUAS will “not create a hazard to the national airspace system or the public.” 

Given the small size and weight of the sUAS involved and the restricted sterile environment

within which they will operate, the applicant falls squarely within that zone of safety (an

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption,

allow commercial operations of UASs to commence immediately. Also due to the size of the

UASs and the restricted areas in which the relevant sUAS will operate, approval of the

application presents no national security issue. Given the clear direction in Section 333 of the

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong

equivalent level of safety surrounding the proposed operations and significant public benefit

in the proposed operational usage including enhanced environmental awareness, enhanced 

emergency response capability, and associated societal benefits arrived at through research 

initiatives performed by I2R that support those two areas, the grant of the requested

exemptions is in the public interest. Accordingly, the applicant respectfully requests that the

FAA approve the requested exemption.
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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations to the already safe environmental 

monitoring and emergency response operations conducted with conventional aircraft. These

limitations and conditions to which I2R agrees to be bound when conducting commercial 

operations under an FAA issued exemption include:

1. The sUAS will weigh less than 20 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew 

(Observer). Automated mission flight segments may be pre-programmed and activated by the 

Pilot while still maintaining VLOS.

3. Maximum total flight time for each operational flight will be less than 30 minutes. Flights will

be terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL in the area where airborne 

data collection is planned.

5. Minimum two (2) man crew for each sUAS operation will consist of the Pilot and Observer. 

6. The sUAS Pilot will have passed an FAA private pilot’s knowledge test and second class

medical. The Observer will not be operating the aircraft but the PIC will ensure that the Observer 

can perform the VLOS requirements of operations.

7. The sUAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder other than 

the sUAS Pilot, who possesses the necessary PIC qualifications, is also present on location, that 

person can also be designated as PIC.

8. The sUAS will only be operated by the PIC within a confined “Sterile Area” as defined in the 

SOP.

9. A pre-flight briefing will be conducted in regard to the planned sUAS operation prior to each 

day’s flight activities. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing.

10. Pilot and Observer will have been trained in operation of sUAS generally and received up-todate information on the sUAS to be operated.

11. The Observer and Pilot will at all times be able to communicate by voice or radio/cell phone.

12. Any required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

13. If the sUAS loses communications or loses its GPS signal, the sUAS has a failsafe enabled to 

return to a pre-determined location within the Security Perimeter and land.

14. The sUAS will have the capability have its flight aborted in case of unpredicted obstacles or

emergencies that are observed by the Flight Crew.
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14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a)(1)

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

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

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f) and Section 333 

of the Reform Act both authorize the FAA to exempt aircraft from the requirement capability, 

and proximity to airports and populated areas of the particular UAS. 

Safety Mitigation:

The sUASs selected by I2R are safe when taking into account their size, weight, speed, 

and operational capability. The sUASs weigh less than 20 pounds and will be flown at 

less than 30 miles per hour and outside controlled airspace unless prior permission is 

granted by controlling agency. Additionally, the sUASs carry neither pilots nor 

passengers, carry no explosive materials and or flammable liquid fuels, and operate

exclusively within the parameters stated in the Operator’s Manuals and SOPs.

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

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

I2R will also provide the FAA with advance notice of all operations via communication 

with the nearest airport ATC. In all cases, the sUAS operated under the proposed 

conditions, will be at least as safe as, or safer than conventional rotorcraft operating with 

an airworthiness certificate without the restrictions and conditions of the proposed UAS 

operations.

14 CFR §45.23 (B): Marking of the Aircraft

The regulation requires:

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.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word

“Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be

impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29

(f).

Safety Mitigation:

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by §45.29 (f) where those working with the sUAS will see the 

identification of the UAS as “Experimental.” The FAA has issued the following

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
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14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations - Pilot in Command 

(PIC)

Sections 61.113 (a) & (b) limits 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 PIC operating the aircraft to have a private

pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a

conventional aircraft that carries the pilot and passengers, the sUAS 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 Manual. The level of safety provided by

the requirements included in the SOP exceeds that provided by single individual holding a

commercial pilot’s certificate operating a conventional aircraft. The risks associated with

commercial operations contemplated by Part 61 when drafted, that allowing operations of the

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

by 14 CFR §61.113 (a) & (b).

