Attn:

Docket Operations, M

- 30 U.S. Depa rtment of Transportation (DOT) 1200 New Je rsey Avenue, SE., Room W12

- 140 West Building Ground F loor, 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 doc uments

Submitted on February 29, 2016

Christopher E. Muhl 16706 Monte Alto Place Pacific Palisades, California, 90272 Tel: (310) 699

- 0881 Email: cmuhl999@gmail.comCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

2 

## 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 Op erator

................................ ................................ ................................ ................ 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 Limitatio ns 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 C amera Attachments

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

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

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

................................ ................................ ................................ ................................ ................................ .................... 20 Dimensions

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

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

................................ ................................ ................................ ................................ ................................ .............. 21 Propeller

................................ ................................ ................................ ................................ ................................ .............. 21CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

3 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 Prioritizatio n

................................ ................................ ......................... 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

................................ ................................ ....................... 43CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

4 

## G lossary O f A bbreviations

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

s UAS 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 SystemsCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

5 Docket Operations, M

- 30 U.S. Depa rtment of Transportation (DOT) 1200 New Je rsey Avenue, SE., Room W12

- 140 West Building Ground F loor , 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 exe mption 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) a nd (b), to operate Small Unmanned Aircraft Systems ( s UAS) 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 s UAS for aerial surveying, d ata collection, and the development of geographic informati on systems (GIS) for natural

resource and agricultural applications. This petition is similar to other approved petitions, and will permit the commercial operation of s UAS, given that such operatio ns

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 wit h 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 a ny 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 5 5 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 h erein 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 an d 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 establis hed 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 f or a determination of exemption if the characteristics of the
sUAS an d 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, weigh ing less thanCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

6 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 und eveloped and unpopulated areas. For any operation that would require exceeding the conditions of the “blanket” COA, or the condition s of this exemption, or any future FAA final rule, Christopher E. Muh l 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. S pecific A pplicable R egulations F rom 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 U nmanned Aircraft Systems (sUAS) pur suant to Section 333 of the
FAA Modernization and Reform Act of 2012 P.L. 112

- 95).CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

7 

### 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 p otential 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 cl ose 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 l ine 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 t he 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

Ch ristopher E. Muhl engages projects related to natu ral 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 r esolutions, 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 possibl e 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 p ayload), 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 e stablished 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 i s:CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

8 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 s UAS in natural resource applications for over two years. Mr. M uhl’s education, training, and research encompass GIS, remote sensing, mobile mapping, web mapping, web development, and geospatial programming. More specifically, h e has worked to develop data acquisition and processing pipelines

, integrating geospatial programming and Structure from Motion (SfM) software, to utilize s UAS acquired data in geographic information systems and within online web mapping environments

.
Mr. Muhl engages projects related to natural resources and agriculture. Those projects rela ted 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 yie ld 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 lo cal 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 su ch, 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 fix ed

- 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 failsafeCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

9 functions of sUAS and UAS, and when operated in c lose 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) weigh t, 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 exempti on, 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 proc edures 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 b e 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, application s of UA for n atural
resources and a gricultur e typically occur in un developed 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 Depart ment 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 resourc e 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 scientif ic understanding of interactionsCHRISTOPHER 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 an d 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 co mbustion 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 o f 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

ac cordance 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 Operat or, 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 O f T he 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 posses sion, or the Federal government. The PIC must also meetCHRISTOPHER 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 Depa rtment of Homeland Security, and as such, UA operations present no threat to national security.

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

current third

- class FAA airman medical certificate

, o r a valid U.S. driver's li cense.

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
certific ations 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 opera tions, 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, regist ered 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 Christop her 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 p etition are listed below under Proposed Conditions and
Limitations Of Th e 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

- avoi d responsibilities required by § 91.111, 91.113, and 91.115 by scanning the area around the aircraft for potential ly conflicting traffic and assisting the PIC with navigational awareness.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

12 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. ab ove 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 experien ces 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
fiv e 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 Suppl ement, 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 incl ude 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 aircraf t, 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 Proced ures 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

13 • 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 r estriction. 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 limitati ons stated in this grant
of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and madeCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

14 available to the Administrator upon request. If a discrepancy exists between the
condit ions 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 docum ents. 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 enf orcement 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., inopera ble 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 fo r 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
i ssued 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 ce rtificate.

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
mainta ining 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) andCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

15 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 experience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distan ce 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 ma de 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 tether ed 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

- d etermined 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 condition s) 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 pr acticable.

