29 June 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear Sir or Madam: 

Attached please find Swainston Digital Imaging's (SDI) request for an exemption from the listed 

Federal Aviation Regulations to allow commercial operation of Small Unmanned Aircraft 

Systems ("sUAS") for aerial imaging, safety surveys, forensic inspections, and law enforcement 

support. This exemption request is initially for the use of the "Inspire" sUAS manufactured by 

DJI, an established sUAS company. 

Also attached to this letter is the equipment SDI Flight Manual, which outlines the operating 

requirements, limitations, and technical specifications for the DJI Inspire sUAS System as used 

by SDI. SDI has reviewed this Manual and has found it to be acceptable for sUAS operations. 

Applicant submits this manual as a Confidential document under 14 CFR 11.35 (b) as the entire 

manual contains proprietary information that the applicant has not and will not share with others. 

The Manual contains operating conditions and procedures that are not available to the public and 

are protected from release under the Freedom of Information Act 5 USC 552 et. seq. 

Thank you for your time and consideration, and please let me know if you have any questions. 

Sincerely, ' / • _ _,_, ___ _ 

f;;sw~;o~ 

~_/~~ ,~ 

Swainston Digital Imaging 

President 

Cc File 

Enclosures 

Swainston Digital Imaging 
29 June 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation 

Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119;91.121; 9.151(a); 91.405 (a) (1); 

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

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) 

and 14 C.F.R. Part 11, Swainston Digital Imaging (SDI), an aerial photography and digital 

imaging company, on behalf of itself and its related affiliates under common ownership and 

control, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") 

to allow commercial operation of its Small Unmanned Aircraft Systems ("sUAS") for aerial 

imaging for video, still photography, forensic inspections, safety surveys, and law enforcement 

support, 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 detailed in this document and the attached Flight Manual, the requested exemption would 

permit the operation of sUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled and 4) would provide safety enhancements to the already best 

practices safety protocols followed by SDI during aerial photography and inspection operations. 

SDI is a member of the "Professional Aerial Photographers Association, International" (PAP A) 

and has a longstanding demonstrated record of safe operations in the National Airspace System 

(NAS). Principal employees have received Private Pilot ground school training and each have 

logged well over 25 hours of sUAS flight operations. Approval of this exemption would thereby 

enhance safety and fulfill 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. 

Swainston Digital Imaging 
The name and address of the applicant is: 

Swainston Digital Imaging 

1542 Little Dove Court 

Henderson, Nevada 89014 

Lane Swainston 

PH: 702-501-7555 

Email: lane@swainston.com 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 109 

14 C.F.R. 119 

14 C.F.R. 121 

14 C.F.R. 91.151 (a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.405 (a) 

14 C.F.R. 407 (a) (1) 

14 C.F.R. 409 (a) (2) 

14 C.F.R. 417 (a) & (b) 

I. STATUTORY AUTHORITY FOR EXEMPTIONS 

2 

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

authority includes exempting civil aircraft, as the term is defined under §40 101 of the Act, 

including 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) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator 

finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 

USC §44704; 14 CFR §91.203(a) (1). 

Section 333(b) of the Reform Act assists the Secretary in determining whether sUAS may 

operate in the National Airspace System (NAS) without creating a hazard to the user, the public, 

or a threat to national security. In making this determination, the Secretary must consider: 

• The sUAS's size, weight, speed, and operational capability; 

• Whether the sUAS operates within the visual line of sight of the operator 

Swainston Digital Imaging 
3 

+ Whether the sUAS operates outside of highly populated areas and away from 

close proximity to airports 

Reform Act §333(a). If the Secretary determines that a sUAS "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." !d. §333(c) 

SDI's sUAS are multirotor vehicles, weighing 20 or fewer lbs. including payload. They operate 

under normal conditions at a speed of no more than 70 knots and have the capability to hover, 

and move in the vertical and horizontal plane simultaneously. The sUAS will operate only in the 

PIC and Visual Observers visual line of sight at all times and will operate only within the 

designated area described in the Confidential SDI Flight Manual, attached as Exhibit 1 

(hereinafter "the Manual"). Such operations will insure that the sUAS will "not create a hazard to 

users ofthe national airspace system or the public." Reform Act Section 333 (b). 

Given the small size of the sUAS involved and the restricted and controlled environment within 

which they will operate, our application falls squarely within the zone of safety (an equivalent 

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

commercial operations of sUAS to commence immediately. Also, due to the small size of the 

sUAS, altitudes, and restricted areas in which the 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 the significant public benefit, including enhanced safety, the grant of the 

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

FAA grant the requested exemption without delay. 

II. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

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

consider whether certain unmanned aircraft systems may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. By granting an 

exemption the FAA will fulfill Congress's intent of allowing UAS to operate with significant 

safety precautions in low risk environments. 

The use of sUAS on aerial photography operations can significantly reduce the risk to 

photographers and participants. Also, sUAS can inspect, photograph, and collect data on hard to 

get to areas that otherwise would require direct access or manned aircraft. 

Additionally, sUAS could replace the use of helicopters and small aircraft to produce imagery 

for various purposes. The sUAS we propose to fly in this application are less than 20 pounds, 

and carry no combustible material on board, as opposed to the much larger conventionally 

powered small aircraft. Shifting to s U AS from helicopters and other manned aircraft presents a 

marked safety increase for our workers and the public. 

Swainston Digital Imaging 
4 

Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used for 

aerial imaging and data collection. The sUAS used by SDI use rechargeable lithium ion batteries, 

as opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times 

heavier. 

III. EQUIVALENT LEVEL OF SAFETY 

SDI proposes that the exemption requested herein apply to sUAS 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 under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe protocols 

followed on imaging, photography, safety surveys, forensic inspection, and law enforcement 

support operations conducted with helicopters and other conventional aircraft. 

SDI will be bound by the following limitations when conducting its sUAS operations under an 

FAA issued exemption: 

1. The sUAS will be less than 20 pounds. 

2. Flights will be operated within visual line of sight of a Pilot in Command. 

3. Maximum total flight time for each operational flight will be 20 minutes. The Pilot in 

Command calculates battery reserve, and will return the sUAS to the "Designated Safety 

Zone" with at least 20% battery power reserve should that occur prior to the 20 minute limit. 

4. Flights will normally be operated at an altitude of not more than 400 feet AGL, never 

exceeding 1200 feet AGL. 

5. Crew for each operation will consist of the sUAS Pilot in Command (PIC) who will keep the 

sUAS within his visual line of sight at all times and will be supported by a qualified Visual 

Observer (VO). 

6. The sUAS operator will be trained in flight operations, and safety procedures as detailed in 

the Flight Manual. 

7. The sUAS will only operate within a confined "Area of Operations" (AO) as defined in the 

Manual. The Manual also requires the establishment of a "Designated Safety Zone" (Safety 

Zone) for the preparation, takeoff, and landing flight operations area. 

8. A briefing will be conducted regarding the planned sUAS operations prior to each day's 

production activities. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the Safety Zone be present for this briefing. 

