Page | 1 

August 7, 2015 

Docket Operations, M-30

U.S. Department of Transportation (DOT)

Docket Management System

1200 New Jersey Ave., SE 

Room W12-140, West Building Ground Floor 

Washington, DC 20590-0001 

Dear Sir or Madam:

Attached please find Aerial Photo Shop, Inc. (Aerial Photo Shop) request, as a member of the 

Professional Aerial Photographers Association, International (PAPA), for an exemption from the 

listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned 

Aircraft Systems ("sUAS") for aerial imaging to include video and still photography. This 

exemption request is initially for the use of the Inspire 1 sUAS manufactured by DJI, an 

established sUAS company and in accordance with the sUAS training and certification program 

as administered by PAPA. 

Also attached to this letter is the equipment “Aerial Photo Shop Flight Manual” (Manual), which 

outlines the operating requirements, limitations, and technical specifications for the DJI System 

as used by Aerial Photo Shop. Aerial Photo Shop 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,

David D. Price 

Aerial Photo Shop 

Corporate Officer

Professional Aerial Photographers Association-International Section 333 Doc 15-011 
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August 7, 2015 

Docket Operations, M-30

U.S. Department of Transportation (DOT)

Docket Management System

1200 New Jersey Ave., SE 

Room W12-140, West Building Ground Floor 

Washington, DC 20590-0001 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 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 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, Aerial Photo Shop Inc. (Aerial Photo Shop), 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 and still photography, 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 as to access and 4) would provide safety enhancements to the 

already best practices safety protocols followed by Aerial Photo Shop during aerial photography 

operations in accordance with the training and certification provided by the Professional Aerial 

Photographers Association, International (PAPA). Aerial Photo Shop is a member of the 

Professional Aerial Photographers Association-International (PAPA) and has a demonstrated 

record of safe operations in the National Airspace System (NAS). Principal employees have 

logged well over 25 hours of sUAS flight operations. The Pilot/s In Command (PIC) proposed 

by Aerial Photo Shop is a FAA licensed pilot with years of safe and successful aerial 

photography 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. 

Professional Aerial Photographers Association-International Section 333 Doc 15-011 
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Professional Aerial Photographers Association-International Section 333 Doc 15-011 

The name and address of the applicant is: 

Aerial Photo Shop, Inc.

42160 Parado Del Sol Dr. 

Temecula, Ca 92592 

PIC-David D. Price, FAA Licensed Pilot (Commercial Rotorcraft, Private Pilot) 

PH: 760-807-1254 

Email: david@aerialphotoshop.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

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 §40101 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) 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. §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
Page | 4 

• 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." Id. §333(c) 

Aerial Photo Shop' 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 Pilot's visual line of sight at all times and will operate only within the 

controlled “Area of Operations” described in the Confidential Aerial Photo Shop Flight Manual

(Manual), attached as Exhibit 1 (hereinafter "Manual"). Such operations will ensure that the 

sUAS will "not create a hazard to users of the 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 controlled 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, Aerial Photo Shop 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) of the 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 333 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. 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 

Professional Aerial Photographers Association-International Section 333 Doc 15-011 
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Professional Aerial Photographers Association-International Section 333 Doc 15-011 

powered small aircraft. Shifting to sUAS from manned aircraft presents a marked safety increase 

for our workers and the public. 

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

aerial imaging and data collection. The sUAS used by Aerial Photo Shop 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 AND SECURITY

Aerial Photo Shop 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 and photography operations conducted with conventional aircraft. 

Aerial Photo Shop 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.

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

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, but never in

controlled airspace without prior coordination and approval of ATC.

5. Flights will not be conducted within the surface area of controlled airport airspace without

prior coordination and approval of ATC.

6. Flights will not be conducted within 5 miles of any uncontrolled airport without prior

coordination and approval of the airport authority.

7. Crew for each operation will consist of the sUAS Operator who will keep the sUAS within his

visual line of sight at all times and a qualified Observer.

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

the Flight Manual.

9. The sUAS will only operate within a confined "Area of Operations" as defined in the Manual,

including but not limited to evaluation of the airspace by reference to a current 1:500,000 scale

FAA Sectional Aeronautical Chart. The Manual also requires the establishment of a

"Designated Safety Zone" for the flight operations area.