Safety Mitigation:

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

airspace and communication issues pertaining to all aircraft operators but also in the

unique aspects of UAS flight. The PICs of I2R will have successfully completed ground 

pilot school. I2R will require any PIC to have at a minimum completed private pilot’s 

ground school, pass a FAA private pilot’s knowledge test and adhere to the SOP listed in

Appendix C.

We find that the combination of aeronautical knowledge, UAS airmanship skills through 

regular flight time logged, and verification through remaining current is a sufficient 

method to evaluate a pilot’s qualifications, given that operations will be conducted within 

the limitations outlined in this petition.

14 CFR §91.7 (a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the SOP for maintenance and use 

of pre-flight safety check lists prior to each flight, an equivalent level of safety will be provided.

The UASs to be operated by I2R are safe when taking into account their size, weight, speed, and 

operational capability. The UASs weigh less than 20 pounds and will be flown at less than 30 

miles per hour and outside controlled airspace unless prior permission is granted by controlling 

agency. Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials 

and or flammable liquid fuels, and operate exclusively within the parameters stated in the 

Operator’s Manuals and SOPs.

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

Reform Act that the UAS selected provides an equivalent level of safety when compared to 
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aircraft normally used for the same application. (Regulatory Docket No. FAA-2014-0352). 

These criteria are met, and therefore no exemption is needed.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides:

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 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.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual

on the aircraft, not only because there is no pilot on board, but because there is no room or

capacity to carry such an item on the aircraft.

Safety Mitigation:

An equivalent level of safety will be provided by following the SOP and pre-flight 

checklist. The PIC will take all required preflight actions - including performing all 

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

and takeoff distance, aircraft performance data, and identifying safe landing areas -

before initiation of flight. 

The equivalent level of safety will be maintained by keeping the checklist and SOP at the 

ground station with the operators at all times where the pilot flying the sUAS will have 

immediate access to it. The FAA has issued the following exemptions to this regulation: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

32827, and 10700.

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. 

Safety Mitigation:

An equivalent level of safety will be provided by following the SOP and pre-flight 

checklist. The PIC will take all required preflight actions - including performing all 

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

and takeoff distance, aircraft performance data, and identifying safe landing areas -

before initiation of flight. 

14 CFR §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. sUASs and remotely piloted aircraft, by their design do not have fully functional dual
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controls. Flight control is accomplished through the use of a handheld remote control (RC) 

transmitter that communicates with the aircraft via radio communications. The FAA has 

approved exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. 

Safety Mitigation:

Given the size and speed of the UAS employed by I2R, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are 

aboard the UAS and all persons will be at a safe distance away in the event that the UAS 

encounters any difficulties during flight instruction. In addition, we will conduct flight 

training at local Academy of Model Aeronautics (AMA) fields or other approved 

locations. These training flights will be conducted in full compliance with AMA field 

safety and operational rules. The FAA has stated (Regulatory Docket No. FAA-2014-

0352) that no exemption is required. Also see Exemptions Nos. 5778K & 9862A.

14 CFR §91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. The 

UAS will never operate at higher than 400 ft. AGL. 

Safety Mitigation:

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as location where it is operated. No flight will be taken without the permission of 

the property owner or relevant authorities. Because of the advance notice to the property 

owner and participants in the activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft

weighing far more than the maximum 55 lbs. proposed herein and the lack of flammable

fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 ft. AGL. In order to avoid any risk to 

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

UAS operations, all persons not essential to flight operations (nonparticipating persons) 

shall remain at appropriate safe distances away from the planned flight zone. If a 

situation arises where nonparticipating persons enter the planned flight zone of the UAS, 

flight operations shall cease immediately by the PIC activating a Return To Launch 

(RTL) command to bring the UAV back to the launch area.

In addition, the low-altitude operations of the sUAS will ensure separation between these 

small UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119.

14 CFR §91.121: Altimeter Settings

This regulation 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.” 
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Safety Mitigation:

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

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

altitude information relayed in real time to the operator. See Grant of Exemption to

Astraeus Aerial, Docket No. FAA-2014-0352. As the attached Operations Manual

indicates, the chosen UAS meets these requirements, and a zero altitude initiation point

will be obtained prior to flight.