9. All onsite personnel will consent to the UAS flyover on site by waiver, and the operator will 

obtain additional verbal or written consent of all persons who will be allowed within 100 feet 

of the flight AO. 

10. Pilot in Command will have been trained in operation ofUAS generally and will have 

received up-to-date information on the particular sUAS to be operated as required by the SDI 

Manual. 

11. Necessary written and/or oral permission from the relevant property holders will be obtained. 

Swainston Digital Imaging 
5 

12. All necessary permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other appropriate government agencies 

as may be required. 

13. If the sUAS loses communications or loses its GPS signal, it will have the capability to enter 

"loiter mode" and hover, reestablish satellite connection, and return to a predetermined 

location within the "Designated Safety Zone" and land. 

IV. DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the Pilot in Command operating the aircraft to have 

completed a sUAS flight training course of25 hours before flying a sUAS (See the SDI Manual 

for details). Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is 

remotely controlled with no living thing or cargo on board. The area of operation is controlled 

and restricted per prior planning and necessary coordination with the local FSDO if applicable, 

and all flights are planned and coordinated in advance as required and as set forth in the SDI 

Flight Manual. 

The sUAS to be operated hereunder is less than 20 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a controlled Area of Operation as set out in the SDI Flight Manual. Like other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by the Pilot in 

Command, pursuant to the SDI Flight Manual requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the Area of Operation 

as is currently done by SDI on normal aerial photography operations. The FAA will have 

advance notice of all operations as may be required. 

The risks associated with the operation of the sUAS are therefore diminished from the level of 

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

operations of the sUAS as requested with an operator who has met the minimum requirements 

stated in the SDI Manual achieves the level of safety contemplated by 14 C.F.R. §61.113 (a) & 

(b). 

14 C.F.R. 91.103: Preflight Action 

This regulation requires each Pilot in Command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement as the PIC will take separate 

preflight actions, including checking for weather conditions, checking flight battery requirements, 

checking takeoff and landing distances, and all other actions in the Preflight Checklist in the SDI 

Manual. These actions will provide an equivalent level of safety. 

Swainston Digital Imaging 
6 

14 C.F. R. 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. This 

exemption is for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and 

vertical landing, which will typically operate at altitudes of less than 400 AGL, so an exemption 

may be needed to allow such operations. The sUAS will never operate at altitude higher than 

1200 AGL and will be in a controlled area with a "Designated Safety Zone", where buildings and 

people will not be exposed to operations without the specified pre-obtained consent. (See SDI 

Manual for detailed procedures.) 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well 

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

the property owner or local officials. Because of the advance notice to the property owner and 

any onsite personnel as outlined in the SDI Flight Manual, all affected individuals will be aware 

of the planned flight operations. Unlike flight operations with aircraft or rotorcraft weighing far 

more than the maximum 20 lbs. proposed herein, our sUAS will not carry flammable fuel. In 

addition, the coordinated operations of the sUAS will ensure separation between sUAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. 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." As the sUAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the SDI Flight Manual and Safety Check list, 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our 

sUAS is limited to operations in controlled environments as outlined in the SDI Flight Manual, 

and has a limited range and flight time which require an exemption from 14 CFR 91.151 (a) 

The battery powering the sUAS provides over 20 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, sUAS flights would necessarily be limited to a 

few minutes in length. Given the limitations on the sUAS's proposed flight area and the location 

of its proposed operations within a predetermined area, a longer time frame for flight in daylight 

or night VFR conditions is reasonable. 

SDI believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151(a)). Operating the small sUAS, in a controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, 

Swainston Digital Imaging 
with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, 

limiting sUAS flights to a few minutes would greatly reduce the utility for which the exemption 

will be granted. 

7 

An equivalent level of safety can be achieved by limiting flights to approximately 20 minutes, or 

enough battery reserve to ensure that the sUAS lands at the ground station with at least 20% of 

battery power (as determined by the onboard monitoring system and the PIC), whichever 

happens first. This 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. 

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in the 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 SDI. Maintenance will be accomplished by the Operator and 

pursuant to the flight manual and operating handbook as referenced in the SDI Flight Manual. 

An equivalent level of safety will be achieved because these small sUAS are 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 sUAS can land immediately and will be typically operating from 400 

AGL or less and no higher than 1200 feet AGL. As provided in the SDI Flight Manual, the PIC 

will ensure that the sUAS is in working order prior to initiating flight, perform required 

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

********* 

Pursuant to C.F.R. Part 11, 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 C.F.R. § 21, subpart H; 14 C.F.R. 

45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7 

(a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 

91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (55lbs or less) in aerial photography operations. 

Swainston Digital Imaging 
Approval of exemptions allowing commercial operations of sUAS in the aerial photography, 

safety surveys, forensic inspection, law enforcement support, and video industries enhances 

safety while reducing risk. Manned aircraft still photography, forensic inspection, law 

enforcement support and video creates a greater risk because the aircraft are much larger, have 

combustible fuel, and carry an onboard human crew. In contrast, a sUAS weighing fewer than 

20 lbs. and powered by batteries eliminates virtually all of that risk, given the reduced mass and 

lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights. 

8 

The operation of small sUAS, weighing less than 20 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a controlled environment and, as a result, are far safer than conventional 

operations conducted with turbine or reciprocating helicopters or full scale manned aircraft 

operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or public property with the necessary private property owner's 

prior consent and knowledge. Images taken will be of individuals who have also consented to 

being filmed or otherwise having agreed to be in the area where aerial photography, safety 

surveys, or forensic inspections will take place. 

********* 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012--size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security -provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant's sUAS in construction 