10. 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 Designated Safety Zone be present for this briefing.

11. 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 operation.
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Professional Aerial Photographers Association-International Section 333 Doc 15-011 

12. Operator will have been trained in operation of UAS generally and will have received up-todate information on the particular sUAS to be operated as required by the Aerial Photo Shop

Manual.

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

14. All required permissions and permits will be obtained from territorial, state, country, or city

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

15. 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.

16. Aerial Photo Shop personnel will be easily identified by law enforcement personnel and the

Public through wearing a green fluorescent or blaze orange vest with Section 333 Grant and

PAPA credentials prominently displayed within a weatherproof container on the persons

back.

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 Operator operating the aircraft to have completed a 

sUAS flight training course of 25 hours before flying a sUAS (See the Aerial Photo Shop

Manual for details) or meeting any FAA pilot licensing requirement. 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 set forth in the Aerial Photo Shop 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 Aerial Photo Shop Manual. Like other 

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

Operator, pursuant to the Aerial Photo Shop 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 on aerial photography operations. The FAA will have advance 

notice of all operations as 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 Aerial Photo Shop Manual, achieves the level of safety contemplated by 14 C.F.R. 

§61.113 (a) & (b).
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Professional Aerial Photographers Association-International Section 333 Doc 15-011 

14 C.F.R. 91.103: Preflight Action 

This regulation requires that each Operator in Command take certain actions before flight to 

ensure the safety of flight. An exemption is needed from this requirement as the Pilot 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 Aerial Photo Shop Manual. These actions will provide an equivalent level of 

safety.

14 C.F. R. 91.119: Minimum/ Maximum 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 altitudes higher than 

the base of controlled airspace without prior approval and coordination with ATC 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 Aerial Photo Shop

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 Aerial Photo Shop 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 low-altitude 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 Aerial Photo Shop 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 Aerial Photo Shop
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Professional Aerial Photographers Association-International Section 333 Doc 15-011 

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 approximately 20 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would necessarily be 

impossible to conduct. Given the limitations on the sUAS's proposed flight area and the location 

of its proposed operations within a predetermined area, a shorter time frame (less than 30 

minutes) for flight in daylight or night VFR conditions is reasonable. 

Aerial Photo Shop 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, 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 of the small UAS. 

An equivalent level of safety can be achieved by limiting flights to 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 operator), 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 Aerial Photo Shop. Maintenance will be accomplished by the 

operator and pursuant to the flight manual and operating handbook as referenced in the Aerial 

Photo Shop 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 even if 

operating at a maximum of 1200 feet AGL. As provided in the Aerial Photo Shop Manual, the 

operator 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 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. 

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: 
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Professional Aerial Photographers Association-International Section 333 Doc 15-011 

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. 

Approval of exemptions allowing commercial operations of sUAS in the aerial photography

industry enhances safety while reducing risk. Manned aircraft still photography and video may 

create a greater risk because the craft are much larger, have combustible fuel, and carry an 

onboard human pilot. 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.

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 manned aircraft operating in close proximity to the ground and people.

Privacy

All Flights will occur over private or public property with the 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 will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--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 the aerial 

photography industry pursuant to the Manual appended hereto. 

Sincerely,

David D. Price 

Aerial Photo Shop, Inc.

Corporate Officers
sUAS Operations Manual

Aerial Photo Shop, Inc.

7 August 2015

This manual contains standard operating procedures and guidelines for UAS operations.
2 

Aerial Photo Shop, Inc.

sUAS 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
3 

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

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

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

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

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

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

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

Communications.........................................................................................19

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

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

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

Flight Procedures..............................................................................................21

Motor Start........................................................................................................21

Take-Off.............................................................................................................21

In-Flight..............................................................................................................22

Let Down/Landing..............................................................................................23

Shutdown ..........................................................................................................23

Emergency Procedures......................................................................................24

Motor Thrust Loss..............................................................................................24

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

Battery Failure Failsafe ...............................................................................25

Transmitter/Controller Battery Failure .......................................................26

