Attn:

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE., Room W12-140

West Building Ground Floor, Washington, DC 20590-0001

PETITION FOR EXEMPTION

Christopher E. Muhl requests an exemption from Title 14, Code of Federal Regulations 

(14 CFR) part 21, subpart H; and Sections 61.23 (a) and (c), 61.101 (e) (4) and (5), 61.113 (a), 

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

and 91.417 (a) and (b), concerning commercial operation of the 3D Robotics X8+, 3D 

Robotics Aero, 3D Robotics Solo, DJI F550, DJI F450, DJI S1000, DJI S900, DJI Phantom 2, 

DJI Phantom 2 Vision, DJI Phantom 2 Vision+, DJI Phantom 3, DJI Inspire 1, and Precision 

Hawk Lancaster unmanned aircraft systems pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (Public Law 112-95).

Content Provided Per FAA Section 333 Petition Checklist:

1. Operator name and address;

2. The specific applicable regulations from which relief is required (CFRs);

3. How the operator will maintain an equivalent level of safety or no adverse impact 

to safety;

4. How granting the exemption would be in the public interest;

5. The proposed operations;

6. The make and model of the aircraft for proposed operations; and

7. Supporting documents

Submitted on February 29, 2016

Christopher E. Muhl

16706 Monte Alto Place

Pacific Palisades, California, 90272

Tel: (310) 699-0881

Email: cmuhl999@gmail.com
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Table of Contents

Glossary Of Abbreviations ............................................................................................. 4

Publishable Summary...................................................................................................... 6

A. Specific Applicable Regulations From Which Relief Is Required ........... 6

B. An Equivalent Level of Safety ............................................................................. 7

C. The Public Interest ................................................................................................. 7

D. The Unmanned Aircraft Systems ....................................................................... 7

Operator’s Name and Address ...................................................................................... 7

About the Operator .......................................................................................................... 8

Maintaining An Equivalent Level Of Safety ............................................................ 8

Safety Of Life And Property ...................................................................................... 8

Public Privacy and National Security .................................................................... 9

The Public Interest........................................................................................................... 9

Unmanned Aircraft Operator, PIC, and VO ........................................................... 10

The Operator ................................................................................................................ 10

Qualifications Of The PIC, Medical Standards And Certifications............. 10

The Crew ........................................................................................................................11

Proposed Operations of the Unmanned Aircraft ...................................................11

A. Identification and Registration Markings ......................................................11

B. Flight Planning, Operations, and Conditions ................................................11

C. The Small Unmanned Aircraft Systems ......................................................... 12

Proposed Conditions and Limitations Of The Exemption ................................. 13

Appendix A: Aircraft Make and Model .................................................................... 17

3D Robotics X8+ .......................................................................................................... 17

Type ........................................................................................................................................................................................17

Model.....................................................................................................................................................................................17

Dimensions........................................................................................................................................................................17

Weight and Payload....................................................................................................................................................17

Materials..............................................................................................................................................................................17

Propeller..............................................................................................................................................................................17

Motor and Electronic Speed Controller (ESC).........................................................................................18

Other Requirements...................................................................................................................................................18

Flight Characteristics.................................................................................................................................................18

GPS..........................................................................................................................................................................................18

Digital airspeed sensor............................................................................................................................................. 19

Telemetry Data Recording ................................................................................................................................... 19

RF Communications.................................................................................................................................................. 19

Power Source................................................................................................................................................................... 20

Camera Attachments................................................................................................................................................ 20

3D Robotics Aero......................................................................................................... 20

Type ....................................................................................................................................................................................... 20

Model.................................................................................................................................................................................... 20

Dimensions........................................................................................................................................................................21

Weight and Payload....................................................................................................................................................21

Materials..............................................................................................................................................................................21

Propeller..............................................................................................................................................................................21
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Motor and Electronic Speed Controller (ESC).........................................................................................21

Other Requirements...................................................................................................................................................21

Flight Characteristics.................................................................................................................................................21

GPS..........................................................................................................................................................................................22

Digital airspeed sensor..............................................................................................................................................22

Telemetry Data Recording ....................................................................................................................................22

RF Communications...................................................................................................................................................23

5.8GHz Video Link........................................................................................................................................................23

Power Source....................................................................................................................................................................23

Camera Attachments.................................................................................................................................................23

Appendix B: Preflight, Launch and Recovery Procedures ................................. 24

Launch Site and Safety Considerations ............................................................... 24

Preflight ........................................................................................................................ 25

Launch............................................................................................................................ 26

Recovery ........................................................................................................................ 27

Appendix C: Operations & Emergency Procedures.............................................. 28

Chain of Command .................................................................................................... 28

Operator, PIC and VO Duties.................................................................................. 28

Operator Duties............................................................................................................................................................. 28

PIC Duties......................................................................................................................................................................... 28

VO Duties........................................................................................................................................................................... 30

Method for Alerting Ground Crew and Participants ....................................... 30

Method for Reporting Emergencies...................................................................... 30

Emergency Prioritization ......................................................................................... 30

Safety Areas and Evacuation Routes .................................................................... 31

Ground Crew and Participant Information ........................................................ 31

Emergency Drills ........................................................................................................ 31

Medical Duties ............................................................................................................. 31

Pre-Flight Briefing ..................................................................................................... 31

Aircraft Operations Emergency Procedures....................................................... 32

Ground Crew Emergency Procedures................................................................... 34

Reporting....................................................................................................................... 35

Incident Reports............................................................................................................................................................35

Documentation.............................................................................................................................................................. 36

Air Traffic Control Special Provisions................................................................. 36

Coordination Requirements................................................................................................................................. 36

Notice to Airmen (NOTAM) .................................................................................... 37

Appendix D: Lost Communications Procedure ..................................................... 38

Appendix E: Lost Link Mission................................................................................... 39

Appendix F: Communications..................................................................................... 41

Appendix G: Control Station ....................................................................................... 43
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Glossary Of Abbreviations 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

C.F.R. Code of Federal Regulations

COA Certificate of Waiver or Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

sUAS Small Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing

GIS Geographic Information Systems
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE., Room W12-140

West Building Ground Floor, Washington, DC 20590-0001

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act 

of 2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 

C.F.R.

Dear Sir or Madam:

Christopher E. Muhl seeks exemption from the requirements of 14 C.F.R. part 21, 

subpart H; and Sections 61.23 (a) and (c), 61.101 (e) (4) and (5), 61.113 (a), 61.315 (a), 91.7 (a), 

91.119 (c), 91.121, 91.151 (a) (1), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (2), and 91.417 (a) and 

(b), to operate Small Unmanned Aircraft Systems (sUAS) pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 C.F.R. Part 11. This 

exemption will permit Christopher E. Muhl to operate sUAS for aerial surveying, data 

collection, and the development of geographic information systems (GIS) for natural 

resource and agricultural applications. This petition is similar to other approved 

petitions, and will permit the commercial operation of sUAS, given that such operations 

are conducted in accordance with conditions defined herein, or as may be defined by the 

FAA.

A grant of this petition will allow Christopher E. Muhl to operate the 3D Robotics 

X8+, 3D Robotics Aero, 3D Robotics Solo, DJI F550, DJI F450, DJI S1000, DJI S900, DJI 

Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision+, DJI Phantom 3, DJI Inspire 1, 

and Precision Hawk Lancaster unmanned aircraft systems in accordance with the

conditions of the “blanket” Certificate of Waiver or Authorization (FAA Form 7711-1 UAS 

COA) issued with the Section 333 exemption, or as may be established by the FAA in a 

grant of this petition, or as may be established by the FAA in any future final rule, or as 

otherwise defined by an Air Traffic Organization (ATO) issued COA. The 3D Robotics 

X8+, 3D Robotics Aero, 3D Robotics Solo, DJI F550, DJI F450, DJI S1000, DJI S900, DJI 

Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision+, DJI Phantom 3, DJI Inspire 1, 

and Precision Hawk Lancaster unmanned aircraft systems have previously been 

approved by the FAA in previous exemptions as defined in table 1 below. All aircraft 

covered in this petition for exemption are battery-powered, weigh less than 55 lbs. (all-up 

weight – including batteries and payload), and will be operated in accordance with the 

FAA’s conditions for the category of sUAS. 

An equivalent level of safety will be achieved with respect to manned aircraft, as 

the use of the UA listed herein significantly reduces potential risks to life and property. 

Manned fixed-wing aircraft and rotorcraft are inherently, more mechanically complex, 

weigh thousands of pounds, carry highly explosive fuel, lack the breadth of failsafe 

functions of sUAS and UAS, and when operated in close proximity to people and 

infrastructure, present a more significant threat to human safety than unmanned 

aircraft. 

Operation of the unmanned aircraft (UA) included in this petition under the 

conditions established by the FAA, are inline with the intentions of Congress as directed 

in SEC. 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95 (P.L. 112-

95). Section 333 provides for a determination of exemption if the characteristics of the 

sUAS and its operations, including, 1) size, 2) weight, 3) speed, 4) operational capability, 5) 

proximity to airports and populated areas, and 6) operation within visual line of sight, do 

not create a hazard to users of the national airspace system or the public or pose a threat 

to national security. The UA listed in this petition are small aircraft, weighing less than 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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55 lbs. and will be operated at slow speeds, close to the ground, during daytime Visual 

Flight Rules (VFR) conditions, and within visual line of sight. Operations of UA for 

natural resource and agricultural applications will typically occur in undeveloped and 

unpopulated areas. For any operation that would require exceeding the conditions of the 

“blanket” COA, or the conditions of this exemption, or any future FAA final rule, 

Christopher E. Muhl will obtain an ATO issued COA and operate by the conditions 

prescribed therein. 

For any additional information or clarification, please do not hesitate to contact 

Mr. Muhl whenever is convenient for you. 

Thank you,

Christopher E. Muhl

16706 Monte Alto Place

Pacific Palisades, California, 90272

Tel: (310) 699-0881

Email: cmuhl999@gmail.com

Table 1. FAA Previously Issued Grants of Exemption for Listed sUAS

Aircraft Exemption No. 

3DR X8 12501, 14453

3DR Aero 12501, 14453, 13208

DJI F550 13332

DJI F450, 14502, 13332

DJI S1000 11753, 12531

DJI S900 14502, 13332, 11309A

DJI Phantom 2 12531

DJI Phantom 2 Vision 12531

DJI Phantom 2 Vision+ 12531, 12991, 14662

DJI Phantom 3 12991

DJI Inspire 1 12531, 12991, 14662

Precision Hawk Lancaster 11253A

Publishable Summary 

A. Specific Applicable Regulations From Which Relief Is Required 

Christopher E. Muhl seeks exemption from the requirements of 14 C.F.R. part 21, 

subpart H; and Sections 61.23 (a) and (c), 61.101 (e) (4) and (5), 61.113 (a), 61.315 (a), 91.7 (a), 

91.119 (c), 91.121, 91.151 (a) (1), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (2), and 91.417 (a) and 

(b), to operate Small Unmanned Aircraft Systems (sUAS) pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 P.L. 112-95).
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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B. An Equivalent Level of Safety 

An equivalent level of safety will be achieved with respect to manned aircraft, as 

the use of the UA listed herein significantly reduces potential risks to life and property. 