industry pursuant to the SDI Manuf!.l appended hereto. 

~~~-.e-<-- Lane Swainston 

Swainston Digital Imaging 

President 

Cc File 

Swainston Digital Imaging 
UAS Flight Manual 

Swainston Digital Imaging 

29 June 2015 

This manual contains standard operating procedures and guidelines for UAS operations. 
Swainston Digital Imaging 

UAS Operations Manual 

Table of Contents 

Purpose, Scope, and Mission Statement ............................................................. 5 

Definitions .......................................................................................................... 6 

Personnel Responsibilities .................................................................................. 8 

Visual Observer .................................................................................................... 8 

PIC ....................................................................................................................... 8 

Flight Team Composition ..................................................................................... 8 

Qualification Requirements ................................................................................. 8 

Operating limitations and Conditions ................................................................. 9 

Maintenance Procedures .................................................................................. 10 

Routine Maintenance ........................................................................................ 10 

Full Flight Test .................................................................................................... 11 

Software Firmware Update Policy ...................................................................... 11 

Logs and Records .............................................................................................. 12 

Pilot and Aircraft Hours ...................................................................................... 12 

Battery Logbook ................................................................................................. 12 

Flight Planning .................................................................................................. 13 

Weather ............................................................................................................. 13 

Site Permissions ................................................................................................. 13 

Pre-Flight Inspections and Checks ...................................................................... 13 

Documentation .................................................................................................. 14 

Pre-Flight Area and Personnel Checks ................................................................ 14 

Closed Set Operations ........................................................................................ 15 

2 
On-Site Procedures ............................................................................................ 16 

Site Survey .................................................................................................. 16 

Selection of Operating Areas and Alternatives ............................................ 16 

Boundaries .................................................................................................. 17 

Anemometer Weather Check ..................................................................... 18 

Crew Briefing .............................................................................................. 18 

Communications ......................................................................................... 18 

Frequency Scans ......................................................................................... 19 

Recharging and Battery Use {Fuel Management) ........................................ 19 

Load-outs and Equipment ........................................................................... 19 

Flight Procedures .............................................................................................. 20 

Motor Start ........................................................................................................ 20 

Take-Off ............................................................................................................. 20 

ln-Fiight .............................................................................................................. 21 

Let Down/Landing .............................................................................................. 21 

Shutdown .......................................................................................................... 22 

Emergency Procedures ..................................................................................... 23 

Motor Thrust Loss .............................................................................................. 23 

Battery Failure ................................................................................................... 23 

Battery Failure Failsafe ............................................................................... 24 

Transmitter/Controller Battery Failure ....................................................... 25 

Controller Battery Failsafe .......................................................................... 25 

Loss of Control Frequency .................................................................................. 25 

Loss of Control Frequeny Failsafe ...................................................................... 25 

Malicious or Accidental Interference with Control Frequency ........................... 26 

Pilot Incapacitation ..................................................................................... 26 

3 
Aircraft Incursion ........................................................................................ 26 

Fly Away Procedure .......................................................................................... 27 

Crash & Incident Response ................................................................................ 27 

Appendix A - Checklists ..................................................................................... 28 

Pre-Flight Start-Up Checklist .............................................................................. 29 

Pre-Flight Inspection Checklist ........................................................................... 31 

ln-Fiight .............................................................................................................. 32 

Landing Checklist ............................................................................................... 33 

Appendix B ....................................................................................................... 34 

Maintenance Logbook ....................................................................................... 35 

Appendix C ....................................................................................................... 36 

Incident/ Accident Logbook ................................................................................ 37 

Appendix D ....................................................................................................... 38 

Flight Record Logbook ....................................................................................... 39 

Appendix E ....................................................................................................... 40 

Inspire User Manual ........................................................................................... 41 

4 
PURPOSE, SCOPE, AND MISSION STATEMENT 

Swainston Digital Imaging (SDI), a member of the Professional Aerial 

Photographers Association, International (PAPA} intends as the Operator to 

promote safe operation of sUAS in the National Airspace System (NAS} in a 

manner that is consistent with a long history of safe and professional flight 

operations in close cooperation with the Federal Aviation Administration (FAA). 

The Operators are experienced professional aerial photographers and have 

completed private pilot ground school for rotary wing aircraft as well as 

approximately 40 hours of instructor supervised flight time. The sUAS Pilots in 

Command (PIC} that will operate systems according to the approach outlined in 

this Flight Manual of procedures (Manual) are trained in accordance with this 

Manual and have received at least 25 hours of UAS training combined with 

experience on conventional Aerial Photographic flight missions. 

The intent of the Manual is to provide the outline of a system to conduct safe and 

successful sUAS operations in accordance with the applicable FAA regulations and 