Controller Battery Failsafe ..........................................................................26

Loss of Control Frequency..................................................................................26

Loss of Frequent Failsafe....................................................................................26

Malicious or Accidental Interference with Control Frequency ...........................27
4 

Pilot Incapacitation .....................................................................................27

Aircraft Incursion ........................................................................................27

Fly Away Procedure ..........................................................................................28

Crash & Incident Response ................................................................................28

Appendix A - Checklists.....................................................................................29

Pre-Flight Start-Up Checklist..............................................................................30

Pre-Flight Inspection Checklist........................................................................... 32 

In-Flight.............................................................................................................. 33 

Landing Checklist ............................................................................................... 34 

Appendix B ....................................................................................................... 35 

Maintenance Logbook ....................................................................................... 36 

Appendix C ....................................................................................................... 37 

Incident/Accident Logbook ................................................................................ 38 

Appendix D ....................................................................................................... 39 

Flight Record Logbook .......................................................................................40

Appendix E ........................................................................................................41

Inspire1 User Manual ....................................................................................41 
5 

PURPOSE, SCOPE, AND MISSION STATEMENT

Aerial Photo Shop, Inc. (Aerial Photo Shop), 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 licensed pilots. The sUAS Pilots In Command (PIC) 

that will operate systems according to the approach outlined in this Manual of 

Procedures (Manual) are trained in accordance with this Manual and FAA 

regulations and have decades of successful experience on 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.
6 

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 take offs and landings of the sUAS at a given Area of Operations.

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

and onboard 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.
7 

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.
8 

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 an FAA-licensed pilot with at least 25 hours of sUAS flight 

time. The VO must demonstrate experience with FAA procedures and the 

standard procedures of this Manual. 
9 

OPERATING LIMITATIONS AND CONDITIONS

Operational Ceiling - Maximum 1,200 ft AGL, typical 400 ft AGL.

Operational Endurance - 15 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)
10

MAINTENANCE PROCEDURES

Only Aerial Photo Shop 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 an Aerial Photo Shop 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, GPS

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 
11

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

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 Aerial Photo Shop 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 sUAS 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 Aerial Photo Shop

personnel or appointed service providers. All upgrade information such as 

version numbers and new functions are recorded in the Maintenance Logbook. 

All Aerial Photo Shop 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 Aerial Photo Shop 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.
12

LOGS AND RECORDS

PILOT AND AIRCRAFT HOURS

Aerial Photo Shop PIC are required to keep a log of pilot and aircraft hours. 

To meet this requirement, Aerial Photo Shop holds and updates a spreadsheetbased 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

Aerial Photo Shop 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 – Aerial Photo Shop

Incident Logbook (Appendix C) and Maintenance Logbook (Appendix B).
13

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 (ATIS), the ATIS broadcast system will be consulted. 

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

forecast.

The operating envelope for the Inspire 1 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 sUAS 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 sUAS, the aircraft will be prohibited from 

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

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

components according to the recommended checklists in the DJI Inspire 1

operator manual, and in the Aerial Photo Shop checklist:
14

 Airframe

 Battery

 Transmitters

 Camera and Gimbal

 Propulsion system including propellers

In addition, with the battery attached and turned on in the sUAS, 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 1 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 sUAS 

is flown from a new location.

DOCUMENTATION

PIC will ensure that all documents used by Aerial Photo Shop 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 sUAS 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 sUAS 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 SUAS 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:

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

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

 The transmitter (for level-of-charge and to check that switches
15

are in the ‘home’ position);

 The camera (secured, on and operating).

 Propulsion system

• In addition, when the flight battery is connected to the sUAS, 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 sUAS aerial

filming conducted under this grant of exemption;

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

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

o Name and certificate number of sUAS 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
16

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 Aerial Photo Shop 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 Aerial Photo Shop

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

way to, all manned aviation operations and activities at all

times.

o 500 ft. 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 sUAS, 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
17

does not present an undue hazard.

o Ability of Aerial Photo Shop 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 (500 ft 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 - Aerial Photo Shop 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 Aerial Photo Shop 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
18

operations.