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 beCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

16 available to the PIC at the Ground Control Station of the UAS any time the aircraft is operatin g. 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 ha s granted permission for operating closer to those objects and the PIC has made a safety assess ment 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 c onducted 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. A ny 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 report ed to the National Transportation Safety Board (NTSB) per
instructions contained on the NTSB Web site: www.ntsb.gov.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

17 

## 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 FS

TH9X 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
g round 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

s afety, 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 flig ht 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 t he 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

18 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 bat tery 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 (3 00 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

19 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 airsp eed 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 fo lder 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 g round 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: Dipo le 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

20 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 therm al 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

pr ovided 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

sta tion, 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 enhance d 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. Sit uational 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 AeroCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

21 Dimensions

Width

- Wingspan: 74 in (188 cm) Length: 51 in (129 cm)
Int ernal 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 u p 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 minutesCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

22 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 Reco rded:

• 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 sign ed 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

23 • 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

• Trans mission 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 c loverleaf 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 syste m

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 cameraCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

24 

## Appendix B: Prefli ght, 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/impai r 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 o f 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, a nd 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 t he 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. Du ring 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 memb ers 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 pre flight briefing will be conducted by the PIC or
VO , unique UA related terminology will be defined, and two

- way radio
communication will be test ed

.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

25 

### 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 wi nd 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 autonom ous 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. Wi ngs, 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 fo r 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 themCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

26 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 th at propellers are fastened correctly

3.3. Consider the danger zone of the propeller. Insure that the propellers will not
come in to contact with fingers, hands, grass, twigs, or other objects

3.4. All team members should be at least 5 meters from the aircraft for sma ller 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 batteryCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

27 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 eve nt 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 e nsure 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 damagedCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

28 

## Appendix C: Operations & Emergency Procedures

Chain of Command

In the event o f 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. T he 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 O perator 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 term s 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 a t 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, Win d 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 O perating 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 operationsCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

29 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. Co nverging. 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, ai rplane, 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 shal l alter course to the right.
vi. Overtaking. Each aircraft that is being overtaken has the right

- of

way 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
lan ding, 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

- of

way. 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.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

30 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 throu ghout 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.

V O Duties

a. Visual observers must be used at all time s 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 a vailable. 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 t he 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, th e ground crew must act to ensure the protection of property.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

31 

### 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 loc ation, 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 t reatment 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 pa rticipants 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 avai lable 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

- Fl ight Briefing

The pre

- flight briefing will address the following:

• Individual roles and responsibilities

• Threats, hazards, and protective actions

• Worse Case ScenariosCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

32 • Communication procedures

• Emergency response procedures

• Safe

- cover locations and evacuati on 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 O perations 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
l ocated 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 even t 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 re aches 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 minimumCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

33 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 neare st 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. Ditchi ng 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 controlCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

34 5.7.4. If the link is reestablished:

5.7.4.1. Heading

– Es tablish 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, a nd 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 li po 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 l ocation 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.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

35 1.1.1.3.5. Ensure that the battery is placed in a fireproof containing during transport, and when placed in storage at t he 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 th e 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 unmana geable, 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 oper ating 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 th e 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 d istance, and ensure that the appropriate emergency responder(s) ha s 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 procedur e
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 Report s

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.

A dditionally, a ny incident, accident, or flight opera tion 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 theCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

36 National Transportation Safety Board (NTSB) pe r 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) Tota l aircraft operational hours f) Takeoff or Landing damage

Equipment malfunctions. Reportable malfunctions include, but are not limited to the following:

a) On

- board flight con trol 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
sch eduling 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 op erator must remain clear of all MTRs.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

37 

### 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

w ill 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 areaCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

38 

## 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 no t 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) wi ll 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 P ractices 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 a irport (s) or airport manager (s).

If a loss of communication occurs, the aircraft will be directed to the lost link flight plan, wh ich 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 di rected to the lost link flight plan, which is RTB
and land.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

39 

## 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 ho me 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, heli port, 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 e vent 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 activ ated.

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 air craft enters a fly

- away
1.1.5.1. Record aircraft positionCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

40 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, withi n spe aking 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.CHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

41 

## 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 s ystem 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, airp lane, 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 aircra ft conditions during flight:

• GPS status

• Connection strengthCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

42 • 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, pitc h, 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 program med via additional channelsCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

43 

## 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 sophisticate d 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 functionalitie s

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 n ot 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 horizonCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

44 • R ecording 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)

 Altitu de (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/s 2 )

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: HPCHRISTOPHER E. MUHL

– PETITION FOR EXEMPTION

45 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 wit h local ATC.