Manned fixed-wing aircraft and rotorcraft are inherently more mechanically complex, 

weigh thousands of pounds, carry highly explosive fuel, lack the breadth of failsafe 

functions of sUAS and UAS, and when operated in close proximity to people and 

infrastructure, present a more significant threat to human safety than unmanned 

aircraft. Section 333 provides for a determination of exemption if the characteristics of the 

sUAS and its operations, including, 1) size, 2) weight, 3) speed, 4) operational capability, 5) 

proximity to airports and populated areas, and 6) operation within visual line of sight, do 

not create a hazard to users of the national airspace system or the public or pose a threat 

to national security. The UA listed in this petition are small aircraft, weighing less than 

55 lbs. and will be operated at slow speeds, close to the ground, during daytime Visual 

Flight Rules (VFR) conditions, and within visual line of sight. Operations of UA for 

natural resource and agricultural applications will typically occur in undeveloped and 

unpopulated areas. 

C. The Public Interest 

Christopher E. Muhl engages projects related to natural resources and 

agriculture. Those projects related to natural resources incorporate monitoring and 

analyzing interactions between developed and undeveloped areas, and the components 

and patterns inherent within each ecosystem. Projects related to agriculture include 

water resources monitoring, crop yield analysis, and topographic surveying. Mr. Muhl

specializes in the development of orthophotographs, 3-dimensinional models, and digital 

surface and digital terrain models for use in GIS and remote sensing transformations. 

The services and products rendered and produced, aid in improving management 

decisions for natural resources and agriculture. UAS and sUAS provide data of the 

highest spatial and temporal resolutions, and at a cost significantly less than that 

produced via manned aircraft. As such, an exemption will enable Mr. Muhl to produce 

products and services of the highest quality, at reasonable price points, and in a manner 

safer than would be possible with manned aircraft. 

D. The Unmanned Aircraft Systems 

A grant of this petition permits Christopher E. Muhl to operate the 3D Robotics 

X8+, 3D Robotics Aero, 3D Robotics Solo, DJI F550, DJI F450, DJI S1000, DJI S900, DJI 

Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision+, DJI Phantom 3, DJI Inspire 1, 

and Precision Hawk Lancaster unmanned aircraft systems. All aircraft covered in this 

petition for exemption are battery-powered, weigh less than 55 lbs. (all-up weight –

including batteries and payload), and will be operated in accordance with the FAA’s 

conditions for the category of sUAS, and under the conditions of the “blanket” Certificate 

of Waiver or Authorization (FAA Form 7711-1 UAS COA) issued with the Section 333 

exemption, or as may be established by the FAA in a grant of this petition, or as may be 

established by the FAA in any future final rule, or as otherwise defined by an Air Traffic 

Organization (ATO) issued COA. 

Operator’s Name and Address 

The name and address of the Operator is: 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Christopher E. Muhl

16706 Monte Alto Place

Pacific Palisades, California, 90272

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

Christopher E. Muhl

16706 Monte Alto Place

Pacific Palisades, California, 90272

Tel: (310) 699-0881

Email: cmuhl999@gmail.com

About the Operator 

Christopher E. Muhl holds a degree in environmental science with an emphasis in 

geospatial science, and has worked with sUAS in natural resource applications for over 

two years. Mr. Muhl’s education, training, and research encompass GIS, remote sensing, 

mobile mapping, web mapping, web development, and geospatial programming. More 

specifically, he has worked to develop data acquisition and processing pipelines, 

integrating geospatial programming and Structure from Motion (SfM) software, to 

utilize sUAS acquired data in geographic information systems and within online web 

mapping environments. 

Mr. Muhl engages projects related to natural resources and agriculture. Those 

projects related to natural resources incorporate monitoring and analyzing interactions 

between developed and undeveloped areas, and the components and patterns inherent 

within each ecosystem. Projects related to agriculture include water resources 

monitoring, crop yield analysis, and topographic surveying. He specializes in the 

development of orthophotographs, 3-dimensinional models, and digital surface and 

digital terrain models for use in GIS and remote sensing transformations. The services 

and products rendered and produced, aid in improving management decisions for 

natural resources and agriculture. 

A grant of this exemption request will enable Mr. Muhl to offer sUAS and 

geospatial services to a variety of clients, including federal, state, and local government 

agencies, and non-governmental organizations, other businesses, and private landowners.

UAS and sUAS provide data of the highest spatial and temporal resolutions, and at a cost 

significantly less than that produced via manned aircraft. As such, an exemption will 

enable Mr. Muhl to produce products and services of the highest quality, and at 

reasonable price points. 

Mr. Muhl is a member of the Academy of Model Aeronautics (AMA) and holds 

considerable experience operating multirotor and fixed-wing aircraft as a hobbyist. 

Maintaining An Equivalent Level Of Safety 

Safety Of Life And Property 

An equivalent level of safety will be achieved with respect to manned aircraft, as 

the use of the UA listed herein significantly reduces potential risks to life and property. 

Manned fixed-wing aircraft and rotorcraft are inherently more mechanically complex, 

weigh thousands of pounds, carry highly explosive fuel, lack the breadth of failsafe 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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functions of sUAS and UAS, and when operated in close proximity to people and 

infrastructure, present a more significant threat to human safety than unmanned 

aircraft. Section 333 provides for a determination of exemption if the characteristics of the 

sUAS and its operations, including, 1) size, 2) weight, 3) speed, 4) operational capability, 5) 

proximity to airports and populated areas, and 6) operation within visual line of sight, do 

not create a hazard to users of the national airspace system or the public or pose a threat 

to national security. The UA listed in this petition are small aircraft, weighing less than 

55 lbs. and will be operated at slow speeds, close to the ground, during daytime Visual 

Flight Rules (VFR) conditions, and within visual line of sight. Operations of UA for 

natural resource and agricultural applications will typically occur in undeveloped and 

unpopulated areas. 

 Christopher E. Muhl will conduct UA operations in accordance with the 

conditions of the “blanket” COA (FAA Form 7711-1 UAS COA) issued with the Section 333 

exemption, or as may be established by the FAA in a grant of this petition, or as may be 

established by the FAA in any future final rule, or as otherwise defined by an Air Traffic 

Organization (ATO) issued COA. 

Information on specific operating and safety procedures can be found in the 

Appendices to this petition. The following are provided:

1. Appendix B: Preflight, Launch and Recovery

2. Appendix C: Operations & Emergency Procedures

3. Appendix D: Lost Communication

4. Appendix E: Lost Link Mission

5. Appendix F: Communications

6. Appendix G: Control Station

Public Privacy and National Security 

All operations will occur on lands, which the Operator has been granted 

permission to access and acquire data upon by the owner or governing agency. In so 

doing, there will be no violation of public privacy. In any scenario in which data contains 

a nonparticipating individual(s), measures will be taken to blur or remove the 

individual(s) to protect his or her privacy. Furthermore, applications of UA for natural 

resources and agriculture typically occur in undeveloped and unpopulated areas where a 

violation of public privacy is inherently minimal to nonexistent. 

Christopher E. Muhl will adhere to the Association of Unmanned Vehicle 

Systems International’s Code of Conduct, available at http://www.auvsi.org/conduct.

The PIC must hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate, as prescribed by 14 CFR part 61. Under these conditions, the PIC 

will have been screened by the Department of Homeland Security, and as such, UA 

operations present no threat to national security.

The Public Interest 

The utilization of UA for aerial surveying, data collection, and the development 

of geographic information systems (GIS) for natural resource and agricultural 

applications provide several benefits to the general public. Unmanned aircraft provide a 

means to data acquisition that enhances data quality via unmatched spatial and temporal 

resolutions. Such data is critical to improving the scientific understanding of interactions 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

10

between developed and undeveloped areas, and the components and patterns inherent 

within each ecosystem. The acquisition of higher quality data, analyzed and distributed in 

near real-time, can greatly improve how natural and agricultural resources are managed. 

Applications of UA for natural resource monitoring have already proven 

invaluable to furthering the scientific understanding of anthropogenic events on natural 

systems. UA greatly enhance the ability to monitor the impacts of climate change, 

drought, urban development, pollution, deforestation, poaching, forest pathogens, 

estuarine eutrophication, habitat restoration, and so forth. With each year, the condition 

of the planet becomes increasingly critical. Monitoring the growing number of 

environmental epidemics via satellites and manned aircraft is cost prohibitive. 

Furthermore, launching and operating satellites and manned aircraft via fossil fuels to 

monitor problems that have arisen through the combustion of fossil fuels is 

unreasonable. The operation of UA for natural resource monitoring is both 

environmentally conscious and cost effective.

Unmanned aircraft have demonstrated their utility in agriculture for over 20 

years. UA are a leading technology in precision agriculture. UA have been used 

extensively to perform crop assessments via true color images and false color composites, 

topographic surveys for irrigation, and to aid in precise applications of plant nutrients 

and pesticides/herbicides. The application of UA in agriculture can greatly enhance crop 

yield, while reducing pesticide/herbicide overspray. The end result equates to higher 

returns for farmers, while reducing impacts of agricultural runoff on natural ecosystems, 

waterways, aquifers, and the ocean. 

Monitoring anthropogenic and natural systems via manned aircraft to the extent 

possible with unmanned aircraft is not only cost-prohibitive, but would also result in 

hazardous levels of congestion within the National Air Space. When operated in 

accordance with the FAA’s guidelines, UA provide a means to data acquisition that 

significantly enhances the safety of the general public. 

Given the foregoing, and satisfaction of the following criteria of Section 333, 

namely, the 1) size, 2) weight, 3) speed, 4) operational capability, 5) proximity to airports 

and populated areas, and 6) operation within visual line of sight, the FAA should have 

good cause to determine that a grant of this petition is in the public interest. 

Unmanned Aircraft Operator, PIC, and VO 

The Operator 

Christopher E. Muhl will serve as the Operator for any UA operated under this 

exemption. Mr. Muhl will ensure that the PIC and the VO hold the appropriate training 

and certifications required to operate a UA in accordance with the conditions of this 

exemption. 

Qualifications Of The PIC, Medical Standards And Certifications 

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

commercial, private, recreational, or sport pilot certificate, as prescribed by 14 CFR part 

61. The PIC must also hold a current FAA airman medical certificate, as prescribed by 14 

CFR part 67, or a valid U.S. driver's license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

11

the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC 

is rated on his or her pilot certificate. Under these conditions, the PIC will have been 

screened by the Department of Homeland Security, and as such, UA operations present 

no threat to national security.