The Ardupilot Hexacopter has both a barometric altimeter and a GPS altitude capability 

for dual comparative knowledge of altitude for both flight and position reporting via 

telemetry to the Ground Station. An equivalent level of safety will be achieved by the 

operator, pursuant to the SOP and Preflight Check list, confirming the altitude of the 

launch site shown on the Mission Planner “Home Location” before the flight. Setting the 

Home location is part of the standard procedure for all missions flown as it sets the 

latitude, longitude, and altitude of the launch point as “Home” for the mission. The 

default altitude setting in Mission Planner is “Above Ground Level”.

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) 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 battery powering the sUAS provides approximately 12-20 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be impossible.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30

minutes or 25% of operational battery power whichever happens first. A highly audible low 

battery alarm is attached to the sUAS as per the SOP before each mission that alerts the pilot to 

this low battery condition and provides ample opportunity for the Pilot to safely land the vehicle. 

A remaining battery power level is also transmitted to the ground station HUD via telemetry 

during flights to provide the Observer with real time knowledge of power levels. These 

monitoring controls along with the limiting restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its limited operating area. Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808.

Safety Mitigation:

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

terminated with at least 25% reserve operational battery power still available. I2R is not 

seeking an exemption to fly at night. See Grant of Exemption to Astraeus Aerial, Docket 

No. PAA-2014-0352. The Operations Manual conforms to this limit, providing an 

equivalent level of safety.
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14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and

Registration

The regulation provides in pertinent part:

(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 (b) 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.

Safety Mitigation 

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the Pilot flying the sUAS will have immediate access to them; to the 

extent they are applicable to the sUAS. The UAS fully loaded will weigh no more than 

20 lbs. and is operated without an onboard Pilot. As such, there is no ability or place to 

carry certification and registration documents or to display them on the sUAS.

The FAA has issued numerous exemptions to this regulation. A representative sample of 

other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 

9816A, and 10700.

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given 

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

sections will not apply to the applicant. Maintenance will be accomplished by the operator as 

identified in the pre-flight checklist and SOP as referenced to the Manual.

Safety Mitigation

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

be performed in accordance with the Operators Manual. As provided in the Operators

Manual, flights will not be conducted unless a pre-flight operations checklist is 

performed that includes all of the aircraft's components. 

An equivalent level of safety will be achieved because the I2R sUAS is very limited in 

size and will carry a small payload and operate only in controlled areas for limited 

periods of time. If mechanical issues arise the UAS can be landed immediately and will 

be operating from no higher than 400 ft. AGL. As provided in the Manual, the operator 

will ensure that the UAS is in working order prior to imitating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. 
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Summary of Exception Request:

Pursuant to 14 CFR Part 1, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed.

Applicant seeks an exemption from the following rules:

14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.13 (a) & (b); 91.7 (a); 91.9 (b) (2);

91.103 (b); 91.109; 91.19; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407 (a) (1);

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (20lbs or 

less) in support of environmental monitoring and emergency response imaging operations.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior

consent and knowledge or over public lands with permissions received from public agencies.
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Appendix A UAS Photos and Specification Sheets

Specifications:

MODEL: Ardupilot Hexacopter

MANUFACTURER: RCT800 frame/3DRobotics (Ardupilot flight control system)

DISTRIBUTOR: Innovative Imaging Research (I2R)

TYPE: Multi-rotor: Hexacopter

FRAME DIAMETER: 800mm

READY-TO-FLY WEIGHT: 7lbs 8oz (with Canon camera and 1 4S 6000mAh battery)

RADIO: 6 channel minimum, 8+ channels recommended and used (Spektrum DX-8)

BATTERY: 14.8V 4S 6000 mAh LiPo (1 or 2 in parallel for total 12000 mAh)

FLIGHT TIME: 12-20 minutes

Gear Installed:

RADIO: Spektrum DX-8; 2.4 Ghz; 8 channel remote radio controller

MOTORS: (6) HP4215 630KV brushless motors

ELECTRONIC SPEED CONTROLLERS: Turnigy Plush 40A ESCs

PROPELLERS: (6) T-Motor 15x5 carbon fiber

BATTERY: (2) Turnigy Nano-tech 4s 6000mAh 25-50C discharge rate

AUTOPILOT: 3DR Ardupilot 2.6 APM flight controller

CAMERA MOUNT: I2R direct to frame

CAMERAS: Canon SX260 HS 12 MPixel (RGB and NGB models) 8.2 oz
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Ardupilot Hexacopter by I2R