consistent with the section 333 waiver that this Manual is based upon. It is 

expected that the Operator will continue to apply the skills and experience they 

have employed in manned aircraft operations under FAA regulations. This 

combination of prior successful flight experience and sound sUAS flight 

operational procedures is intended to promote the highest levels of 

professionalism in safe aerial photographic flight missions. 

5 
DEFINITIONS 

The following definitions of words and terms apply to the information contained 

in this Manual and are specific to procedures and operations that are outlined 

herein. In the case of a conflict with an official FAA definition, the FAA definition 

will be the rule. 

Anemometer- An instrument to measure the velocity of the wind in the Area of 

Operations. 

Area of Operations- Defined as the area where sUAS operations will be carried 

out for a specific flight or series of flights on a given mission. 

Checklists- Procedural checklists used by the PIC to verify proper and safe 

procedures during all phases of sUAS operations. 

Designated Safety Zone- Defined and marked area of ground operations used for 

safe takeoffs and landings of the sUAS at a given Area of Operations. 

Flight Control Systems- The combination of telemetry, PIC operated controls, 

and on board control mechanisms that are employed to control the flight of the 

sUAS. 

Frequency Analyzer- A device used to scan the Area of Operations for possible 

interference from radio waves. 

GPS- Global Positioning System. 

Handheld Radio- A radio transceiver capable of communication with other Pilots 

or FAA personnel in the Area of Operations. 

Loiter Mode- A default recovery mode the sUAS goes into when communications 

are lost from the PIC. 

Maintenance Recommendations- Periodic maintenance recommendations for 

each of the sUAS components that have a usable life. 

6 
Manual- This flight manual that combines the Operator specific procedures with 

the sUAS manufacturers' manual. 

Manufacturers Recommendations- Written recommendations provided by the 

manufacturers of the various components of the sUAS. 

NAS- National Airspace System. 

Non Participants- Persons who have not agreed to participate in sUAS 

operations. 

Operator- The entity submitting as the applicant on this waiver request to the 

FAA who will be responsible for all sUAS operations and procedures. 

PAPA- Professional Aerial Photographers Association, International. 

Participants- Persons who have agreed to participate in sUAS operations. 

Pilot In Command- Person who will fly the UA during sUAS operations and who is 

responsible for all safety related or operational decisions under the direction of 

the Operator in accordance with this Manual and FAA requirements. 

SOP- Standard operating procedures. 

sUAS- Small Unmanned Aerial Systems as contemplated under the FAA 

guidelines, not to exceed 55 pounds in weight or 100 miles per hour in speed. 

Telemetry- Electronically transmitted data that provides control and information 

transmissions to and from the PIC and the sUAS. 

UA- Unmanned Aircraft. 

Visual Observer- An individual who is designated to observe flight operations and 

to maintain visual contact with the UA during flight operations while maintaining 

communications and coordination with the PIC. 

7 
PERSONNEL RESPONSIBILITIES 

VISUAL OBSERVER 

All operations will utilize a Visual Observer. The main responsibilities of the Visual 

Observer will be to ensure that the UA is operated within the visual line of sight of 

both the PIC and Visual Observer at all times. The Visual Observer will maintain 

verbal communication with the PIC at all times. Prior to flight, the PIC will ensure 

that the Visual Observer understands and can perform all the duties required of 

the Visual Observer. 

PIC 

Pilot in Command is responsible for the safe operation of the sUAS at all times in 

accordance with this Manual and the applicable FAA regulations. 

Pilot in Command will be responsible for: 

• All support personnel. 

• Performing all pre-flight, flight phase, and post flight inspections, air 

worthiness, diagnostics, and testing. 

• Manufacturer recommended maintenance operations. 

• Weather condition assessments and forecast reviews. 

FLIGHT TEAM COMPOSITION 

The onsite flight team is composed of a Pilot in Command (PIC} and a Visual 

Observer (VO}. The PIC is responsible for all flight operations and decisions to 

proceed. The VO is responsible to maintain visual contact with the UA and to 

provide constant communication with the PIC regarding aircraft status and 

surrounding conditions within the Area of Operations. 

QUALIFICATION REQUIREMENTS 

The PIC must be a licensed Commercial Pilot and must have completed the PAPA 

sponsored ground school with at least 25 hours of sUAS flight time. The VO must 

have completed sUAS ground school training and must demonstrate experience 

with FAA procedures and the standard procedures of this Manual. 

8 
OPERATING LIMITATIONS AND CONDITIONS 

Operational Ceiling- Maximum 1,200 ft AGL, typical400 ft AGL. 

Operational Endurance- approximately 20 minutes. 

Maximum Speed- 100 MPH 

Maximum Operating Temperature- 110 degrees F 

Minimum Operating Temperature - 0 degrees F 

Maximum Operational Wind Speed- 15 MPH (gusts to 20 MPH) 

9 
MAINTENANCE PROCEDURES 

Only SDI personnel or an appointed service technician may carry out maintenance 

on the sUAS aircraft systems described in this operations manual. In all cases a 

Maintenance Logbook (see Appendix B) is completed to reflect any work 

undertaken and a flight test, testing all functions (including the return-to-home 

failsafe facility), is subsequently carried out by the PIC. 

ROUTINE MAINTENANCE 

The Pre-Flight and Post-Flight checklists shown in Appendix A are completed by 

the PIC every time a SDI sUAS aircraft is operated. Every six months (or fifty hours 

of flight time- whichever comes first) the following inspection is carried out by 

the PIC. The inspection is recorded in the Maintenance Logbook along with any 

findings. Any issues identified are remedied and the aircraft undergoes a full 

flight-test before the aircraft is returned to Operational Status: 

• Inspection of the airframe for any damage, unusual marks and tightness of 

fixings; 

• Inspection of the motor mountings for correct tension; 

• Inspection of the propellers for condition, unusual marks, chips, cracks and 

tightness of fasteners; 

• Inspection of electrical wiring for condition, unusual marks or discoloration; 

• Inspection of electrical terminal fittings and plugs for secure attachment 

and general condition; 

• Inspection of the attachment of all fittings such as flight controller, G PS 

antennas etc. for secure attachment; 

• Inspection of payload attachment points for condition and security of 

payload; 

• Inspection of the condition and function of all ancillary equipment such as 

transmitter etc. 

• Testing of all system battery packs for charge status and general condition. 

If any issues or problems are identified then the aircraft is not allowed to fly until 

the issue has been remedied. If minor problems (such as damaged propellers, 

faulty battery packs etc.) are identified and remedied, and the PIC believes the 

aircraft is suitable to return to Operational Status then the work completed is 

noted in the Maintenance Logbook. If major issues are identified (such as an 

unserviceable motor, damaged airframe etc.}, then the aircraft undergoes a full 

10 
flight test regime (as described below), once the identified fault has been 

remedied. 

FULL FLIGHT TEST 

The system has all functions tested with a minimum of five minutes flight time by 

a qualified PIC recording any abnormalities in the Flight Record Logbook 

(Appendix D). If the PIC deems the aircraft to be safe then he must sign the Flight 

Record Logbook as fit for Operational use. Systems with identified issues relating 

to firmware or software (see below) are grounded by SDI until any problems are 

rectified. 

SOFTWARE AND FIRMWARE UPDATE POLICY 

All new software and firmware are thoroughly assessed before installation. 

Particular attention is focused on relevance to operations, reason for release and 

any known issues. Multi-rotor and UAS forums are consulted regularly for any 

reported issues with the release and only when the validity of the upgrade has 

been confirmed is the upgrade considered. 

In all circumstances the upgrade is performed by qualified SDI personnel or 

appointed service providers. All upgrade information such as version numbers 

and new functions are recorded in the Maintenance Logbook. All SDI PIC are 

made aware that the firmware or software has been upgraded before any flight 