Specifically, the PIC will hold, at a minimum, a sport pilot certificate, and a 

current third-class FAA airman medical certificate, or a valid U.S. driver's license. 

Please note that PIC qualifications should be contingent on any future FAA 

determination (Final Rule) on PIC qualifications for operating small unmanned aircraft 

systems. With respect to the foregoing, the PIC will hold, at a minimum, the 

certifications and qualifications required by the FAA presently, or in any future final 

rule.

The Crew 

The UA flight crew will consist of the PIC and the VO. The PIC is responsible for 

the operation of the UA. The VO is responsible for visually observing the UA during 

flight, monitoring the surroundings of the study area for hazards, and relaying critical 

information to the PIC. Both the PIC and the VO will receive training on UA flight 

characteristics, general UA operating procedures, mission planning and operations, and 

emergency procedures. The PIC and VO will be trained in the general operational 

characteristics of each UA listed in this petition. 

For more information on PIC and VO responsibilities and emergency procedures, 

please see Appendix C: Operations & Emergency Procedures.

Proposed Operations of the Unmanned Aircraft 

A. Identification and Registration Markings 

All UAs will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, and identified by serial number, registered in accordance with 14 CFR part 47, 

and have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart 

C. Markings will be as large as practicable.

B. Flight Planning, Operations, and Conditions 

This exemption will permit Christopher E. Muhl to operate sUAS for aerial 

surveying, data collection, and the development of geographic information systems (GIS) 

for natural resource and agricultural applications. 

 UA operations will be conducted in accordance with the Conditions and 

Limitations established by the FAA in a grant of this petition. The proposed Conditions 

and Limitations of this petition are listed below under Proposed Conditions and 

Limitations Of The Exemption. 

The flight crew will consist of the PIC and the VO. The VO will be positioned to 

assist the PIC, to exercise the see-and-avoid responsibilities required by § 91.111, 91.113, and 

91.115 by scanning the area around the aircraft for potentially conflicting traffic and 

assisting the PIC with navigational awareness.
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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For each flight, a geofence will be programmed into the mission, restricting the 

UA’s range of movement to the area of operations. All operations will be conducted 

below 400 ft. above ground level (AGL). The UA will never be operated at a speed 

exceeding 87 knots (100 miles per hour), nor will the UA be operated at airspeeds greater 

than the maximum UA operating airspeed recommended by the aircraft manufacturer.

The UA will only be operated in visual meteorological conditions (VMC), and when 

visibility is at least 3 statue miles form the PIC. Operations of the UA will never be less 

than 500 feet below a cloud, nor less than 2,000 feet horizontally from a cloud. All Flight 

operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures, except where FAA approved conditions have been satisfied.

Prior to each flight, a preflight safety risk assessment will be conducted. The 

assessment will review the planned operations, and determine hazards and safety 

mitigations. Detailed plans will be developed to mitigate the risk of collision with other 

aircraft and the risk posed to persons and property on the ground in the event the UAS 

experiences a lost link, needs to divert, or the flight needs to be terminated. For each 

operation, the PIC/Operator will establish Lost Link Points (LLP), Divert/Contingency 

Points (DCP) and Flight Termination Points (FTP). FTPs will be located no closer than 

five nautical miles (NM) from any airport, heliport, airfield, NAVAID, airway, populated 

area, major roadway, oil rig, power plant, or any other infrastructure.

UA operations will not be conducted over populated areas or over heavily 

trafficked roads or open-air assembly of people. The UA will be operated beyond the 

following distances from the airport reference point (ARP) of a public use airport, 

heliport, gliderport, seaplane base and military airports listed in the Airport/Facility 

Directory, Alaska Supplement, or Pacific Chart Supplement of the U.S. Government 

Flight Information Publications.

a) 5 nautical miles (NM) from an airport having an operational control tower; or

b) 3 NM from an airport having a published instrument flight procedure, but not 

having an operational control tower; or

c) 2 NM from an airport not having a published instrument flight procedure or an 

operational control tower; or

d) 2 NM from a heliport, gliderport or seaplane base

Radio frequency spectrums for UA operated under this petition include the 

unlicensed bands (900 megahertz (MHz), 2.4 gigahertz (GHz), and 5.8 (GHz). Specifically, 

915 MHz and 2.4 GHz will be used for communication between the aircraft, the ground 

station, and the transmitter. Data captured via sensors onboard the aircraft, will be 

transmitted on the 5.8 GHz spectrum. Given these conditions, a license from the FCC as 

authorization to transmit is not required. 

To aid the PIC and VO in operating UA safely, the Operator has created the sUAS 

Operations and Emergency Procedures document. This document is attached in 

Appendix C. 

C. The Small Unmanned Aircraft Systems 

UA specifications are described in Appendix A: Aircraft Make and Model.

The proposed aircraft for this Petition for Exemption are:

• 3D Robotics X8+
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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• 3D Robotics Aero

• 3D Robotics Solo

• DJI F550

• DJI F450

• DJI S1000

• DJI S900

• DJI Phantom 2

• DJI Phantom 2 Vision

• DJI Phantom 2 Vision+

• DJI Phantom 3

• DJI Inspire 1

• Precision Hawk Lancaster 

Proposed Conditions and Limitations Of The Exemption 

1. Operations authorized by this grant of exemption are limited to the 3D Robotics 

X8+, 3D Robotics Aero, 3D Robotics Solo, DJI F550, DJI F450, DJI S1000, DJI S900, 

DJI Phantom 2, DJI Phantom 2 Vision, DJI Phantom 2 Vision+, DJI Phantom 3, DJI 

Inspire 1, and Precision Hawk Lancaster unmanned aircraft systems when 

weighing less than 55 pounds including payload. Proposed operations of any other 

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

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

not permitted.

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

The exemption holder may use either groundspeed or calibrated airspeed to 

determine compliance with the 87 knot speed restriction. In no case will the UA 

be operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer.

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

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

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

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate or U.S. driver’s license.

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

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

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

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

times; electronic messaging or texting is not permitted during flight operations. 

The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can 

perform the duties required of the VO.

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

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

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

operating documents must be accessible during UAS operations and made 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

14

available to the Administrator upon request. If a discrepancy exists between the 

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

operating documents, the conditions and limitations herein take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined 

in its operating documents. The operator may update or revise its operating 

documents. It is the operator’s responsibility to track such revisions and present 

updated and revised documents to the Administrator or any law enforcement 

official upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to this grant of exemption. 

If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an 

amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS−80) may be contacted if questions arise regarding updates or revisions to 

the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations 

under this exemption. Functional test flights may only be conducted by a PIC 

with a VO and must remain at least 500 feet from other people. The functional 

test flight must be conducted in such a manner so as to not pose an undue hazard 

to persons and property.

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

that it is in a condition for safe operation.

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

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

for all potential discrepancies, e.g., inoperable components, items, or equipment. 

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

aircraft is prohibited from operating until the necessary maintenance has been 

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

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

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

components.

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

safety bulletins.

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

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

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

issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or 

the Federal government. The PIC must also meet the flight review requirements 

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

pilot certificate.

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

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

operated under this exemption, including evasive and emergency maneuvers and

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

PIC qualification flight hours and currency must be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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determining the PIC’s ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption are permitted under the 

terms of this exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

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

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

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

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

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on 

the current FAA-published aeronautical chart, unless a letter of agreement with 

that airport’s management is obtained or otherwise permitted by a COA issued to 

the exemption holder. The letter of agreement with the airport management 

must be made available to the Administrator or any law enforcement official 

upon request.

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

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

PIC.

18. For tethered UAS operations, the tether line must have colored pennants or 

streamers attached at not more than 50-foot intervals beginning at 150 feet above 

the surface of the earth and visible from at least 1 mile. This requirement for 

pennants or streamers is not applicable when operating exclusively below the top 

of and within 250 feet of any structure, so long as the UA operation does not 

obscure the lighting of the structure.

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

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

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

emergencies.

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

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

conduct the intended operation and to operate after that for at least five minutes 

or with the reserve power recommended by the manufacturer if greater.

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

operations shall be conducted in accordance with an ATO-issued COA. The

exemption holder may apply for a new or amended COA if it intends to conduct

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

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

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

identification (N−Number) markings in accordance with 14 CFR part 45, Subpart 

C. Markings must be as large as practicable.

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

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be 
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

16

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request.

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

activities at all times.

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

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

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately in a manner ensuring the safety of nonparticipating persons; 

and

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

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be 

reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents 

must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov.
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Appendix A: Aircraft Make and Model 

3D Robotics X8+ Technical Specifications 

3D Robotics X8+ 

The 3D Robotics X8+ is a remotely operated, multi-rotor, electric small unmanned 

aircraft system (sUAS) designed to carry imaging sensors up to 1.76 lbs (0.8 kg) in weight. 

Autonomous flight functions and enhanced flight characteristics and fail-safes are 

provided by the 3DR Pixhawk flight controller. The aircraft is operated via a FlySky FSTH9X 9-channel transmitter, and via commands from the ground station, which includes 

a laptop computer equipped with Mission Planner ground station, and radio air and 

ground modules. The ground station provides mission planning (mapping interface 

includes no-fly zones), telemetry log recording and mission analysis, real-time flight 

data, real-time flight tracking and terrain following for enhanced spatial awareness and 

safety, GPS waypoint navigation, and the ability to define horizontal and vertical 

geofences. 

The X8+ can autonomously launch, execute a mission, and land without input from the 

pilot-in-command (PIC)/operator. Situational awareness during autonomous flight is 

achieved through, 1) line-of-site flight, 2) live-tracking and terrain following via the 

ground station, 3) real-time flight data (providing latitude, longitude, altitude, airspeed, 

battery life, and mission updates), and 4) constant observation by the PIC and observer. 