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

checks, Aerial Photo Shop 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 sUAS manufacturer’s operating manuals, or

if not identified therein, only in conditions where wind speed is less than

15mph, gusting up to 20mph.

• Crew Briefing - Aerial Photo Shop 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 sUAS

and the ground station functions, with particular emphasis on

moving parts including weight of the sUAS, 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 - Aerial Photo Shop uses channel-hopping technology on
19

2.4GHz to maintain communications with the SUAS for the purposes of 

platform control. There is no communication (‘downlink’) from the SUAS to 

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

frequency, the SUAS 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 - Aerial Photo Shop when able 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 sUAS. 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 1 utilizes

a 4500mAh 22.2V “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 sUAS. A battery charge log will be

kept via the proprietary DJI Inspire 1 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 Inspire 1 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 1 Users/operators Manual of 2935

grams, with a total payload weight not to exceed 300 grams. Payload
20

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

tactile testing. All attachment points will be inspected and tested weekly.
21

FLIGHT PROCEDURES

Aerial Photo Shop 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 sUAS 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 1 User/operators

Manual.

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

flight mode is selected DJI Inspire 1 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
22

response to commands. 

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 - Aerial Photo Shop 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 500 ft 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 sUAS to

ensure adequate voltage according to the DJI Inspire 1

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 sUAS.

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 100mph.

o Maintain visual contact with sUAS at all times.

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

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

the sUAS if contact is lost.
23

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

the PIC will ensure that the following practices are followed:

o Establish and guide the sUAS 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:

1. The sUAS battery is switched off or disconnected.

2. The camera is stopped and is then switched off.

3. The sUAS is removed from the landing area and is checked for

any abnormalities or damage.

4. The transmitter is switched off.

5. The sUAS battery is removed, tested, and then the battery is

safely secured and stored.
24

EMERGENCY PROCEDURES

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

question: In the event of a malfunction, failure or other in-flight emergency, how 

is the sUAS 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 Inspire 1 has no ‘rotor redundancy’. Loss of power to a 

motor on a quad copter will result in a crash. For this reason, Aerial Photo Shop

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 sUAS is lifted into a temporary, low-altitude holding

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

moved to check that sUAS 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 sUAS 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.

sUAS BATTERY FAILURE

As has been addressed in above previous sections, Aerial Photo Shop has 

procedures and practices in place designed to prevent sUAS 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 1 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.
25

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

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

percentage of charge are not met.

BATTERY FAILURE FAILSAFE

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

battery failure, the DJI Inspire 1 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 1 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

Inspire 1 will also begin to descend and land automatically.

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

execute the combination stick command (CSC) to shut off

motors.

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.
26

TRANSMITTER/CONTROLLER BATTERY FAILURE

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

procedures, Aerial Photo Shop requires that the PIC ensure the DJI Inspire 1

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

Aerial Photo Shop will use The DJI Inspire 1 flight control system that incorporates 

an automated failsafe system which commands the sUAS 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

Power LED

I di t

Sound Remote Controller Status

None Normal

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

B--B--B...... Alert will sound after 15 minutes of inactivity. It will stop 

once you start using the remote controller.

LOSS OF CONTROL FREQUENCY (and/or Ground Station Failure) 

To help prevent a loss of control frequency, Aerial Photo Shop 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 sUAS well within the required minimum range of 

the DJI Inspire 1 controller/transmitter.

LOSS OF CONTROL FREQUENCY FAILSAFE

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

ground station failure etc.) the DJI Inspire 1 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 DJI Inspire 1 User/Operator Manual, the sUAS will return to the takeThe 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.
27

off and landing area and auto-land.

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

of the DJI Inspire 1 User/Operator Manual, the sUAS will auto-land.

• The RTH failsafe mechanism works by the sUAS 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 acquired –

denoted by a single red pulse from the LED or a series of continuous

green pulses).

The RTH failsafe function on the sUAS is tested by Aerial Photo Shop 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, 

Aerial Photo Shop requires that when able 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 sUAS becomes unviable, the sUAS will hover

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

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

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

briefed on the sUAS’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 sUAS to immediately maintain safe visual separation, and give

way to any manned flight operation.
28

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 sUAS 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 sUAS, and then follow the Incident Response Procedure as outlined 

below:

• Crash & Incident Response While Aerial Photo Shop 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
29

Appendix A

Checklists
30

PRE-FLIGHT START-UP CHECKLIST:

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

charged (confirm voltages).