operations are undertaken. 

Any upgraded system has all functions thoroughly tested with a minimum of five 

minutes flight time by a qualified SDI PIC who records any abnormalities in the 

Flight Record Logbook. If the PIC deems the aircraft to be safe then the PIC signs 

the Flight Record Logbook as fit for Operational use. If any doubts exist as to the 

new upgrade the aircraft is downgraded to the previous firmware and the flight 

test procedure is repeated. Systems with identified issues relating to firmware or 

software are grounded until the problem can be rectified. 

11 
LOGS AND RECORDS 

PILOT AND AIRCRAFT HOURS 

SDI PIC are required to keep a log of pilot and aircraft hours. 

To meet this requirement SDI holds and updates a spreadsheet-based Personal 

Flying Log Book for Aircraft Operating Crew. This log book is a separate document 

which can be viewed on request (see sample page at Appendix D). 

BATTERY LOGBOOK 

SDI Personal Flying Log Book (Appendix D) additionally records information about 

battery condition (charge) before and after each flight. The Battery Logbook is 

accompanied by- and supported with- SDIIncident Logbook (Appendix C) and 

Maintenance Logbook (Appendix B). 

12 
FLIGHT PLANNING 

WEATHER 

Operator will require PIC to obtain all necessary weather information in order to 

plan and conduct safe flight operations according to and as referenced by any 

applicable UA Operator Manuals. If operating near an operating Automatic 

Terminal Information Service {A TIS), the A TIS broadcast system will be consulted. 

If A TIS is not available, PIC will consult-alternative sources for a current weather 

forecast. 

The operating envelope for the Inspire has been referred to earlier. It is 

emphasized that the PIC is to ensure the operating envelope environment meets 

or exceeds all safe and legal visibility, precipitation, humidity, and wind limitations 

for safe operation. 

SITE PERMISSIONS 

• Secure permissions from property owner if required. 

• Secure permissions from participants. 

• Coordinate with local law enforcement if required. 

• Prior to operations, Operator receives permission for take-off and landing 

from the relevant land-owner. In most cases permission attainment is 

unproblematic as the landowner and the client are the same individual (or 

entity). In the case of local authority owned land, the relevant authority is 

contacted in advance to secure permission for take-off and landing, and to 

find out about any operating restrictions or specific insurance requirements 

that might apply. 

PRE-FLIGHT INSPECTIONS AND CHECKS 

Prior to each flight, the PIC will conduct a pre-flight inspection and determine if 

the UAS is in a condition for safe flight, and to account for all possible 

discrepancies or inoperable equipment. If the inspection reveals any condition 

that will affect the safe operation of the UAS, the aircraft will be prohibited from 

operating until the necessary maintenance can be performed and the UAS can be 

returned to safe flight. The preflight inspections will include the following 

components according to the recommended checklists in the DJI Inspire operator 

manual, and in the SDI checklist: 

13 
D Airframe 

D Battery 

D Transmitters 

D Camera and Gimbal 

D Propulsion system including propellers 

In addition, with the battery attached and turned on in the UAS, the PIC will 

oversee and monitor the series of diagnostic tests to determine and verify proper 

voltage levels, control function, communication, and GPS satellite connectivity 

acquisition. PIC will utilize the DJI Inspire LED indicators as well as telemetry data 

to determine if the proper preflight diagnostics have been completed. The PIC 

will also perform and log a pre-flight compass calibration each time the UAS is 

flown from a new location. 

DOCUMENTATION 

PIC will ensure that all documents used by SDI to ensure safe flight operations and 

any document required under 14 CFR 91.9 and 91.203 must be available at the 

Ground Control Station on site at any time the UAV is operating, and ready to be 

made available to any law enforcement official upon request. If possible, these 

documents will be on the PIC's person at all times during flight operations, and 

accessible to law enforcement without interrupting the PIC while conducting 

flight operations (possibly in a pouch on the back of the vest). 

PRE-FLIGHT AREA AND PERSONNEL CHECKS 

• Survey flight operations area for safety concerns and to verify conditions. 

• Examine all components of the UAS to verify proper function in accordance 

with the applicable manuals and manufacturer's instructions. 

• Verify notification to all personnel on site. 

• Establish Designated Safety Zone and verify safe clearances. 

• PIC should wear the specified safety vest. 

• The ultimate responsibility for aircraft airworthiness and operational safety 

rests with the UAV pilot-in-command. For this, the PIC- as an aid- uses a 

Pre-Flight Checklist (see Appendix A). In summary, the Pre-Flight Checklist 

prompts examination of the following: 

D The airframe (for condition and lack of damage); 

D The battery (for level-of-charge and security of attachment); 

D The transmitter (for level-of-charge and to check that switches 

14 
are in the 'home' position); 

D The camera (secured, on and operating). 

D Propulsion system 

• In addition, when the flight battery is connected to the UAV, the flight 

controller undertakes a series of diagnostic tests (while simultaneously 

locating the position of GPS satellites). 

CLOSED SET OPERATIONS 

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

and television filming and production, the following additional conditions and 

limitations apply: 

• The operator must have a Motion Picture and Television Operations 

Manual {MPTOM) as documented in this grant of exemption. 

• At least 3 days before aerial filming, the operator of the UAS affected by 

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

Standards District Office {FSDO) with jurisdiction over the area of proposed 

filming. The 3-day notification may be waived with the concurrence of the 

FSDO. The plan of activities must include at least the following: 

o Dates and times for all flights; 

o Name and phone number of the operator for the UAS aerial 

filming conducted under this grant of exemption; 

o Name and phone number of the person responsible for the onscene operation of the UAS; 

o Make, model, and serial or N-Number of UAS to be used; 

o Name and certificate number of UAS PICs involved in the aerial 

filming; 

o A statement that the operator has obtained permission from 

property owners and/or local officials to conduct the filming 

production event; the list of those who gave permission must 

be made available to the inspector upon request; 

o Signature of exemption holder or representative; and 

o A description of the flight activity, including maps or diagrams 

of any area, city, town, county, and/or state over which filming 

will be conducted and the altitudes essential to accomplish the 

operation. 

• Flight operations may be conducted closer than 500 feet from participating 

15 
persons consenting to be involved and necessary for the filming production, 

as specified in the exemption holder's MPTOM. 

ON-SITE PROCEDURES 

The on-site procedures undertaken by SDI are conducted in accordance with and 

controlled through an extensive use of checklists. For this reason the following 

sections repeatedly refer to various checklists found in Appendix A of this Manual. 

• Site Survey- In advance of operations, a survey is undertaken to review the 

site, its terrain, structures and surroundings- to check any assumptions 

made about the location prior to arrival and to adjust the operations plan 

accordingly. For this, an On-Site Survey Checklist is used (see Appendix A, 

page 25}. The primary purpose of the site survey is to make a visual check 

of the operating area with the objective of identifying any potential 

hazards. 

• Selection of Operating Areas and Alternatives- In advance of the pre-flight 

On-Site Survey, Google maps will be consulted and- if possible- the local 

site will be visited beforehand. The site will be specifically checked in terms 

of: 

o Proximity to Airport Reference Points (ARP} as denoted in the 

Airport Facility Directory (AFD}. Must operate outside 5 miles 

of ARP, unless otherwise agreed upon by virtue of written 

letter of agreement with the airport's management, or 

otherwise permitted by the COA issued to Photographic 

Solutions 

o Ability of PIC and VO to operate the UAS clear of, and give way 

to, all manned aviation operations and activities at all times. 

o 500ft. clearance of all non-participating persons, vessels, 