Type 

Octo-copter 

Model 

3D Robotics X8+

Dimensions 

Width (with propellers): 29.5 in (74.93 cm)

Length: 13.7 in (35 cm)

Height: 11.8 in (20 cm)

Weight and Payload 

Aircraft Weight (with battery): 5.6 lbs (2.56 kg)

Payload Capacity: 1.76 lbs (0.8 kg)

Materials 

Airframe: Aluminum and Carbon Fiber

Camera Mount & Gimbal: Aluminum and Acrylonitrile-Butadiene-Styrene (ABS)

Propeller: Nylon

Propeller 

Number: 8 propellers (8 motors)
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Propeller: 4 APC Propeller slow-fly (11x4.7), 4 APC Propeller slow-fly pusher (11x4.7)

Diameter: 11 in

Pitch: 4.7

Weight: 0.49 ounces (13.89 grams)

Motor and Electronic Speed Controller (ESC) 

Motor Model: SunnySky V2216-12 KV800 II motor

Motor type: Brushless

Number of Motors: 8

Motor Weight: 2.65 ounces (75 grams)

Motor Max Continuous Current (A): 17A

Motor Max Continuous Power (W): 180W

Motor Max Efficiency Current: 5-15A > 80%

ESC: 3D Robotics 20A with SimonK

ESC Output: Continuous 20A, Burst 25A up to 10 seconds

ESC Input Voltage: 2-4 cells lithium battery or 5-12 cells NiCd/NIHM battery

ESC BEC: 2A / 5V

Max Speed: 35,000rpm for 12 poles BLM

Weight: 0.74 ounces (21 grams)

Other Requirements 

Maximum Operational Wind Speed: 22.40 mph (10 m/s)

Flight Characteristics 

Climb Rate: 6 ft/sec

Descent Rate: 5 ft/sec

Turn Rate: 90 degrees/sec

Cruise Speed: 11.18 mph (5 m/s)

Maximum Speed: 15.7 mph (17 m/s)

Maximum Altitude ASL: 328 ft (100 m) with default geofence

Maximum Altitude (considering flight time and reserve): 2,000 ft (609.6 m)

Maximum Range: 984 ft (300 m) with default geofence 

Maximum Flight Time: 15 minutes

Launch Type: Vertical-launch

Landing Type: Vertical-landing

Autonomous Landing Accuracy: 8.2 ft (2.5 m)

GPS 

3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update)

Specifications:

• u-blox NEO-7 module

• 5 Hz update rate

• Ceramic patch antenna

• LNA and SAW filter

• Rechargeable 3V lithium backup battery

• Low noise 3.3V regulator

• Power and fix indicator LEDs

• Weight: 0.59 ounces (16.8 grams)
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Digital airspeed sensor 

Specifications:

• Measurement Specialties 4525DO sensor

• 1 psi measurement range (≈up to 100 m/s or 360 km/h or 223 mph)

• 0.84 Pa resolution, with 

• Data delivered at 14 bits from a 24 bit delta-sigma ADC 

• Temperature measurements to allow calculation of true airspeed from indicated 

airspeed using the MS5611 static pressure sensor

Telemetry Data Recording 

Flight Data Recording: On-Board and ground station

On-board data stored to: 2Gb MicroSD memory card

Ground station data stored to: “Logs” subfolder in the Mission Planner installation folder

Data Recorded: 

• ATT (attitude information)

• ATUN (auto tune overview)

• ATDE (auto tune step details)

• CAM (time and position when camera shutter was activated)

• GPSTime (the GPS reported time since epoch in milliseconds)

• CMD (commands received from the ground station or executed as part of a 

mission)

• COMPASS (raw compass, offset and compassmot compensation values)

• CURRENT (battery voltage, current and board voltage information)

• CTUN (throttle and altitude information)

• D32, DU32 (single data values which are either signed 32bit integers or unsigned 

32bit integers)

• EKF (Extended Kalman Filter)

• ERR (error messages)

• EV (event numbers)

• GPS (status, time, number of satellites, HDop, Lat, Lng, RelAlt, Alt, SPD, GCrs)

• IMU (accelerometer and gyro information)

• Mode (flight mode)

• NTUN (navigation information)

• PM (performance monitoring)

• RCOUT (pwm output to individual RC outputs)

RF Communications 

915 MHz Link

• Aircraft to ground and ground to aircraft (2-way)

• Aircraft Antenna: Dipole swivel

• Controller Antenna: Dipole swivel

• Transmission Power: 100 mW maximum output power (adjustable)

• Receiver sensitivity: -117 dBm receive sensitivity

• Supply voltage: 3.7-6 VDC (from USB or DF13 connector)

• Transmit current: 100 mA at 20 dBm

• Receive current: 25 mA

• Serial interface: 3.3 V UART

• Range: 0.6 miles (1 km)
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Power Source 

Cell chemistry: Lithium Polymer

Voltage: 14.8V

Capacity: 10,000 mAh

Cell Configuration: 4S (4-series)

Recharge Time: 1 hr (after typical flight)

Length: 6.6 in (16.7 cm)

Width: 2.6 in (6.5 cm)

Height: 1.4 in (3.5 cm)

Weight: 28.33 ounces (803 grams)

Camera Attachments 

Static camera mount and dampening system

2-Axis gimbal and dampening system

24MP Sony Alpha 5100 mirrorless digital camera

14MP Canon G10 digital camera

12MP Canon S100 digital camera

FLIR thermal cameras

Tetracam multispectral cameras

MicaSense RedEdge multispectral camera

3D Robotics Aero Technical Specifications 

3D Robotics Aero 

The 3D Robotics Aero is a remotely operated, fixed-wing, electric small unmanned 

aircraft system (sUAS) designed to carry imaging sensors up to 4.41 lbs (2 kg) in weight. 

Autonomous flight functions and enhanced flight characteristics and fail-safes are 

provided by the 3DR Pixhawk flight controller. The aircraft is operated via a Spectrum 

DX7 7-channel transmitter equipped with an LCD monitor, and via commands from the 

ground station, which includes a laptop computer equipped with Mission Planner ground 

station, and radio air and ground modules. The ground station provides mission planning 

(mapping interface includes no-fly zones), telemetry log recording and mission analysis, 

real-time flight data, real-time flight tracking and terrain following for enhanced spatial 

awareness and safety, GPS waypoint navigation, and the ability to define horizontal and 

vertical geofences. 

Following hand launch, the Aero can autonomously execute a mission, and land without 

input from the pilot-in-command (PIC)/operator. Situational awareness during 

autonomous flight is achieved through, 1) line-of-site flight, 2) first-person-view (FPV) via 

the ground station monitor, 3) live-tracking and terrain following via the ground station, 

4) real-time flight data (providing latitude, longitude, altitude, airspeed, battery life, and 

mission updates), and 5) constant observation by the PIC and observer. 

Type 

Fixed-wing single motor aircraft

Model 

3D Robotics Aero
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Dimensions 

Width - Wingspan: 74 in (188 cm)

Length: 51 in (129 cm)

Internal Payload Volume: 280 cm3

Weight and Payload 

Aircraft Weight (with battery): 6.8 lbs (3 kg)

Payload Capacity: 4.41 lbs (2 kg)

Materials 

Airframe: Expanded PolyOlefin (EPO)

Camera Mount & Gimbal: Acrylonitrile-Butadiene-Styrene (ABS) 

Propeller: Nylon

Propeller 

Number: Single propeller (single motor)

Propeller: Gemfan nylon electric propeller (11x7)

Diameter: 11 in

Pitch: 7 

Weight: 0.81 ounces (23 grams)

Motor and Electronic Speed Controller (ESC) 

Motor Model: RC Tiger Motor 2820 830kv motor

Motor type: Brushless

Number of Motors: 1

Motor Weight: 4.66 ounces (132 grams)

Motor Max Continuous Current (A): 42A

Motor Max Continuous Power (W): 668W

Motor Max Efficiency Current: 10-32A > 75%

ESC: RC Tiger Motor 60A

ESC Output: Continuous 60A, Burst 80A up to 10 seconds

ESC Input Voltage: 2-6 cells lithium battery or 5-18 cells NiCd/NIMh battery

ESC BEC: Pentium-60A: 3A / 5V (switch mode)

Max Speed: 35,000rpm for 12 poles BLM

Weight: 2.12 ounces (60 grams)

Other Requirements 

Maximum Operational Wind Speed: 25 mph (11 m/s)

Flight Characteristics 

Climb Rate: 3.5 ft/sec

Descent Rate: 3.5 ft/sec

Turn Rate: 3 degrees/sec

Cruise Speed: 33 mph (15 m/s)

Maximum Speed: 56 mph (90 km/hr)

Minimum Speed: 22 mph (35 km/hr)

Maximum Altitude ASL: 6,500 ft 

Maximum Flight Time: 40 minutes
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Launch Type: Hand-launch

Landing Type: Belly-landing

Autonomous Landing Accuracy: 6.5 ft latitude x 131 ft longitude (2 m x 40 m)

GPS 

3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update)

Specifications:

• u-blox NEO-7 module

• 5 Hz update rate

• Ceramic patch antenna

• LNA and SAW filter

• Rechargeable 3V lithium backup battery

• Low noise 3.3V regulator

• Power and fix indicator LEDs

• Weight: 0.59 ounces (16.8 grams)

Digital airspeed sensor 

Specifications:

• Measurement Specialties 4525DO sensor

• 1 psi measurement range (≈up to 100 m/s or 360 km/h or 223 mph)

• 0.84 Pa resolution, with 

• Data delivered at 14 bits from a 24 bit delta-sigma ADC 

• Temperature measurements to allow calculation of true airspeed from indicated 

airspeed using the MS5611 static pressure sensor

Telemetry Data Recording 

Flight Data Recording: On-Board and ground station

On-board data stored to: 2Gb MicroSD memory card

Ground station data stored to: “Logs” subfolder in the Mission Planner installation folder

Data Recorded: 

• ATT (attitude information)

• ATUN (auto tune overview)

• ATDE (auto tune step details)

• CAM (time and position when camera shutter was activated)

• GPSTime (the GPS reported time since epoch in milliseconds)

• CMD (commands received from the ground station or executed as part of a 

mission)

• COMPASS (raw compass, offset and compassmot compensation values)

• CURRENT (battery voltage, current and board voltage information)

• CTUN (throttle and altitude information)

• D32, DU32 (single data values which are either signed 32bit integers or unsigned 

32bit integers)

• EKF (Extended Kalman Filter)

• ERR (error messages)

• EV (event numbers)

• GPS (status, time, number of satellites, HDop, Lat, Lng, RelAlt, Alt, SPD, GCrs)

• IMU (accelerometer and gyro information)
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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• Mode (flight mode)

• NTUN (navigation information)

• PM (performance monitoring)

• RCOUT (pwm output to individual RC outputs)

RF Communications 

915 MHz Link

• Aircraft to ground and ground to aircraft (2-way)

• Aircraft Antenna: Dipole swivel

• Controller Antenna: Dipole swivel

• Transmission Power: 100 mW maximum output power (adjustable)

• Receiver sensitivity: -117 dBm receive sensitivity

• Supply voltage: 3.7-6 VDC (from USB or DF13 connector)

• Transmit current: 100 mA at 20 dBm

• Receive current: 25 mA

• Serial interface: 3.3 V UART

• Range: 0.6 miles (1 km)

5.8GHz Video Link 

• Link Type: Aircraft to Ground (One-Way)

• Transmitter: 5.8 GHz 200 mW Wireless AV Transmitter

• Receiver: 5.8 GHz 32-channel wireless receiver

• Transmitter Antenna: High-gain cloverleaf antennae

• Receiver Antennas: High-gain cloverleaf antennae

• Transmitter Power Consumption: 200mW

• Selectable Channels: CH1: 5705 MHz, CH2: 5685 MHz, CH3: 5665 MHz, CH4: 5645 

MHz, CH5: 5885 MHz, CH6: 5905 MHz, CH7: 5925 MHz, CH8: 5945 MHz

Power Source 

Cell chemistry: Lithium Polymer

Voltage: 14.8V

Capacity: 6,000 mAh

Cell Configuration: 4S (4-series)

Recharge Time: 1 hr (after typical flight)

Length: 6.3 in (16 cm)

Width: 2.0 in (5 cm)

Height: 1.6 in (4 cm)

Weight: 23.99 ounces (680 grams)

Camera Attachments 

Static camera mount and dampening system

2-Axis gimbal and dampening system

24MP Sony Alpha 5100 mirrorless digital camera

14MP Canon G10 digital camera

12MP Canon S100 digital camera

FLIR thermal cameras

Tetracam multispectral cameras

MicaSense RedEdge multispectral camera
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Appendix B: Preflight, Launch and Recovery Procedures 

The proposed UAS operations will occur between 0 ft AGL and 400 ft AGL, and will 

never exceed 400 ft AGL. The process of safely preparing, launching, and recovering a 

UAS during a mission is defined here.