 Ensure no frequency conflicts with video and transmitter / receiver.

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

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

condition and properly secured.

 Check motor / engine and mounting attachments to the airframe.

 Inspect propellers / mounting hardware (tight) / rotor blades for chips and

deformation.

 Check the landing gear for damage and function.

 Test electrical connections (plugged in and secure).

 Ensure photo / video equipment mounting system is secure and

operational.

 Check location of GPS equipment controlling the autopilot.

 Check the IMU movements in the ground control software.

 SUAS in stabilization mode, ensure control response move toward the

correct positions.

 SUAS / Drone is in a level location safe for takeoff.

 FPV / Power up ground station.

 FPV / Power up Video receiver.

 If using Video recorder, turn on camera system.

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

 SD camera memory clear and inserted into the camera.

 Action / Start filming.

 All transmitter controls move freely in all directions.

 All transmitter trims in neutral position.

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

 Transmitter throttle to zero.

 Radio transmitter on.

 Connect / power on battery to airframe.

 Ensure led indicators and audible tones are correct.

 Timer on (if applicable).

 FPV, confirm video is in monitor / goggles.
31

 Scan for nearby cars / people / animals.

 Say “CLEAR!”.

 Arm flight controller.

 Increase throttle slightly listening for any abnormalities.

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

 Confirm Voltage levels are correct.
32

PRE-FLIGHT INSPECTION CHECKLIST:

 Perform initial walk-around.

 Inspect SUAS for cracks in joints and structural members.

 Inspect SUAS for loose or damaged screws, ties, fasteners, straps.

 Inspect SUAS for loose or damaged wiring.

 Inspect SUAS for loose or damaged connections (solder, plugs, etc.).

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

to check for loosened components.

 Ensure antennas and masts are secure.

 Inspect / clean FPV Camera and Lens and insure it is secured and

connections are firmly attached.

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

 Ensure FPV Transmitters are secure and operational.

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

 Ensure the following fail-safe equipment is functioning:

 RTH (return to home).

 Recovery Command Response (toggle test).

 Firmware Airport Proximity Detection.

 Ensure props are smooth and free of damage / defect (check blade, surface

and hub).

 Ensure prop adapters are tight / secure.

 Ensure voltage alarm is connected.

 Ensure arming / idle timeout is properly configured.

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

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

 Perform range test.
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IN-FLIGHT CHECKLIST:

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

controller/transmitter.

 Never let the SUAS out of your sight even for a second.

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

pollution.

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

and buildings.

 If the SUAS must be flown over buildings or people, use a lightweight SUAS

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

exposure.

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

flying by First Person View (FPV).

 Do not fly SUASs within distance defined by local laws of any

private/commercial airport/helipad.

 Do not fly around a pre-existing SUAS flying site without a frequencymanagement agreement.

 Do not interfere with operations and traffic patterns at any airport.
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LANDING CHECKLIST: 

 Regardless of whether of a manual or automated SUAS landing, scan

landing area for potential obstruction hazards.

 Announce out loud “Preparing to Land”.

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

state or settling.

 Carefully land the aircraft away from obstructions and people.

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

 Turn off the transmitter.

 Turn the power off to the photo equipment.

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

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

 Check pictures: Verify that the SUAS camera actually took the pictures.

 LOG FLIGHT.
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Appendix B

Maintenance Logbook
36

MAINTENANCE LOGBOOK

Date Component Maintenance

Activity

Maintenance

Time

Comments
37

Appendix C

Incident/Accident Logbook
38

INCIDENT/ACCIDENT LOGBOOK

Date of

Incident/

Accident

Time of

Incident/

Accident

Name of Injured Incident/Accident

Details

Action Taken Notes
39

Appendix D

Flight Record Logbook
40

FLIGHT RECORD LOGBOOK (Sample Page)

Date Location Activity Flying Time Battery 

Before

Battery 

After

Comments