vehicles, and structures unless; A. sufficiently protected in the 

event of an accident, and the nonparticipating persons remain 

protected at all times during operations of the UAS, and B. The 

owners and controllers of any vessels, vehicles, or structures 

has granted permission for the operating closer to those 

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

operating closer to those objects and determined that it does 

not present an undue hazard. 

16 
o Ability of SDI to conduct operations over private or controlled 

access property with permission from the owner/controller or 

representative of such, and said permissions are granted. 

o Proximity to radio interferences 

o Prevailing weather conditions have been adequately assessed, 

including; high winds, convection, visibility, minimum cloud 

clearance {500ft below, and 2,000 ft horizontal clearance), or 

when visibility is less than 3 miles from the PIC. 

The primary site for take-off and landing will be assessed (size, shape, surface, 

slope and surroundings) and an alternative site will be identified should the 

primary site become unavailable or unsuitable. 

• Boundaries- SDI requires that proper identifiers and signage will be in 

place in the operating area to alert people to the fact that aerial work is 

being conducted. The PIC will be responsible for cordoning to ensure safe 

distances from operations are observed. Cordoning procedures to be 

practiced include: 

o Take-off and Landing safety Area: PIC will determine the safe 

distances of all people from the take-off and landing operation 

of the UAS. The PIC will also establish a cordoned area with 

clearly marked delineation the take-off and landing operations. 

o Signage and Identifying Clothing: The PIC will place signage at 

each entry point within the operations area alerting people to 

the following: 

A. Low altitude aerial work is being conducted 

B. Use of any actual sensing equipment being used 

C. A request asking people to not enter the area without 

first notifying the PIC or SDI designated on-site flight 

operations personnel 

D. PIC and VO will put on outerwear that will identify them 

in their respective roles. Signage will be attached on 

their person that will instruct law-enforcement, 

observers, or any other people present that they are not 

to be interrupted un-necessarily while conducting flight 

operations. 

17 
• Anemometer Weather Check- Beyond pre-site planning weather forecast 

checks, SDI requires that the PIC conduct specific on-site weather checks. 

The PIC will utilize a hand-held or portable Anemometer to determine wind 

speed, direction, temperature, and humidity. Aerial operations will only be 

conducted within the specific recommended wind and humidity limitations 

of the UAS manufacturer's operating manuals, or if not identified therein, 

only in conditions where wind speed is less than 15m ph, gusting up to 

20m ph. 

• Crew Briefing- SDI flight operations personnel will typically include the PIC, 

VO, and other possible ground crew. The operations personnel, in addition 

to any other parties that may be present, will be briefed prior to the start of 

operations. The briefing will include: 

o Introduction to the equipment being used including the UAS 

and the ground station functions, with particular emphasis on 

moving parts including weight of the UAS, and the harm or 

damage that could possibly be inflicted by coming into contact 

with those components {particularly the propellers, and hot 

surfaces) 

o Familiarization with the failsafe return-to-home systems and 

instruction on how to activate those systems if the PIC is 

unable to activate those systems 

o Expected flight plan, holding positions, flight duration, and 

overall flight boundaries. 

o Expected responsibilities and authority of each flight 

operations personnel 

o Identification and familiarization with the take-off and landing 

designated areas, and the requirements for remaining clear of 

those areas at all times. 

o The need for all present to alert the PIC of any encroachments 

of people or objects into the airspace and ground boundaries 

o Importance of mitigating any possible distractions or unnecessary communication with the PIC during operations 

o Careful review of Lost Link and emergency procedures 

• Communications- SDI uses channel-hopping technology on 2.4GHz to 

maintain communications with the UAV for the purposes of platform 

control. There is no communication ('downlink') from the UAV to the 

18 
ground station. In the event of loss of or interference with the control 

frequency, the UAV is programmed to return to its take-off position and 

land autonomously ('return-to-home'}. This failsafe procedure is described 

further under Emergency Procedures. 

• Frequency Scans- SDI will perform frequency scans to help identify 

possible conflict with radio communications. This will be performed via a 

hand-held or portable radio spectrum scanner by the PIC. These scans will 

include a full spectrum scan of the applicable frequency range of the UAS. 

Possible sources of radio interference or conflict will be identified and 

evaluated to determine if flight operations can be safely continued. 

• Recharging and Battery Use (Fuel Management)- The DJI Inspire utilizes a 

4,500mAh 22.8 V LiPo {{intelligent" battery. Batteries are charged at base 

prior to flight operations. The number of batteries that will be transported 

to the flight operations area will be based on the specific needs of the flight 

operations or mission. The battery capacity will be tested utilizing the 

internal proprietary tester on the battery, and will also be checked utilizing 

the proprietary DJI software, as well as any internally sensed telemetry 

software and hardware attached to the UAS. A battery charge log will be 

kept via the proprietary DJI Inspire software and will be completed prior to 

every flight. Any battery found to be less than fully-charged, damaged, 

displays insufficient voltage, or otherwise defective will not be used. 

• Load-outs and Equipment- The lnpire is a simple quad-copter UAS with 

limited capability for loads and equipment. Removable equipment includes 

the battery, gimbal, camera, telemetry hardware, antenna, and imaging 

transmitter. The battery is held in place via proprietary fittings. The gimbal 

is attached via screws into the airframe. The camera is attached to the 

gimbal using screws and a proprietary harness. All other equipment is 

attached using nylon fittings, Velcro, or adhesives. Total takeoff weight 

with these components will not exceed the maximum recommended takeoff weight identified in the Inspire Users/operators Manual of 2935 grams. 

Payload security is tested prior to any operations both visually and by 

vigorous tactile testing. All attachment points will be inspected and tested 

weekly. 

19 
FLIGHT PROCEDURES 

SDI will utilize checklists to direct the flight operations personnel in flight 

procedures. The following section will continually refer to the several checklists 

presented in the Appendix. 

• Motor Start- All of the various preflight checks will have been performed 

prior to motor start and will include: 

o PIC and VO will put on identifying outerwear. 

o Pre-flight compass calibration, GPS verification, and voltage 

diagnostics completed. 

o Take-off position and location is checked to ensure it is clear of 

obstacles, debris, potential hazards, and people. 

o Transmitter switches are placed in the proper configuration, 

including the home switch and GPS mode switch. 

o Transmitter is on and properly charged with voltage confirmed. 

o Battery is secured, on, and properly seated. 

o Camera and gimbal is armed, responding to commands, and 

stabilized. 

o UAS is placed in the proper takeoff position. 

o LED flight mode indicator, and telemetry read-out shows adequate 

GPS connectivity according to the DJI Inspire User/operators Manual. 

o LED flight mode indicators and telemetry read-outs show the proper 

flight mode is selected DJI Inspire User/operators Manual. 

o Camera is switched on. 

o All flight operations personnel are in their proper position and at the 

ready. 

o Start motors, and establish functional pre-take-off power setting. 

• Take-Off- Once motors have been started, the PIC will verify that the pretake-off checklist has been completed. Once this has been verified, the PIC 

will follow the following take-off procedure: 

1. Apply power for a controlled ascent to a safe low-level test altitude 

over the take-off area, and then hold. 

2. After in hold, PIC performs check of all control stick response 

including rudder, aileron, elevator, and throttle to ensure proper 