Launch Site and Safety Considerations 

1. Launch site & safety considerations

1.1. Launch site and PIC/operator position

1.1.1. An ideal launch site will:

1.1.1.1. Provide a level launch and landing surface for the aircraft

1.1.1.2. Be free of water, sand, dirt, and other debris than can damage/impair 

the motors and/or the lens of the imaging system 

1.1.2. The pilot position must provide for line-of-site operation at all times

1.1.2.1. Certain locations are more advantageous than others. For example, a 

position on a hilltop can provide the pilot with a better view of both the 

aircraft and the study area it is flying over.

1.1.2.2. When possible, it is advised that the pilot be positioned between the 

aircraft and the sun. When the aircraft is positioned between the sun 

and the pilot, the pilot can lose sight of the aircraft, and subsequently 

lose control.

1.1.3. In some conditions, it is ideal to maintain a position along the perimeter of 

the flight area

1.1.4. When flying manually, flight plans positioned forward of the operator’s 

location are ideal

1.1.5. Balance is impaired while looking up at the aircraft, for this reason, in 

certain areas (e.g., near a steep cliff), it is import that the pilot and team 

members be firmly positioned, or seated for the duration of the flight

1.2. Team position

1.2.1. During launch and landing, it is ideal for all team members to be at least 5 

meters from the aircraft for smaller craft (<3 kg) and 10 meters for larger 

aircraft (>3 kg).

1.2.2. Do not operate an aircraft near a child. If a child is present, ensure that an 

adult (other than the PIC and VO) is present to protect the child in the event 

that the operator loses control of the aircraft. 

1.2.3. When possible, it is ideal that all team members are positioned outside of 

the field-of-view of the camera throughout the flight

1.3. Other safety considerations

1.3.1. During launch, flight and landing, it is important that the PIC, VO, and 

team members maintain spatial awareness. In the event that the PIC should 

lose control of the aircraft, all members must be able to move in the 

direction of safety. 

1.3.2. During flight, the PIC and VO must focus on the location of the aircraft. It is 

highly advised that team members keep a constant look-out for other 

aircraft, birds, and other threats

1.3.3. Avoid flying in areas subject to magnetic or radio interference 

1.3.4. Communication with the PIC and VO by team members should be kept to a 

minimum during a mission, unless to convey information critical to the safe 

operation of the UA

1.3.4.1. Prior to each flight, a preflight briefing will be conducted by the PIC or 

VO, unique UA related terminology will be defined, and two-way radio 

communication will be tested.
CHRISTOPHER E. MUHL – PETITION FOR EXEMPTION

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Preflight 

2. Preflight Checklist

2.1. Review Weather Conditions with the NOAA Aviation Weather Center

2.1.1. Understand general weather patterns for the area

2.1.2. Wind

2.1.2.1. Do not exceed the aircraft’s rating for wind

2.1.2.2. A wind and temperature gauge will be used for monitoring weather

conditions

2.1.3. Avoid extreme temperatures

2.1.4. Consider high humidity

2.1.5. Dew point

2.1.5.1. Ensure that temperature will not reach the stated dew point during 

flight. This can easily be overlooked during long autonomous flights. 

2.1.6. Avoid precipitation

2.2. Aircraft Components

2.2.1. Check all screws to ensure that they are tightened properly

2.2.1.1. This may include:

2.2.1.1.1. Motors

2.2.1.1.2. Arms

2.2.1.1.3. Center plates (top, bottom...)

2.2.1.1.4. Landing legs

2.2.1.1.5. Gimbal, control board, and related components

2.2.1.1.6. Camera mount

2.2.1.1.7. Power Distribution Board (PDB)

2.2.1.1.8. Propellers

2.2.1.1.9. Wings, ailerons, elevator(s), rudder, and linkage

2.2.1.1.10. Wheels

2.2.1.1.11. Other components

2.2.2. Ensure that zip-ties for ESCs and other components are secure

2.2.3. Ensure that motors spin freely

2.2.4. Inspect all solder joints for cracks

2.2.5. Inspect wires for damage

2.2.6. Ensure that motors are clean of dust, sand, hair, and other debris

2.2.7. Inspect threads on propeller shaft for signs of wear or stripping

2.2.8. Ensure that all components are securely fastened (e.g., receiver, flight 

controller, inertial management unit (IMU), power management unit 

(PMU), GPS, LED, electronic speed controllers (ESC), telemetry sensors... 

2.2.9. Check all connectors (e.g., battery to PDB and PDB to PMU)

2.2.9.1. Watch for cracks in brass connectors

2.2.10. Inspect propellers 

2.3. Battery

2.3.1. Check battery voltage

2.3.2. Ensure that battery is mounted properly and securely fastened

2.3.3. Ensure that the battery discharge/balance wires will not contact props 

during flight

2.4. Transmitter

2.4.1. Check battery voltage

2.4.2. Ensure that the correct aircraft model is selected in the transmitter

2.4.3. Ensure that transmitter and receiver are linked

2.4.4. If telemetry sensors are mounted on the aircraft, ensure that the transmitter 

is communicating with them
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2.4.4.1. Program the transmitter so that telemetry data can be monitored 

quickly during flight

2.4.5. Check all switches to ensure that they are functioning properly and in the 

correct positions (e.g., ensure that the desired flight mode is set accordingly)

2.4.6. Check all servo actions

2.4.7. Check antenna angle/position

2.4.8. Perform range test

Launch 

3. All systems go

3.1. Wear protective glasses

3.2. Ensure that propellers are fastened correctly

3.3. Consider the danger zone of the propeller. Insure that the propellers will not 

come into contact with fingers, hands, grass, twigs, or other objects

3.4. All team members should be at least 5 meters from the aircraft for smaller craft 

(<3 kg) and 10 meters for larger aircraft (>3 kg).

3.5. Ensure that the throttle position is at the lowest setting and turn on the 

transmitter first

3.5.1. Always turn on the transmitter first, then turn on the aircraft.

3.5.2. Always turn off the aircraft first, then turn off the transmitter. 

3.6. Ensure that the throttle position is at the lowest setting and turn on the aircraft

3.7. Check for correct audible beeps

3.8. Check for correct LED signals

3.9. Confirm GPS/satellite connectivity/quality

3.10. For fixed-wings, ensure that ailerons, elevator, and rudder move throughout 

their full range of motion and are clear of obstructions

3.10.1.Check servo range and speed

3.11. Press the safety button to allow arming, or equivalent method depending on 

aircraft

3.12. PIC/operator announces “arming”

3.13. Arm the aircraft

3.14. PIC/operator announces “clear prop”

3.15. Engage the motors and throttle up slowly.

3.15.1.Listen for abnormal sounds

3.15.1.1. ESCs not functioning properly can sometimes be identified by sound

3.15.2.PIC/operator announces “take-off”

3.16. For multi-rotors, lift off slowly, enter a hover at approximately 6 feet, and 

confirm that attitude, pitch, roll, yaw, and elevation movements are normal, or as 

desired and adjust trim if necessary

3.17. Ensure that flight data on the transmitter and the ground station are displaying 

properly

3.18. Initiate flight plan

3.19. During flight 

3.19.1.Keep a constant watch on the aircraft 

3.19.2.For manual flight, ensure that stick commands on the transmitter generate 

the appropriate reactions from the aircraft

3.19.3.For autonomous flight, closely monitor flight data for errors messages, and 

visually monitor aircraft for abnormal performance 

3.19.4. Avoid anything which the aircraft could harm, or that could harm the 

aircraft

3.19.5.Pay close attention to voltage warnings, satellite connectivity, RF signal 

quality, and aircraft altitude and air speed

3.19.5.1.Do not over-discharge the battery
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3.19.5.2.Lipo batteries should never be discharge beyond 3.3 volts per cell

3.19.5.3.Ideally, they should not be discharged beyond 3.5 volts per cell to 

ensure maximum battery life

3.19.5.4.Lipo storage voltage is 3.8 volts per cell

Recovery 

4. Landing

4.1. Ensure that the landing area is clear of any obstructions

4.1.1. Clear the area of people

4.1.2. All team members should be at least 5 meters from the aircraft for smaller 

craft (<3 kg) and 10 meters for larger aircraft (>3 kg).

4.2. Ensure that no other hazards are present

4.3. PIC/operator announces “landing”

4.4. Slow aircraft descent

4.5. Land the aircraft

4.6. Disarm the aircraft

4.7. Engage the safety button, or equivalent method depending on aircraft

4.8. Turn off the aircraft

4.9. Turn off the transmitter

4.10. Inspect the aircraft for any damage

4.11. In the event of a crash

4.11.1.Throttle down the aircraft

4.11.2.Locate and visually inspect the aircraft for damage

4.11.3.When retrieving the aircraft, pay close attention to the Lipo battery

4.11.3.1. Lipo batteries must be carefully monitored for a minimum of 15 

minutes following a crash to ensure that they will not combust. It is 

advised to let the battery sit in a safe location of one hour following a 

severe crash. 

4.11.3.2. Ensure that the battery does not puff up

4.11.3.3. Follow the manufacturers procedures for handling and inspecting 

batteries that may be damaged
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Appendix C: Operations & Emergency Procedures 

Chain of Command 

In the event of an emergency, the Operator or PIC will determine if an emergency 

situation exists, determine the correct course of action, and whether or not to activate the 

emergency procedures. The pilot in command (PIC) is responsible for control of the 

aircraft, while the visual observer (VO) assumes the task of directing emergency 

procedures. 