Communications System Description

2.4GHz Data Link

 Link Type: Hexacopter to Ground & Ground to Hexacopter (Two-Way)

 8 Channel 

 Hexacopter Antenna: Wired Whip Antenna

 Controller Antenna: Omni-Directional

 Transmission Power (North America): 200mW (+19.25 dBm)

 Frame Rate: 11ms

 Receiver Resolution: 2048

 Modulation: DSM2 with DSMX spread spectrum 

technology 

 Frequency band: 2.4000 - 2.4835 GHz

 Certifications: CE, FCC

 Flight log recording to SD card on receiver

 Telemetry warning system

 Failsafe functions: Throttle, Battery, GPS and Ground 

Control Station

900mhz 3DR Data Link

 Link Type: Hexacopter to Ground (One-Way)

 Transmitter Antenna: Omni-Directional

 Transmission Power: 100mW (20dBm)

 Frequency hopping spread spectrum (FHSS)

 Built in error correcting code

 Transmits realtime location, flight dynamics readings, 

voltage readout, current draw, system health status

GPS

 GPS Used For: Position Hold, Location & 

Velocity Data

 Maximum Satellites Tracked 

Simultaneously: 16

 Position Update Rate: 4 Hz

 GPS Antenna: Ceramic Patch

 Battery Backup: 75mAh Lithium Polymer
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Mission Planner Ground Control Station

The Ground Control System (GCS) is a laptop computer running MissionPlanner software and a 

handheld Spektrum DX-8 RC radio. The GCS is initially used for setup and 

calibration/configuration/testing of the flight controller, GPS, and motors on the Ardupilot 

Hexacopter. It is also used for configuration of flightmodes and failsafe response actions for 

low/loss of battery onboard or loss of signal from the radio. The GCS provides a multi-window 

view during flights consisting of a HUD display for realtime airframe action monitoring, a 

moving map display showing the location of the Arducopter at all times, and live flight dynamics 

readout from onboard sensors. Working through the GCS the pilot is also able to modify the 

programmed mission of the Arducopter in flight, but typically uses the DX-8 radio primarily. 

The HUD display of the GCS shows any mode changes enacted through the radio (eg. Switching 

from Loiter to Auto mode).Mission Planner heads up display (HUD) with live mission progress 

tracking on GoogleMap overlay on right.

Settable flight modes in Mission Planner that correspond to FMode and Gear 3-position switches 

on DX-8 RC controller/transmitter. These are pre-configured and tested for proper switching 

before flight.
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Appendix B UAS Manuals

I2R Mission Planning and Execution

1.0 Mission Planning in Ground Control System (GCS)

The Mission Planner GCS has many helpful utilities and tools for planning automated missions 

(Auto mission), especially for aerial ground photography. These Auto missions are initiated by 

putting the DX-8 controller Gear and Flap switches in the (1-0) position after flying in Loiter 

mode (1-1) to check the stability of hold and correct GPS operation prior to mission execution. 

NOTE: Before flying the first auto mission it is important that the hexacopter is properly 

setup, and has been flown a few times and there is confidence that everything is working 

correctly.

Begin by opening up the Mission Planner software that was previously used to configure the 

hexacopter. Connect the Ardupilot Mega (APM) flight controller board to the computer with the 

USB to USB micro cable so that the mission can be uploaded after completion and saved. Once 

you have connected by clicking the ‘Connect’ button at upper right, click on the ’Flight Plan’ tab 

to bring up the screen shown in Figure 1.

Figure 1 Flight Plan initial screen in Mission Planner
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1.1 Home Location

When the hexacopter is first powered up at the flying field, it will try to get a GPS lock. The 

Ardupilot flight controller will then save this position when it gets a GPS lock as the home 

location and mark it on the screen as ‘Home’. This home location is used as the reference point, 

and all the waypoint altitudes are relative to the home altitude. If the mission is being planned 

away from the flying site and there is no auto-set home position, clicking on the ‘Home 

Location’ text on the bottom right menu allows manually choosing a new home location by 

clicking in the map.