response to commands. 

20 
3. PIC confirms with VO that the flight operations area is free of 

obstructions or other manned or unmanned air traffic. 

4. PIC confirms with all flight operations personnel that they are ready 

to proceed with flight operations as planned. 

• In-Flight- SDI requires that the PIC is free to concentrate on positioning, 

scanning, and monitoring systems and the flight operations area without 

un-necessary distraction, and to ensure the flight is compliant with 

remaining 500ft clear of all non-participating persons, vessels, vehicles, or 

structures unless proper permissions have been obtained as described in 

the previous section addressing the selection of sites. Throughout the 

flight, PIC will take particular care to remain within the established 

operating permissions and envelope by executing the following practices: 

o Verify through verbal communication with the VO that they are 

alerted to any manned or unmanned aircraft within the flight area. 

o Verify through verbal communication with the VO that obstacles are 

being identified and avoided. 

o Interval monitoring of voltage and communication with UAV to 

ensure adequate voltage according to the DJI Phantom 2 

User/operating Manual for safe return and landing. 

o Monitor time since motors were started to ensure a minimum of 3 

minutes of battery fuel is available for return and landing of UAV. 

o A safety margin of a minimum of 3 minutes of battery life is 

maintained at all times. 

o Maintain visual contact with flight systems/mode and battery LED 

light indicators at all times. 

o Maintain situational awareness of changes in weather, visibility, or 

cloud avoidance at all times. 

o Maintain operation speeds less than lOOmph. 

o Maintain visual contact with UAV at all times. 

o Ensure VO has visual contact with the UAV in flight at all times. 

Establish a position hold until VO re-establishes visual contact with 

the UAV if contact is lost. 

• Let-Down/Landing- To execute a safe recovery and landing of the UAV, the 

PIC will ensure that the following practices are followed: 

21 
o Establish and guide the UAV through a safe route to directly above 

the cordoned take-off and landing area. 

o Maintain a safe descent rate and follows all procedures and 

techniques to avoid vortex state or settling with power. 

o Verify that a minimum of 3 minutes of battery life is available, as 

mentioned above, to ensure a holding position if the landing area is 

not cleared. 

o Verify that the landing area is clear of debris, obstacles, people, or 

hazards that would preclude a safe landing. 

• Shutdown- Upon landing, the throttle is returned to the home position 

causing the rotors to stop spinning. Operations then proceed as follows: 

• The UAV battery is switched off or disconnected. 

• The camera is stopped and is then switched off. 

• The UAV is removed from the landing area and is checked for 

any abnormalities or damage. 

• The transmitter is switched off. 

• The UAV battery is removed, tested, and then the battery is 

safely secured and stored. 

22 
EMERGENCY PROCEDURES 

The emergency procedures described below address the following, safety-critical 

question: In the event of a malfunction failure or other in-flight emergenc~ how 

is the UAS going to safely land without creating a hazard to other airspace users 

or persons or property on the ground? 

MOTOR THRUST LOSS 

As a quad copter, The Phantom 2 has no 'rotor redundancy'. Loss of power to a 

motor on a quad copter will result in a crash. For this reason, SDI takes specific 

preventative steps to ensure that loss of power to a motor will not occur: 

• Wiring integrity is checked visually prior to any flight operations. 

• A pre-flight battery check is undertaken to test the charge of the cells. 

• Upon take-off, the UAS is lifted into a temporary, low-altitude holding 

position and the throttle/ rudder and aileron/elevator control sticks are 

moved to check that UAV is responding as expected. 

If there is a loss of thrust to a motor, any residual control left available to the PIC 

will be used to guide the UAV away from people and objects to avoid injury or 

damage to property and people. Every effort will be made to restrict the crash 

site to the safest possible position. 

UAV BATTERY FAILURE 

As has been addressed in above previous sections, SDI has procedures and 

practices in place designed to prevent UAV batter failure or malfunction, and they 

include: 

• The batteries are physically inspected and tested through all phases of preflight and post flight for damage or swelling 

• The Battery performance and condition is tested prior to each flight to 

ensure they are fully charged, and the proprietary DJI Inspire software 

charge track/log is checked to ensure the battery meets the minimum safe 

requirements as specified by DJI in operating manual and firmware specs. 

• Throughout all phases of flight, the battery voltage, percentage of charge 

remaining, and time in operation is constantly monitored via the telemetry 

transmission to the ground station to ensure there is the proper minimum 

voltage and time to return and land is achieved and maintained. 

• The PIC will immediately land the UAV in the nearest possible landing area 

23 
if telemetry indicates the minimum voltage, time in operation, or 

percentage of charge are not met. 

BATIERY FAILURE FAILSAFE 

As a preventative measure to keep the UAV from a forced landing or crash due to 

battery failure, the DJIInspire flight controller has several levels of low voltage 

protections incorporated as specified in the attached User/Operator's Manual, 

triggering an automated Failsafe Return to Home and Landing command as 

follows: 

• The low battery capacity warning alerts users when the battery is close to 

depletion during flight. When it appears, users should promptly fly back 

and land to avoid accidental damage. The Inspire has two levels of low 

battery capacity warning. The first appears when the battery has less than 

30% power and the second appears when it has less than 15% power. The 

following list details the battery power warnings: 

o When battery power drops below 30% the LED indicator will 

blink red slowly. 

o At lower than 15%, the LED indicator will blink red rapidly. The 

Phantom 2 will also begin to descend and land automatically. 

After it has landed, keep the throttle stick at its lowest point or 

execute esc. 

o There is a hidden third low battery threshold in addition to the 

1st and 2nd level warnings. This uses 10.65V as its threshold. 

Both this voltage threshold and the 2nd Level Low Battery 

Warning will trigger auto-landing. 

• Altitude can be maintained if necessary by pushing up on the Throttle stick . 

..... 1st Level Low Battery Capacity Warning 

•••••• 2nd Level Low Battery Capacity Warning 

••• Not Stationary or Sensor Bias is too big 

Errors & Aircraft cannot fly.* 

• • • Compass data abnormal because of ferro-magnetic 

interference or the compass needs calibration. 

24 
TRANSMITTER/CONTROLLER BATTERY FAILURE 

As has been mentioned previously, through the extensive use of checklist 

procedures, SDI requires that the PIC ensure the DJIInspire controller (ground 

station) will be fully charged prior to any aerial operation. Any monitors being 

used to display telemetry will also be fully charged. 

CONTROLLER BATTERY FAILSAFE 

SDI will use The DJIInspire flight control system that incorporates an automated 

failsafe system which commands the UAV to return to home and land if there is a 

loss of frequency due to battery failure. The PIC will reference the below LED 

lighting system to monitor the controller charge; 

Remote Controller Power LED Indicator Status 

None Normal 

•••••• 8-8-8...... Low voltage (at 4V-4.3V). Replace the batteries immediately 

•••• Alert will sound after 15 minutes of inactivity. It will stop 8--B--B ..... . once you start using the remote controller. 

The remote controller will power off automatically when battery voltage drops below 4V. Land and 

change batteries as soon as possible when the low voltage alert occurs to avoid loss of control during 

flight. 

LOSS OF CONTROL FREQUENCY {and/or Ground Station Failure} 

To help prevent a loss of control frequency, SDI requires that the PIC ensure flight 

operations only occur within un-aided visual line of site VLOS at all times. Doing 

so will keep the UAV well within the required minimum range of the DJI Inspire 

controller/transmitter. 

LOSS OF CONTROL FREQUENCY FAILSAFE 

If the control frequency signal is lost for more than 3 seconds (UAS out of range, 

ground station failure etc.) the DJI Inspire Flight Controller has been programmed 