Operator, PIC and VO Duties 

Operator Duties 

a. The Operator or pilot in command (PIC) is responsible for halting or canceling 

activity in the certificate of waiver or authorization (COA) area if, at any time, the 

safety of persons or property on the ground or in the air is in jeopardy, or if there 

is a failure to comply with the terms or conditions of this authorization.

b. The operator or delegated representative must not operate in Prohibited Areas, 

Special Flight Rule Areas or, the Washington National Capital Region Flight 

Restricted Zone. Such areas are depicted on charts available at 

http://www.faa.gov/air_traffic/flight_info/aeronav/. Additionally, aircraft operators 

should beware of and avoid other areas identified in Notices to Airmen 

(NOTAMS) which restricts operations in proximity to Power Plants, Electric 

Substations, Dams, Wind Farms, Oil Refineries, Industrial Complexes, National 

Parks, The Disney Resorts, Stadiums, Emergency Services, the Washington DC 

Metro Flight Restricted Zone, Military or other Federal Facilities.

c. All aircraft operated in accordance with this Certificate of Waiver/Authorization 

must be identified by serial number, registered in accordance with 14 CFR part 47, 

and have identification (N-Number) markings in accordance with 14 CFR part 45, 

Subpart C. Markings must be) as large as practicable.

PIC Duties 

The pilot in command (PIC) is responsible:

d. To remain clear and give way to all manned aviation operations and activities at 

all times,

e. For the safety of persons or property on the surface with respect to the UAS, and

f. For compliance with CFR Parts 91.111, 91.113 and 91.115

a. 91.111 Operating near other aircraft

i. No person may operate an aircraft so close to another aircraft as to 

create a collision hazard.

ii. No person may operate an aircraft in formation flight except by 

arrangement with the pilot in command of each aircraft in the 

formation.

iii. No person may operate an aircraft, carrying passengers for hire, in 

formation flight.

b. 91.113 Right-of-way rules: except water operations
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i. Inapplicability. This section does not apply to the operation of an 

aircraft on water.

ii. General. When weather conditions permit, regardless of whether 

an operation is conducted under instrument flight rules or visual 

flight rules, vigilance shall be maintained by each person 

operating an aircraft so as to see and avoid other aircraft. When a 

rule of this section gives another aircraft the right-of-way, the pilot 

shall give way to that aircraft and may not pass over, under, or 

ahead of it unless well clear.

iii. In distress. An aircraft in distress has the right-of-way over all 

other air traffic.

iv. Converging. When aircraft of the same category are converging at 

approximately the same altitude (except head-on, or nearly so), the 

aircraft to the other's right has the right-of-way. If the aircraft are 

of different categories—

1. A balloon has the right-of-way over any other category of 

aircraft;

2. A glider has the right-of-way over an airship, powered 

parachute, weight-shift-control aircraft, airplane, or 

rotorcraft.

3. An airship has the right-of-way over a powered parachute, 

weight-shift-control aircraft, airplane, or rotorcraft.

4. However, an aircraft towing or refueling other aircraft has 

the right-of-way over all other engine-driven aircraft.

v. Approaching head-on. When aircraft are approaching each other 

head-on, or nearly so, each pilot of each aircraft shall alter course 

to the right.

vi. Overtaking. Each aircraft that is being overtaken has the right-ofway and each pilot of an overtaking aircraft shall alter course to 

the right to pass well clear.

vii. Landing. Aircraft, while on final approach to land or while 

landing, have the right-of-way over other aircraft in flight or 

operating on the surface, except that they shall not take advantage 

of this rule to force an aircraft off the runway surface which has 

already landed and is attempting to make way for an aircraft on 

final approach. When two or more aircraft are approaching an 

airport for the purpose of landing, the aircraft at the lower altitude 

has the right-of-way, but it shall not take advantage of this rule to 

cut in front of another which is on final approach to land or to 

overtake that aircraft.

c. 91.115 Right-of-way rules: water operations

i. General. Each person operating an aircraft on the water shall, 

insofar as possible, keep clear of all vessels and avoid impeding 

their navigation, and shall give way to any vessel or other aircraft 

that is given the right-of-way by any rule of this section.

ii. Crossing. When aircraft, or an aircraft and a vessel, are on crossing 

courses, the aircraft or vessel to the other's right has the right-ofway.

iii. Approaching head-on. When aircraft, or an aircraft and a vessel, 

are approaching head-on, or nearly so, each shall alter its course to 

the right to keep well clear.

iv. Overtaking. Each aircraft or vessel that is being overtaken has the 

right-of-way, and the one overtaking shall alter course to keep well 

clear.
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v. Special circumstances. When aircraft, or an aircraft and a vessel, 

approach so as to involve risk of collision, each aircraft or vessel 

shall proceed with careful regard to existing circumstances, 

including the limitations of the respective craft.

g. UAS pilots will ensure there is a safe operating distance between aviation 

activities and unmanned aircraft (UA) at all times.

h. The PIC is responsible to ensure visual observer(s) are:

a. Able to see the UA and the surrounding airspace throughout the entire 

flight, and

b. Able to provide the PIC with the UA’s flight path, and proximity to all 

aviation activities and other hazards (e.g., terrain, weather, structures) 

sufficiently for the PIC to exercise effective control of the UA to prevent 

the UA from creating a collision hazard.

i. Pilots are reminded to follow all federal regulations e.g. remain clear of all 

Temporary Flight Restrictions, as well as following the exemption granted for 

their operation.

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

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

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

emergencies.

VO Duties 

a. Visual observers must be used at all times and maintain instantaneous 

communication with the PIC.

b. Visual observer(s) must be able to communicate clearly to the pilot any 

instructions required to remain clear of conflicting traffic.

Method for Alerting Ground Crew and Participants 

The VO is responsible for directing emergency procedures and tasks, and ensuring the 

safety of all crew, participants, and bystanders. The VO will announce the nature of the 

emergency, and actions and procedures to be activated.

Method for Reporting Emergencies 

Two forms of communication will be present at all times, including a VHF radio and cell 

phones. In the event that cell service is not available for the operations area, a satellite 

phone will be available. Each member of the UA operations team will have access to a 

cell phone, and knowledge of contact information for emergency and medical related 

services. The VO is responsible for determining which emergency and medical related 

services to contact. 

Emergency Prioritization 

Of greatest importance is the safety of civilians (in the air and on the ground), 

participants, and the ground crew. It is the responsibility of the ground crew to ensure 

the safety of any individual that could be harmed by the operation of a UA. Following 

the protection of life, the ground crew must act to ensure the protection of property. 
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Safety Areas and Evacuation Routes 

Safety areas are locations where ground crew, participants and bystander are protected 

from potential hazards. Safety areas may be unique to each flight location, and may 

include natural barriers (e.g., trees or mounds), or manmade barriers (e.g., vehicles or 

netting). 

Secondary safety locations and evacuation routes will also be identified to ensure that all 

participants can safely evacuate an area in the event of a UA crash. Evacuation routes 

will include least cost paths to nearby emergency and medical services to ensure that 

treatment for injuries can begin as soon as possible. Emergency medical standards state 

that treatment for serious injuries should begin within 3 to 4 minutes of an accident. 

Names, Titles, Telephone Numbers 

Emergency Services (fire, ambulance, police): 911

UAS Operator(s)

• Christopher E. Muhl

Phone: (707) 826-5169

 

Ground Crew and Participant Information 

All ground crew and participants will be required to fill out a personal data/information 

form, which will include names, telephone numbers, next in kin, and medical 

information. Electronic versions of these forms will be stored on the ground station 

computer to be readily available to emergency personnel in the event of an emergency.

Emergency Drills 

Periodically, a mock emergency event will be rehearsed to evaluate the implementation 

of the emergency procedures. Drills will address:

• UAS fly-away

• UAS crash and/or ditching

• UAS fire

• UAS induced injuries (e.g., impact with aircraft, burns from batteries)

Medical Duties 

As a general requirement for UAS operations, at least one member of the UAS team 

must have received CPR/First-Aid training within the past 36 months. 

Pre-Flight Briefing 

The pre-flight briefing will address the following:

• Individual roles and responsibilities

• Threats, hazards, and protective actions

• Worse Case Scenarios
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• Communication procedures

• Emergency response procedures

• Safe-cover locations and evacuation routes

• Location and use of common emergency equipment

• Location of the emergency action plan (EAP)

• Safe landing and ditching locations are defined per FAA guidelines for LLP, DCP, 

and FTP procedures. 

A copy of the emergency action plan will be located at the ground station, and available 

for participant review at all times. 

All participants will be required to review the EAP whenever:

• New equipment or processes are introduced

• Revisions are made to the emergency procedures

Briefings will be conducted for each mission and will address:

• Characteristics of the flight location, as they pertain to the emergency procedures

• New equipment or processes 

• Revisions made to the emergency procedures

Aircraft Operations Emergency Procedures 

For each flight area, the Lost Link Points (LLPs), the Divert/Contingency Points (DCPs), 

and the Flight Termination Points (FTPs) will be defined. With these points in mind, the 

following procedures have been defined. 

For missions covering a small area, only 1 LLP, 1 DCP and 1 FTP may be defined. In some 

cases, the LLP will be the FTP, and/or the DCP will be the home/base location. The FTP 

will always be defined with regard to FAA requirements. Specifically, “FTPs will be 

located no closer than five nautical miles from any airport, heliport, airfield, NAVAID, 

airway, populated area, major roadway, oil rig, power plant, or any other infrastructure.” 

Any exception to the foregoing would be subject to FAA consent. 

5. In the event of:

5.1. Motor Reduced Performance 

5.1.1. Heading – Manually activate Return To Base (RTB) – The base location is 

defined during mission planning

5.1.2. Control -- If autonomous RTB function fails, assume manual control 

5.1.3. Airspeed – Reduce to minimum 

5.1.4. Land

5.1.4.1. Land at the base location

5.1.4.2. If unable to RTB, notify ATC and land at nearest DCP

5.1.5. Ditching

5.1.5.1. If unable to land, notify ATC and conduct ditching procedure at FTP 

(see ditching procedure below)

5.2. Low Battery Voltage 

5.2.1. The flight controller will trigger a RTB if the battery voltage reaches a given 

threshold. 