NOTE: Set the Home location carefully and with thought. This Home location is very 

important for automated Return to Launch (RTL) flight command and possibly some of 

the Failsafe defaults in Mission Planner. This is the place that the hexacopter will 

automatically fly back to if you enact an RTL command with your DX-8 radio controller or 

if one of the failsafe conditions such as loss of radio contact or “out of range” occurs. 

(These are all settable in Mission Planner’s CONFIG/TUNING tab when connected via 

USB to the hexacopter flight controller.)

1.2 Manually Adding Waypoints

The mission will be defined by a 

number of waypoints that you will add 

either manually or automatically to the

Flight Plan screen to define the Auto 

mission. To add a waypoint you simply 

need to click on the map.

Before starting to add waypoints, some settings may need to be changed located on the Waypoint 

interface at the bottom of the screen (Figure 2). Note: Default units are meters.

WP Radius - this is the distance around a waypoint that the hexacopter needs to be within, 

before it assumes the waypoint has been reached. If the wind picks up and keeps the hexacopter

from getting there, it will fight to attain that waypoint before moving on to the next. A minimum

4 m. (13 ft.) is recommended as the WP radius.

Figure 2 Waypoint entry table showing settings
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Loiter Radius - this is the radius of a circle that the hexacopter will loiter around if a loiter 

waypoint has been created. A minimum 3 m. (9.8 ft.) is recommended as the Loiter Radius.

Default Alt - this is the default altitude of a waypoint that you add. This should be set at the 

beginning so each waypoint you enter will not require you to enter a value each time.

To add your first waypoint, 

simply click on the map where 

you want it to be (Figure 

3). You will notice that on the 

bottom section of the screen, 

the waypoint table will show 

your recently added 

waypoints. To change 

waypoint parameters, simply 

click on the waypoint you want 

to change on the waypoint 

table, then change the desired 

parameters such as the 

altitude. The table column 

headings dynamically change depending on what type of waypoint you are using.

You can change the type of waypoint by selecting the dropdown box on the corresponding 

waypoint. There are many different types of waypoint commands that you can use with the 

hexacopter (Figure 4). However in this basic mission we will only be using the Waypoint, 

Condition, and RTL/Land commands.

Figure 3 Entering waypoints manually in Flight Plan mode
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There are three main types of commands that you will use initially, 

each of them are briefly explained below:

Waypoint Commands - these are traditional waypoints, and include 

points that can be flown to, points loitered around, take-off and landing 

waypoints

Conditional Commands - these are based on some condition, for 

example there can be a Condition_Delay command that will only 

execute the next command once the delay condition is met. The 

column next to the command usually allows typing in the value for the 

condition. (time in seconds, alt change, etc.)

RTL/Land Commands - these are commands that result in initiating 

either an immediate return to the launch point after the last waypoint or 

a land operation. It is good practice to always end each auto mission 

with an RTL command. The altitude of the final position of the RTL 

command is set in the Config/Tuning main menu option. If this 

altitude is set to zero (0), then the hexacopter begins a Land sequence 

immediately upon reaching the Home position. Landing protocol suggests however, that the Pilot 

switches to Manual (Stabilize) mode and lands manually once the hexacopter has arrived home. 

Manual mode allows a more controlled expedient landing.

1.3 Uploading a Mission

Once a mission plan has been completed and saved using the ‘Save WP File’ button on the right 

side menu, it can be uploaded to the USB connected hexacopter by clicking the ‘Write WPs’

button. After confirmation of upload onscreen, the hexacopter is now outfitted on its flight 

controller memory with an auto-mission that can be executed by a (1, 0) FMode/Gear switch 

setting on the DX-8 controller. 

Figure 4 List of possible 

waypoint command 

entries
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3DR Ardupilot Hexacopter: Communications/Lost Link Procedure

The laptop Ground Control Station (GCS) communicates to the aircraft via a 900mhz radio 

modem for telemetry. This allows the GCS Mission Planner Heads Up Display (HUD) to show 

realtime flight parameters including voltage readout, current draw, GPS status, flight mode, radio 

signal strength, and many other configurable system parameters that can be added and arranged 

on the HUD display screen. The HUD also graphically displays airframe orientation with respect 

to horizon along with a moving map display that tracks the location of the hexacopter as an icon 

positioned via live GPS coordinates sent via telemetry.