to switch the UAS into failsafe mode and it will'return to home' (RTH} and also 

land: 

• If the failsafe occurs while in GPS mode according to the parameters of 

the DJIInspire User/Operator Manual, the UAV will return to the take-off 

25 
and landing area and auto-land. 

• If the fail location occurs while in A Til mode according to the parameters 

of the DJIInspire User/Operator Manual, the UAV will auto-land. 

• The RTH failsafe mechanism works by the UAS Flight Controller saving the 

home (take-off) point automatically when the throttle stick is moved for 

the first time (after 6 or more GPS satellites have been acquireddenoted by a single red pulse from the LED or a series of continuous 

green pulses). 

The RTH failsafe function on the UAS is tested on a weekly basis by SDI by 

switching the transmitter off during a test flight session. 

MALICIOUS OR ACCIDENTAL INTERFERENCE WITH CONTROL FREQUENCY 

As was mentioned in previous sections, through the extensive use of checklists, 

SDI requires that the PIC utilize a Spectrum Scanner to ensure there is no 

accidental or malicious radio interference. In the unlikely event that this should 

occur, the PIC will initiate the failsafe procedure mentioned in the previous 

section 

• Pilot Incapacitation- If the pilot-in-command becomes incapacitated to 

the extent that control of the UAV becomes unviable, the UAV will hover 

in a stationery position until the battery's second level low-voltage 

protection is triggered. At this point, the UAV will descend and land in a 

steady, controlled manner. If an observer is present, they will have been 

briefed on the UAS's failsafe (return-to-home) mode and its activation 

(see Section on "Crew Briefing"). 

• Aircraft Incursion- If another aircraft should enter or appears to be 

entering the Visual Line of Sight Operating Envelope VLOS, PIC will 

operate the UAV to immediately maintain safe visual separation, and give 

way to any manned flight operation. 

26 
FLY AWAY PROCEDURE 

A "fly away" is defined as the loss of control transmission link where the PIC no 

longer has control or the ability to command the UAV to remain within the 

bounds of the intended operation area. In the unlikely event that this should 

occur, the PIC will observe and record the direction of flight heading, speed, and 

altitude of the UAV, and then follow the Incident Response Procedure as outlined 

below: 

• Crash & Incident Response While SDI takes extreme caution in its flight 

procedures to prevent a loss of control or crash, any incident, accident, or 

operation that transgresses the lateral or vertical boundaries as defined 

by the applicable COA issued must be reported to the FAA UAS 

Integration Office {AFS 80 within 24 hours. The following procedures will 

also be ensured by the PIC: 

o PIC will have on their person a copy of the local emergency 

response contact information, including fire, law 

enforcement, medical response, and the UAS Integration 

Office contact information 

27 
Slf1UNS'I'ON ))J(;I'J'JU UlllmNH 

Appendix A 

Checklists 

28 
PRE-FLIGHT START-UP CHECKLIST: 

o Verify all transmitter, on-board aircraft and camera batteries are fully 

charged (confirm voltages). 

o Ensure no frequency conflicts with video and transmitter I receiver. 

D Check all control surfaces for signs of damage, loose hinges, and overall 

condition. Inspect the wings I rotors to ensure they are in good structural 

condition and properly secured. 

o Check motor I engine and mounting attachments to the airframe. 

o Inspect propellers I mounting hardware (tight) I rotor blades for chips and 

deformation. 

o Check the landing gear for damage and function. 

o Test electrical connections (plugged in and secure). 

o Ensure photo I video equipment mounting system is secure and 

operational. 

o Check location of GPS equipment controlling the autopilot. 

o Check the IMU movements in the ground control software. 

o UAV in stabilization mode, ensure control response move toward the 

correct positions. 

o UAV I Drone is in a level location safe for takeoff. 

D FPV I Power up ground station. 

o FPV I Power up Video receiver. 

o If using Video recorder, turn on camera system. 

o Camera settings are correct (still images, video, frame rate). 

o SD camera memory clear and inserted into the camera. 

o Action I Start filming. 

o All transmitter controls move freely in all directions. 

o All transmitter trims in neutral position. 

o All transmitter switches in correct position (typically away). 

o Transmitter throttle to zero. 

o Radio transmitter on. 

o Connect I power on battery to airframe. 

o Ensure led indicators and audible tones are correct. 

o Timer on (if applicable). 

o FPV, confirm video is in monitor I goggles. 

o Scan for nearby cars I people I animals. 

D SayuCLEAR!". 

o Arm flight controller. 

29 
o Increase throttle slightly listening for any abnormalities. 

o Short 20-30 second hover at 3-5 feet (listen for vibrations I loose items). 

o Confirm Voltage levels are correct. 

30 
PRE-FLIGHT INSPECTION CHECKLIST: 

D Perform initial walk-around. 

D Inspect UAV for cracks in joints and structural members. 

D Inspect UAV for loose or damaged screws, ties, fasteners, straps. 

D Inspect UAV for loose or damaged wiring. 

D Inspect UAV for loose or damaged connections (solder, plugs, etc.). 

D Inspect prop mounts and screws and apply slight counter pressure on arms 

to check for loosened components. 

D Ensure antennas and masts are secure. 

D Inspect I clean FPV Camera and Lens and insure it is secured and 

connections are firmly attached. 

D Ensure camera settings are correct (still images, video, frame rate). 

D Ensure FPV Transmitters are secure and operational. 

D Ensure batteries are fully charged, properly seated and secured. 

D Ensure the following fail-safe equipment is functioning: 

D RTH (return to home). 

D Recovery Command Response (toggle test). 

D Firmware Airport Proximity Detection. 

D Ensure props are smooth and free of damage I defect (check blade, surface 

and hub). 

D Ensure prop adapters are tight I secure. 

D Ensure voltage alarm is connected. 

D Ensure arming I idle timeout is properly configured. 

D Ensure correct model is selected in transmitter (if applicable). 

D Check RC transmitter for the correct range and centering for all sticks. 

D Perform range test. 

31 
IN-FLIGHT CHECKLIST: 

D Basics: If flying manually, always keep your fingers on the 

controller/transmitter. 

D Never let the UAV out of your sight even for a second. 

D Climb to a safe altitude away from potential hazards and to reduce noise 

pollution. 

D Keep aircraft at a safe operating distance from people, electric utility lines 

and buildings. 

D If the UAV must be flown over buildings or people, use a lightweight UAV 

and maintain a safe altitude for recovery and make every effort to minimize 

exposure. 

D Spotter: Use a spotter whenever possible and appropriate, especially when 

flying by First Person View {FPV). 

D Do not fly UAVs within distance defined by local laws of any 

private/commercial airport/helipad. 

D Do not fly around a pre-existing UAV flying site without a frequencymanagement agreement. 

D Do not interfere with operations and traffic patterns at any airport. 

32 
LANDING CHECKLIST: 

D Regardless of whether of a manual or automated UAV landing, scan landing 

area for potential obstruction hazards. 

D Announce out loud {{Preparing to Land". 

D Use a safe descent rate and follow correct procedures to avoid a vortex 

state or settling. 

D Carefully land the aircraft away from obstructions and people. 

D Turn the power off to the aircraft and/or disconnect the batteries. 

D Turn off the transmitter. 

D Turn the power off to the photo equipment. 

D Visually check aircraft for signs of damage and/or excessive wear. 

D Remove the unused fuel if applicable. Secure the aircraft. 

D Check pictures: Verify that the UAV camera actually took the pictures. 

D LOG FLIGHT. 

33 
SW1UNSl'ON nm1'1'1U UIJl{;JNG 

Appendix B 

Maintenance Logbook 

34 
Date 

Swainston Digital Imaging 

MAINTENANCE LOGBOOK 

Component Maintenanc Maintenanc 

eActivity eTime 

35 

Comments 
Slfi\INS'I'ON nl(rl'l'iU UIJl(;ING 

Appendix C 

Incident/ Accident Logbook 

36 
Date of Time of 

Incident/ Incident/ 

Accident Accident 

Swainston Digital Imaging 

INCIDENT/ ACCIDENT LOGBOOK 

Name of Injured Incident/ Accident Action Taken 

Details 

37 

Notes 
SW1UNS'I'ON UUJI'1'1U 1111\.HI~G 

Appendix D 

Flight Record Log Book 

38 
Swainston Digital Imaging 

FLIGHT RECORD LOGBOOK (Sample Page) 

Date Location Activity Flying Time Battery Battery Comments 

Before After 

39 
Appendix E 

DJI Inspire User Manual 

40 
INSPIRE 1 

User Manual [v1.o l 

2015.3