5.2.2. Heading -- RTB 

5.2.3. Control -- If a RTB is not triggered, the PIC/operator will manually trigger a 

RTB or assume manual control

5.2.4. Airspeed – reduce to minimum
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5.2.5. Land

5.2.5.1. Land at the base location

5.2.5.2. If unable to RTB, notify ATC and land at nearest DCP

5.2.6. Ditching

5.2.6.1. If unable to land, notify ATC and conduct ditching procedure at FTP

5.3. Ground Station Computer Fail 

5.3.1. Monitor flight data on transmitter

5.3.2. Heading -- RTB 

5.3.3. Control -- If a RTB is not triggered, the PIC/operator will manually trigger a 

RTB or assume manual control

5.3.4. Airspeed – reduce to minimum

5.3.5. Land 

5.3.5.1. Land at the base location

5.3.5.2. If unable to RTB, notify ATC and land at nearest DCP

5.3.6. Ditching

5.3.6.1. If unable to land, notify ATC and conduct ditching procedure at FTP

5.4. Ground Station Power Fail 

5.4.1. Monitor flight data on transmitter

5.4.2. Heading -- RTB 

5.4.3. Control -- If a RTB is not triggered, the PIC/operator will manually trigger a 

RTB or assume manual control

5.4.4. Airspeed – reduce to minimum

5.4.5. Land 

5.4.5.1. Land at the base location

5.4.5.2. If unable to RTB, notify ATC and land at nearest DCP

5.4.6. Ditching

5.4.6.1. If unable to land, notify ATC and conduct ditching procedure at FTP

5.5. Auto Pilot Fail 

5.5.1. Control – Switch to manual operation

5.5.2. Heading – Establish a safe heading and RTB

5.5.3. Airspeed – Reduce to minimum

5.5.4. Land 

5.5.4.1. Land at the base location

5.5.4.2. If unable to RTB, notify ATC and land at nearest DCP

5.5.5. Ditching

5.5.5.1. If unable to land, notify ATC and conduct ditching procedure at FTP

5.6. GPS Fail 

5.6.1. If the flight controller fails to receive input from the GPS for a duration 

equal to 5 seconds, the aircraft enters altitude hold.

5.6.2. Control – Switch to manual operation

5.6.3. Heading – Establish a safe heading and RTB

5.6.4. Airspeed – Reduce to minimum

5.6.5. Land 

5.6.5.1. Land at the base location

5.6.5.2. If unable to RTB, notify ATC and land at nearest DCP

5.6.6. Ditching

5.6.6.1. If unable to land, notify ATC and conduct ditching procedure at FTP

5.7. Lost Link and/or Fly-Away 

5.7.1. In the event of a lost link with the transmitter and ground station, the 

aircraft will enter RTB if it has a GPS lock, and land if GPS is not locked. 

5.7.2. A geofence is established around each home/base location. If the aircraft 

breeches the georeference, RTB is activated. 

5.7.3. Control – If RTB or land is not activated, increase transmitter height to 

improve line of sight and/or move closer to the aircraft and attempt to 

regain manual control
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5.7.4. If the link is reestablished:

5.7.4.1. Heading – Establish a safe heading and RTB

5.7.4.2. Airspeed – Reduce to minimum

5.7.4.3. Land 

5.7.4.3.1. Land at the base location

5.7.4.3.2. If unable to RTB, notify ATC and land at nearest DCP

5.7.4.4. Ditching

5.7.4.4.1. If unable to land, notify ATC and conduct ditching procedure at 

FTP

5.7.5. If fail-safes are not activated, and the link is not established, and aircraft 

enters a fly-away

5.7.5.1. Record aircraft position 

5.7.5.2. Record aircraft heading

5.7.5.3. Record aircraft air speed

5.7.5.4. Notify Air Traffic Control (ATC)

5.7.5.5. Follow aircraft in an emergency vehicle and record heading changes to 

ATC.

5.7.5.6. Continue to attempt to regain control

5.8. Ditching procedure (Flight Termination Points) 

5.8.1. NOTE: The ditching procedure is defined in accordance with the FAA’s 

guidelines for the Flight Termination Points (FTP)

5.8.2. Notify ATC

5.8.3. Heading -- Establish a safe heading to ditching area 

5.8.4. Airspeed – Throttle down to minimum airspeed

5.8.5. Upon enter the ditching area, cut throttle

5.8.6. Record last known aircraft position

Ground Crew Emergency Procedures 

The task of calling 911, and other emergency and medical responders, will be assigned to 

an individual ahead of time. All team members will be prepared to do so. 

1.1. UAS Crash 

1.1.1. Of primary safety concern is the lipo battery. Basic safety procedures 

include:

1.1.1.1. Wear eye protection

1.1.1.2. Inspect the aircraft from a distance of at least 10 feet

1.1.1.3. Look for signs of battery damage, such as smoke

1.1.1.3.1. If the battery is smoking, keep a safe distance from the aircraft 

and prepare to use the fire extinguisher

1.1.1.3.1.1. A lipo battery can instantly produce a large and extremely 

high-temperature fire. The temperature of a combusting lipo 

can exceed 1370 degrees Celsius – be prepared for this at any 

time. 

1.1.1.3.2. Locate the battery. Do not handle it. Look for signs of damage, 

such as puffing/bloating of the battery, cracks, ruptures...

1.1.1.3.3. If the battery appears undamaged, check to see if the battery is 

hot to the touch. If the battery is hot, do not handle it. 

1.1.1.3.4. At this point, the team supervisor or pilot can decide whether to 

leave the battery in the aircraft, or to quickly remove it. Either 

way, if possible, place the aircraft or battery in a safe location and 

observe it for a minimum of 15 minutes. It is advised to let the 

battery sit in a safe location of one hour following a severe crash. 
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1.1.1.3.5. Ensure that the battery is placed in a fireproof containing during 

transport, and when placed in storage at the end of the mission. 

1.2. UAS Fire 

1.2.1. Prior to operating all UA team members should be educated about potential 

fire hazards.

1.2.2. Each team member should be instructed on how to use the fire extinguisher.

1.2.3. The task of using the fire extinguisher should go to someone with prior 

experience operating one.

1.2.4. Aim at the base of the fire, and extinguish thoroughly

1.2.5. Dirt can also be added to the fire to help extinguish the blaze. If a shovel is 

on hand, and it is safe to do so, use it.

1.2.6. In the event that the fire appears unmanageable, call 911

1.2.7. The primary concern is the safety of team members and other people Take 

measures to keep all life out of harms way.

1.3. Vegetation Fire 

1.3.1. In the event that a UA crash results in the ignition of vegetation, quickly 

take measures to extinguish the blaze in addition to calling 911. It is always 

better to have call 911 and wish you had not.

1.3.2. Each team member should be instructed on how to use the fire extinguisher.

1.3.3. The task of using the fire extinguisher should go to someone with prior 

experience operating one.

1.3.4. Aim at the base of the fire, and extinguish thoroughly

1.3.5. Dirt can also be added to the fire to help extinguish the blaze. If a shovel is 

on hand, and it is safe to do so, use it.

1.3.6. In the event that the fire appears unmanageable, retreat to a safe distance, 

and ensure that the appropriate emergency responder(s) has been contacted

1.3.7. The primary concern is the safety of team members and other people. Take 

measures to keep all life out of harms way.

1.4. Personal harm caused by aircraft 

1.4.1. RC aircraft propellers and batteries are the most dangerous parts of the 

aircraft.

1.4.1.1. Nature of the accident

1.4.1.1.1. Severe lacerations caused by propellers

1.4.1.1.2. Burns from lipo batteries

1.4.1.1.3. Personal harm caused by hazards in the field

1.4.1.1.3.1. Broken bones, sprained ankles, snake bites...

1.4.1.2. First-aid procedure

1.4.1.2.1. A first-aid kit will be maintained at the ground station

1.4.1.2.2. Follow least cost path to appropriate medical facility

1.4.1.2.3. Alternatively, contact emergency or medical responder

1.4.1.2.4. First-aid information will be provided at the ground station

Reporting 

Incident Reports 

Following any accident or emergency event, a detailed report of the incident, including 

photographs and eyewitness accounts, will be created. The report will be submitted to the 

Incident Supervisor.

Additionally, any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries defined in the COA will be reported to the FAA via email at mailto:9-

AJV-115-UASOrganization@faa.gov within 24 hours. Accidents will be reported to the 
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National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

Web site: www.ntsb.gov.

Documentation 

Documentation of all operations associated with UAS activities is required regardless of 

the airspace in which the UAS operates. NOTE: Negative (zero flights) reports are 

required.

The operator must submit the following information through

mailto:9-AJV-115-UASOrganization@faa.gov on a monthly basis: 

a) Name of Operator, Exemption number and Aircraft registration number 

b) UAS type and model

c) All operating locations, to include location city/name and latitude/longitude

d) Number of flights (per location, per aircraft)

e) Total aircraft operational hours

f) Takeoff or Landing damage

Equipment malfunctions. Reportable malfunctions include, but are not limited to the 

following:

a) On-board flight control system

b) Navigation system

c) Powerplant failure in flight

d) Fuel system failure

e) Electrical system failure

f) Control station failure

The number and duration of lost link events (control, performance and health 

monitoring, or communications) per UA per flight.

Air Traffic Control Special Provisions 

Coordination Requirements 

a) Operators and UAS equipment must meet the requirements (communication, 

equipment and clearance) of the class of airspace they will operate in.

b) Operator filing and the issuance of required distance (D) NOTAM, will serve as 

advance ATC facility notification of UAS operations in an area.

c) Operator must cancel NOTAMs when UAS operations are completed or will not 

be conducted.

d) Coordination and deconfliction between Military Training Routes (MTRs) is the 

operator’s responsibility. When identifying an operational area the operator must 

evaluate whether an MTR will be affected. In the event the UAS operational area 

overlaps (5 miles either side of centerline) an MTR, the operator will contact the 

scheduling agency 24 hours in advance to coordinate and deconflict. Approval 

from the scheduling agency is not required. Scheduling agencies are listed in the 

Area Planning AP/1B Military Planning Routes North and South America, if 

unable to gain access to AP/1B contact the FAA at email address mailto:9-AJV-115-

UASOrganization@faa.gov with the IR/VR routes affected and the FAA will 

provide the scheduling agency information. If prior coordination and 

deconfliction does not take place 24 hours in advance, the operator must remain 

clear of all MTRs.
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Notice to Airmen (NOTAM) 

A distant (D) NOTAM must be issued when unmanned aircraft operations are being 

conducted. This requirement may be accomplished:

a) Through the operator’s local base operations or NOTAM issuing authority, or

b) By contacting the NOTAM Flight Service Station at 1-877-4-US-NTMS (1-877-487-

6867) not more than 72 hours in advance, but not less than 24 hours prior to the 

operation, unless otherwise authorized as a special provision. The issuing agency 

will require the:

a. Name and address of the pilot filing the NOTAM request

b. Location, altitude, or operating area

c. Time and nature of the activity

d. Number of UAS flying in the operating area
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Appendix D: Lost Communications Procedure 

All operations will occur within Class G airspace. Any flight requiring the use of Class B, 

C, or D airspace will not be conducted without written approval from the FAA. The 

ceiling altitude for all the operations is 400 ft AGL. Prior to each mission, Air Traffic 

Control (ATC) will be contacted and briefed on the mission flight plan.