The Spektrum DX8 hand held transmitter controls for the Arducopter operate at 2.4 Ghz. (see 

Note below) The DX-8 communicates with the AR8000 receiver onboard the Hexacopter via 

their DSMX communications protocol. The AR8000 has an external satellite receiver unit 

attached for increased receiver reliability. Reboot times for this receiver after momentary power 

loss has been tested to be around 1 second. There is a TM1000 full range telemetry module 

onboard the Hexacopter as well that provides realtime flight log data, receiver voltage, flight 

pack battery voltage, RPM and temperature back to the ground control station.

Note: The Spektrum DX-8 transmitter/receiver system uses the new DSMX signal frequency 

management technology to combine both spread spectrum(DSSS) and signal hopping (FHSS) for 

a more reliable communications system than either alone. According to technical review 1 even 

if two DSMX systems find themselves transmitting on exactly the same part of the band at 

exactly the same time, the fact that they're also DSSS means that if each is using a separate 

spreading code, data will probably not be lost.

As of version 3.1 the Arducopter flight control firmware used on the onboard Hexacopter flight 

controller has four (4) failsafes: Throttle, Battery, GPS, and Ground Station Control.

The Throttle Failsafe will trigger if:

 The Hexacopter goes out of Spektrum radio range

 The transmitter is turned off.

 The receiver loses power for some reason.

 The channel 3 signal wire from the radio receiver to the APM flight controller becomes 

disconnected for some reason.

When a throttle failsafe is triggered one of the following will happen:

 Motors disarm – if in stabilize mode and the throttle is zero 

 Return to land (RTL) – if the pilot has GPS lock and is at least 2m away from home 

(launch) position

 

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 LAND – if the pilot has no GPS lock OR the Hexacopter is within 2 meters of Home 

when Failsafe triggers

 Continue with the mission – If the pilot is in AUTO mission mode. Default setting for 

this mode is “Enabled, continue_in_auto_mode”

 If the failsafe clears (throttle climbs back up to nominal levels) the Hexacopter will 

remain in its current flight mode active before the failsafe was triggered. 

The Battery Failsafe will trigger if:

 The battery voltage becomes low for more than 10 seconds

 The estimated current consumed passes your battery capacity

When a battery failsafe is triggered one of the following will happen:

 Motors disarm – if in stabilize mode and the throttle is zero

 RTL – if in AUTO mode, have a GPS lock, and area at least 2 meters from the home 

position

 LAND – in all other cases

The GPS Failsafe will trigger if:

 You lose GPS contact for 5 seconds while you are in AUTO, GUIDED, LOITER, RTL, 

CIRCLE, or POSITION mode. This will trigger a LAND command to the Arducopter.

Note: A LAND command will bring the Arducopter down to the ground at a set rate for a safe 

landing. It is essentially a slow throttle lowering.

A GPS failsafe event will occur if GPS 3D lock or the position “Glitches” for at least 5 seconds 

while the copter is in a mode that requires the GPS (RTL, Auto, Loiter, Circle, Position, Guided 

or Drift). The GPS failsafe response can be set to Land or switch to AltHold mode so that the 

pilot can retake manual control.

Without GPS updates, the inertial sensors allow approximately 10 seconds of accurate position 

information, but after this the horizontal position drift becomes so large that the horizontal 

position cannot be maintained at all. GPS failsafe enables here and either holds the copter in 

position or lands it. If held in position with Alt-hold, the PIC can take back control using

Stabilize manual flight mode.

GPS glitch protection has also been included in the latest version of the flight controller

firmware. GPS glitch protection can help alert the pilot to a bad GPS position, trigger a failsafe 

and reduce the incidents of fly-aways. Glitches are detected by comparing each new position 

update received from the GPS with a position projected out from the previous update’s position 

by a velocity estimate.
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The Glitch clears when the GPS position returns within the acceptable radius (or the radius 

expands to consume the GPS position). At this point the inertial navigation position is reset back 

to the GPS position.

The Ground Control Station Failsafe will trigger if set to do so and the GCS laptop is the primary 

means being used for flight control. This is NOT the case for the proposed operations as the DX8 radio controller is the Primary means of controlling the Arducopter and the GCS is used for 

monitoring of flight path, mission parameters, live system telemetry readings, and system health 

monitoring. The GCS Failsafe is mentioned here as a possible option in case of a need for GCSonly control.

As well as Flight System emergency failsafe functions, ground team personnel will operate under 

a set of emergency response guidelines and checklists to ensure readiness and personnel safety in 

adverse situations. 

A standard pre-, live, and post flight checklist will be employed for all flight operations with 

statements describing actions to take in identified emergency or system failure modes. A contact 

sheet with ATC, fire, and medical assistance numbers will be maintained at the ground control 

site.

A first aid kit will be available at all times along with a fire extinguisher and a large towel to toss 

over the hexacopter for propeller safing in the event of a disarm failure.
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Appendix C Standard Operating Procedures (SOP) and Pre-Flight Checklist

The Ardupilot hexacopter is intended to be operated from 0'AGL to no greater than 400'AGL. 

The procedure for a typical Launch and Recovery is described below and will be available:

Hexacopter Flight Checklist:

Make sure launch area selected is free of overhead obstacles within 50 feet. (trees, powerlines, 

buildings, etc.) Weather should be no rain predicted sustained winds below 15 knots.

1. Flight System check.

a. Check all motor mounts, propellers, and associated wiring for integrity and to see 

that they are securely attached and properly mounted.

b. Check center Flight control stack (Ardupilot board, GPS, telemetry units) for 

integrity (loose, frayed wiring or other). Replace control stack dome securely after 

check.

c. Attach and secure battery to undercarriage of hexacopter and connect battery to 

power control board lead. Listen for properly initiated ESC and motor sound 

cadence. (Short tune followed by single chirp.) If cadence is not correct or no 

cadence, then proceed to manual ESC bind and calibrate sequence.

d. Attach low battery alarm module to white battery monitor lead. Black wire goes 

to negative (-)

e. Power on flight control laptop with Mission Planner software.

f. If any Auto missions are to be flown, connect laptop via USB cable to the small 

USB port on the side of the Ardupilot board in the flight control stack. Hit the 

“Connect” button in Mission Planner to initiate tethered communication to the 

hexacopter.

g. Using the Mission Planner “Flight Planner” option, enter waypoints for mission 

and click “Write WPs” to upload the mission to the hexacopter.

h. Disconnect USB cable from hexacopter and laptop.

i. Connect USB 3DR radio control module into USB port on side of laptop.

j. Click the “Connect” button in Mission Planner to initiate remote telemetry and 

control.

k. Affirm that the left flight HUD screen has “Disarmed” on the screen.

2. Sensor system check.

a. Ensure camera batteries are charged.

b. Prepare camera to be flown on mission by checking for proper battery charge and 

application settings.

c. Initiate camera application and insert camera into holder or mount on the 

hexacopter making sure it is secure and all attach points good.

d. Place readied hexacopter system on flat clear dry launch area free of debris and at 

least 20 feet from pilot/observer ground station location.

3. Range check and Launch Sequence Initiation.

a. Announce that the hexacopter is ready for launch and ask for all eyes to check the 

range to make sure there are no personnel, manned vehicles, or other obstacles in 

the flight area.
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b. Make sure all switches on the DX-8 controller are forward (zeroed) and power on 

the DX-8. Make sure “Hexa” is visible in the DX-8 screen.

c. Ask authorized observer to monitor the Mission Planner software for any 

abnormalities and to confirm the arming status of the hexacopter.

d. Announce that the hexacopter is ready to be armed and launched.

e. Pilot gives secondary range clearance check.

f. Pilot holds left throttle stick DOWN and to the RIGHT for 3 seconds or more to 

arm the controller with the hexacopter. Observer confirms the system is armed, in 

Stabilize mode, and ready for takeoff.

g. The pilot performs takeoff by slowly raising the throttle and using the right pitch 

control to achieve nominal clearance from launch area. (30 feet elevation and 50 

feet out)

h. Pilot switches to Alt-Hold and/or Loiter to stabilize hexacopter in flight.

i. Flight crew observes hexacopter in flight for any functional anomalies. (abnormal 

noise, lack of position hold, mechanical issues) Land, fix, and re-test if anomalies 

identified.