When operating in the vicinity of an airport without an operating control tower, 

operations will be announced in accordance with the FAA Aeronautical Information 

Manual (AIM) 4-1-9 Traffic Advisory Practices at Airports without Operating Control 

Towers.

A VHF radio will be maintained in the field and set to operational frequencies used by 

ATC. To ensure redundancy, a cell phone will also be available for communication with

ATC.

In the event of loss of communication, contact will be established with ATC. Efforts will 

be made to contact the any local airport(s) or airport manager(s).

If a loss of communication occurs, the aircraft will be directed to the lost link flight plan, 

which is return to base (RTB) and land.

During operations, the PIC and VO will be in communication via 2-way radio and/or cell 

phones. In the event of a loss of communication between the PIC and the VO and/or PIC

and ATC/air traffic, the aircraft will be directed to the lost link flight plan, which is RTB 

and land. 
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Appendix E: Lost Link Mission 

Lost link information is also addressed in the EMERGENCY_PROCEDURE document. 

3D Robotics has integrated numerous fail-safe functions into the Pixhawk flight 

controller. These fail-safe functions are developed to ensure that the aircraft will return 

to base (RTB) or otherwise land safely in the event that the PIC/operator has lost control 

of the aircraft. 

A lost link can occur for a variety of reasons. Common causes for lost link events are:

• The RC transmitter power fails (battery failure or the transmitter is turned off)

• The vehicle travels beyond the radio frequency range

• The receiver power fails

• The wires connecting to the receiver to the flight controller are 

disconnected/severed

By default, if a lost link event occurs and the aircraft is in flight, has GPS lock, and is 

more than 2 meters from the home position, RTB is triggered. If GPS lock is not 

established, or the aircraft is within 2 meters of the home location, it will land at its 

current location. 

Lost link procedures, as defined in the EMERGENCY_PROCEDURE document, take into 

consideration FAA guidelines for LLPs, DCPs, and FTPs. For missions covering a small 

area, only 1 LLP, 1 DCP and 1 FTP may be defined. In some cases, the LLP will be the FTP, 

and/or the DCP will be the home/base location. The FTP will always be defined with 

regard to FAA requirements. Specifically, “FTPs will be located no closer than five 

nautical miles from any airport, heliport, airfield, NAVAID, airway, populated area, 

major roadway, oil rig, power plant, or any other infrastructure.” Any exception to the 

foregoing would be subject to FAA consent. 

 The lost link procedure is as follows:

1.1. Lost Link and/or Fly-Away 

1.1.1. In the event of a lost link with the transmitter and ground station, the 

aircraft will enter RTB if it has a GPS lock, and land if GPS is not locked. 

1.1.2. A geofence is established around each home/base location. If the aircraft 

breeches the georeference, RTB is activated. 

1.1.3. Control – If RTB or land is not activated, increase transmitter height to 

improve line of sight and/or move closer to the aircraft and attempt to 

regain manual control

1.1.4. If the link is reestablished:

1.1.4.1. Heading – Establish a safe heading and RTB

1.1.4.2. Airspeed – Reduce to minimum

1.1.4.3. Land 

1.1.4.3.1. Land at the base location

1.1.4.3.2. If unable to RTB, notify ATC and land at nearest DCP

1.1.4.4. Ditching

1.1.4.4.1. If unable to land, notify ATC and conduct ditching procedure at 

FTP

1.1.5. If fail-safes are not activated, and the link is not established, and aircraft 

enters a fly-away

1.1.5.1. Record aircraft position 
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1.1.5.2. Record aircraft heading

1.1.5.3. Record aircraft air speed

1.1.5.4. Notify Air Traffic Control (ATC)

1.1.5.5. Follow aircraft in an emergency vehicle and record heading changes to 

ATC.

1.1.5.6. Continue to attempt to regain control

When fail-safe functions are activated, the nature of the event is displayed on the ground 

station computer, and recorded in the flight telemetry log. These functions provide the 

PIC with real-time information regarding the status of the aircraft during flight, and data 

recording for trouble-shooting in the aftermath of a significant event. 

During a lost link event, the VO is responsible for communicating critical information to 

the PIC, the ground crew, and bystanders. The VO will always collocate, within speaking 

distance, of the PIC.

When a fail-safe is triggered by the flight controller, and the aircraft autonomously 

performs an RTB or lands at the current location, it will automatically disarm the motors 

after landing. At this point, the ground crew will secure the aircraft, and the mission is 

terminated. 
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Appendix F: Communications 

The condition of the aircraft can be monitored at all times via the transmitter and 

separately on the ground control station. This redundancy ensures that in the event that 

one system fails, the other system can be used to monitor the status of the aircraft and 

maneuver the aircraft to a safe landing location. 

Transmitter 

FlySky FS-TH9X with FrSky telemetry module

Transmitter Specifications 

• Frequency: 915 mHz

• Channels: 9

• Model type: helicopter, airplane, glider

• RF power: < 20db

• Modulation: GFSK

• Code type: PPM/PCM

• Sensitivity: 1024

• LCD type: 128 x 64 dot

• Low voltage warning

• DSC port

• Charger port

• Power: 12VDC (1.5AA x 8)

• Weight: 680g

• ANT length: 26mm

• Size: 190 x 80 x 240mm

Transmitter Parameter Adjustments 

• Throttle curves

• Pitch curves

• Endpoint adjustments

• Subtrim

• Swash AFR mixes

• Servo reversing

• Timer

• Dual rate

• Exponential

• Flaperons

• V-Tail mixing

• Elevons

Transmitter Display 

From the transmitter, the PIC/operator can monitor the following aircraft conditions 

during flight:

• GPS status

• Connection strength
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• Altitude in meters

• Speed in meters per second

• Meters from the launch point

• Flight time

• Current flight mode

• GPS signal strength in number of satellites

• Flight battery voltage level

• Flight battery mAh consumed since armed

• Controller battery voltage level

In-Flight Transmitter Parameter Adjustments 

From the ground station the PIC/operator can control the following aircraft functions 

during flight:

• Arm/disarm the aircraft motors

• Throttle, yaw, pitch, roll

• Throttle trim, yaw trim, pitch trim, roll trim

• Flight mode (stabilize, loiter, full autonomy)

• Return-to-launch (RTL), also known as return-to-base (RTB)

• Land at current location

• Camera trigger

• Camera tilt (pitch)

• Additional functions can be programmed via additional channels
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Appendix G: Control Station 

The 3D Robotics Pixhawk flight controller integrates with several ground station 

solutions, including Mission Planner, APM Planner, and DroidPlanner 2. Mission Planner 

will be used for operations with the 3DR Aero and X8+. Mission Planner is a sophisticated 

ground station solution, providing real-time flight monitoring for greater situational 

awareness and enhanced aircraft performance monitoring. Mission Planner also provides 

another level of redundancy, as it can be used to control aircraft functions and fail-safes, 

such as loiter and return-to-base. 

Mission Planner Overview 

Key features of Mission Planner are:

• Mission planning interface, providing:

o Google Map based mission planning environment

o Automated flight grid development

o Waypoint functionalities

o Control over flight parameters, including:

 Flight altitude

 Flight speed

 Angle of flight transects

 Takeoff and landing points

 Waypoint delay

 Relay and servo functions

 Camera parameters

 Image overlap

• Real-time flight monitoring, providing:

o GPS status and HDop

o Current autopilot mode

o Direct line to current waypoint

o Desired turn radius

o Track of recent travel

o GPS reported altitude

o GPS reported direction of travel

o Latitude and longitude

o Heads-up-display (HUD), providing:

 Air speed (ground speed if aircraft is not equipped with the 

appropriate sensor)

 Crosstrack error and turn rate

• Intended heading with crosstrack correction

 Heading direction

 Bank angle

 Wireless telemetry connection 

 GPS time

 Altitude

 Rate of climb

 Ground speed

 Battery status

 Artificial horizon
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• Recording telemetry and dataflash logs, collecting data on:

o Attitude 

o Auto tune

o Time and position of camera shutter activation

o Commands received from the ground station or executed are part of 

mission

o Raw compass, offset and compassmot compensation values

o Battery voltage, current and board voltage information

o Throttle and altitude information

o Error messages

o Event numbers

o GPS data

 Status

 Time

 Number of satellites

 HDop

 Latitude

 Longitude

 Relative altitude (accelerometer + barometric altitude in meters)

 Altitude (m)

 Horizontal ground speed (m/s)

 Ground course in degrees

o Inertial management unit (IMU) data

 Raw gyro rotation rate (deg/s)

 Raw accelerometer values (m/s2)

o Flight Mode

o Navigation information

o Performance monitoring

o Pulse width modulation (PWM) commands from flight controller to 

ESC/motor/RC ouput

• View and analyze telemetry logs

• First-person-view

• Flight simulation

Ground Station Functions (Mission Planner) 

From the ground station, the PIC/operator can control the flowing aircraft functions 

during flight:

• Arm/disarm the aircraft motors

• Flight mode (stabilize, loiter, full autonomy)

• Loiter and resume mission

• Return-to-launch (RTL), also known as return-to-base (RTB)

• Land at current location

• Change speed

• Change altitude

Computer 

[Please Note: Additional computer may be used.]

Brand Name: HP
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Screen Size: 15.6 inches

Processor: 2.7 GHz AMD A Series

RAM: 4 GB

Hard Drive: 750 GB

Graphics Coprocessor: AMD Radeon HD 7520G

Operating System: Windows 8

Weight: 7 pounds

Dimensions: 20.4 x 13.8 x 3 inches

Wireless telemetry 

3DR air and ground radio modules provide communication between the aircraft and the 

ground station. 

Specifications:

• Interchangeable air and ground modules

• 915 MHz

• Micro-USB port

• 6-position DF13 connector

• 100 mW maximum output power (adjustable)

• -117 dBm receive sensitivity

• Based on HopeRF’s HM-TRP module

• RP-SMA connector

• 2-way full-duplex communication through adaptive TDM

• UART interface

• Transparent serial link

• MAVLink protocol framing

• Frequency Hopping Spread Spectrum (FHSS)

• Configurable duty cycle

• Error correction corrects up to 25% of bit errors

• Open-source SIK firmware

• Configurable through Mission Planner and APM Planner

• Supply voltage: 3.7-6 VDC (from USB or DF13 connector)

• Transmit current: 100 mA at 20 dBm

• Receive current: 25 mA

• Serial interface: 3.3 V UART

• 26.7 mm x 55.5 mm x 13.3 mm (without antenna)

Very High Frequency (VHF) Radio 

An aviation VHF radio, such as a Yaesu or ICOM handheld transceiver, will be 

maintained at the ground station for communication with local ATC.