j. Final check for range clearance.

k. Pilot performs manual flight mission or switches to Auto mode to perform pre-set 

mission through waypoint navigation.

l. If any weather, system, or hardware anomalies are detected, the pilot will state 

that the mission is aborted and either immediately land the hexacopter if visibly 

safe to do so or switch to RTL mode to bring the hexacopter back to the launch 

site for landing.

m. To land at completion of a successful mission, the hexacopter is brought back to 

the approximate launch site and placed into Loiter or Alt-Hold mode at 

approximately 30 feet elevation, switched to Stabilize mode and the throttle 

lowered to place hexacopter on ground.

n. Hexacopter is disarmed by holding the throttle stick DOWN and to the LEFT. 

Observer confirms that the Mission Planner is reporting a Disarmed state.

o. The DX-8 is placed on the ground out of the way and pilot goes to hexacopter to 

disconnect battery.

p. Mission is complete and system is safed. Pilot declares that hexacopter is safed 

and battery is disconnected.

At this point, the aircraft is either put away completing the mission or a new battery pack is 

installed and the same procedure is followed for take-off and continuation of the next mission at 

hand.

During flight, both the observer and PIC scan the sky and note any aircraft, aerial obstacles or 

weather that could cause a safety hazard. The vehicle will be landed immediately if any are 

identified. PIC constantly scans the ground station screen for telemetry data from the aircraft 

monitoring battery voltages, RF signal quality, altitude, attitude, and GPS data. 
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3DR Ardupilot Hexacopter Emergency Procedures

Emergency Assumption of Control

If there is any question that the UAS is no longer flying its programmed mission, the Pilot in 

Control (PIC) will take manual control of the aircraft and return it to the landing zone and land it 

under RC control.

If there is any question that any of the other RC selectable flight modes (loiter, altitude-hold) are 

not behaving as designed, the PIC will return flight mode to manual control (stabilize mode) and 

fly the UAS back to home base or switch to RTL(return to land) mode for automated flight back 

to home base.

There may be minor problems that do not require emergency assumption of control. (e.g. sudden 

wind gusts) In these cases the PIC can direct an autopilot landing or manually land the aircraft if 

needed.

If electrical power drops below operational minimum (10.3V for 11.1V 3S batteries; 13.6V for 

4S batteries), the PIC will initiate a mission abort procedure and immediately land. This is 

alerted both through the onboard low voltage alarm via a piercing tonal sound and on the HUD 

display of the ground control system (GCS).

Accident/Incident Notification 

If the UAS is lost, the field crew will attempt to locate the downed aircraft using the GPS 

telemetry log file automatically sent via telemetry to the GCS. This file can be accessed as a 

KML file in Google Earth to view the entire track of the UAS flight and locate the last known 

good location on the map. If the crew needs help, they will request help from base operations 

personnel via cellphone. If the aircraft is recovered, the crew will fill out the flight log, recover 

the onboard flight log file, and check with technical support for evaluation. The crew will write a 

detailed description of the event for I2R’s flight safety review and the FAA. The field crew will 

debrief I2R management of any abnormalities observed during flight operations and begin a 

system functional review when back at base. If a mechanical failure is identified, the crew will 

wait to hear from the technical support team and file a solution report with I2R management 

before returning to field operations.

If the UAS crashes and damages any property or anyone is injured the crew will assess the 

situation by:

 Maintaining personal safety in recovery effort

 Safe the UAS by throwing a towel over and disconnecting battery.

 Care for or request medical care for any injured parties. 

 Notify any applicable response agencies
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 Notify department management

 Write down exactly what happened and be ready to file a report with the department 

review committee and the FAA.

The Ardupilot Hexacopter operational discrepancies/mission anomalies will be written up in the 

aircraft flight log forms. Information will be passed to the department safety officer and the 

manufacturer if necessary. Minor repairs can be made in the field and noted in the aircraft flight 

log forms. It is possible due to the lightweight nature of these aircraft for very minor frame/prop 

damage to occur if a landing is harder than normal. If this occurs and there is no major structural 

damage, the Arducopter may be quickly adjusted/repaired and re-flown with usual first flight 

launch checks. These actions will be noted in the aircraft forms so general wear can be tracked 

and greater understanding of the aircraft characteristics will be understood.