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December 31, 2014

U.S. Department of Transportation Docket Operations, M-30 1200 New Jersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001

Re: Petition of Consumers Energy Company fo r an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Moderniz ation and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Consumers Ener gy Company hereby applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the DJI S1000 with the A2 F light Control System, manufactured by DJI Innovations (the S1000”).

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

Consumers Energy Company requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;

 14 C.F.R Part 27;

 14 C.F.R § 45.23(b);

 14 C.F.R. § 45.27(a);

 14 C.F.R § 61.113;

 14 C.F.R § 91.7(a);

 14 C.F.R § 91.9(b)(2);

 14 C.F.R § 91.9(c);

 14 C.F.R § 91.103;

 14 C.F.R § 91.109(a);

 14 C.F.R § 91.119;

 14 C.F.R § 91.121;

 14 C.F.R § 91.151(a) & (b)U.S. Department of Transportation December 31, 2014 Page Two

2 sd-654307  14 C.F.R § 91.203 (a) & (b);

 14 C.F.R § 91.405(a);

 14 C.F.R § 91.407(a)(l);

 14 C.F.R § 91.409(a)(2);

 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the Consumers Energy Company Operations, Inspection, and Main tenance Manual, the DJI S1000 User Manual, the A2 Flight Control System User Manual, the Consum ers Energy Company S1000 Pilot Operating Handbook, and the Consumers Energy Compa ny S1000 Training Manua l (together, the “Manuals”). The Manuals are submitted herewith as confidential unde r 14 C.F.R. § 11.35(b), because they contain commercial and proprie tary information that Consumers Energy Company has not and will not sh are with others, is not avai lable to the public, and is protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq

.

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in a ccordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely acce lerate the integration of civil unmanned aircraft systems into the national airspace syst em.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operatio n of an unmanned aircraft system where it does not create a hazard to users of the nationa l airspace system (NAS) or the public or pose a threat to national security base d on the following considerations:

 The size, weight, speed a nd operational capability;

 Operation in proximity to air ports and populated areas; and

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency’s safety regulations and minimum standards when the Administrator decides a requested ex emption is in the public interest. See 49 U.S.C. §§ 106(f), 44701-44716, et seq . A party requesting an exempti on must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81.U.S. Department of Transportation December 31, 2014 Page Three

3 sd-654307 III. DESCRIPTION OF CONSUMERS ENERGY COMPANY AND ITS SERVICES

Consumers Energy Company is a pu blic utility that provides natural gas and electricity to more than 6 million Michigan residents. It is headquartered in Jackson, Michigan, and serves customers in 68 counties in Michigan’s Lower Peninsula.

At present, Consumers Energy Company ha s seven power plants. Consumers Energy Company’s largest power plant is the Karn-Wead ock coal-fired generating station located on Saginaw Bay near Bay City. Other Consumers En ergy Company coal-fired plants are the JH Campbell power plant between Holland and Grand Haven; the Cobb power plant in Muskegon and the Whiting Power Plant on Lake Erie in Luna Pier, just north of the Michigan/Ohio state line. Consumers Energy Company also operates and co-owns (with Detroit Edison) the Ludington Pumped Storage Power Plant near Ludington.

Two generating facilities pr eviously owned by Consumers Energy Company (but still serving Consumers Energy Company’s system) ar e the Palisades Nuclear Generating Station, 5 miles south of South Haven and The Mi dland Cogeneration Venture in Midland.

On the Muskegon River, in Newaygo and M ecosta counties, Consumers Energy Company operates 3 Hydroelectric Powerplant complexes. Together, the thre e dams (Rogers, Hardy and Croton) can generate about 45,500 kilowatts.

Consumers Energy Company has secured near ly 60,000 acres to develop wind generation farms in Mason and Tuscola counties. Consum er Energy’s first wind farm began operations in 2013, and today the wind farms generate between 100 and 111 Megawatts of energy each. Development of wind power generation protects the Michigan environm ent and will bolster Michigan’s economy. By combining renewable energy with efficiency measures and new, environmentally advanced large-scale electr ic generation, Consumers Energy Company is meeting the needs of its customers, th e state economy, and the environment.

The contact information for the petitioner, Consumers Energy Company, is as follows:

Jason Milstone Litigation Attorney Consumers Energy Company One Energy Plaza Jackson, MI 49201 Tel. (517) 788-1188 Jason.Milstone@cmsenergy.com C/O William V. O’Conno r William D. Janicki Joanna L. Simon Morrison & Foerster LLP 12531 High Bluff Drive San Diego, CA 92130 Tel (858) 720-5100 WOConnor@mofo.com WJanicki@mofo.com JoannaSimon @ mofo.comU.S. Department of Transportation December 31, 2014 Page Four

4 sd-654307 IV. DESCRIPTION OF PROPOSED OPERATIONS

Consumers Energy Company is requesting exem ptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to perform research and development using the DJI S1000 UAS. Ke y areas of focus for Consumers Energy Company’s research and development are (i) pub lic and worker safety; (ii) safe and timely power restoration following storms; and (iii) ne w methods to effectively inspect power lines, electrical facilities, ve getation and rights of way.

Consumers Energy Company is committed to improving power reliability for customers by more safely and quickly restor ing power to customers after storm related damage to the electrical system. The Michigan Public Se rvice Commission has emphasized to Consumers Energy Company the importance of reducing out age response time, a critical component of which is more accurate and timely storm damage assessment presently conducted by employees in motor vehicles or on foot. Use of the S1000 will help to reduce power restoration time and safety-related incident s involving employees working in adverse weather conditions.

Additionally, current inspections of high volta ge (HVD) power lines are done one to two times a year by helicopter. Use of the S1000 w ill allow such inspections at considerable savings, as well as reduce safety risks because the drone will not ca rry a flammable fuel source. The S1000 will also allow better visual inspection of facilities installed on poles, as helicopter inspection of a utility pole usually involves less than 5 seconds of visual inspection.

Further, inspections of lower voltage power (L VD) lines are typically done by motor vehicle or on foot. Due to visibility limitations base d on the design of utility poles, a certain portion of the pole and its facilities is never inspect ed. Using the S1000 to do LVD inspections will increase their effectiveness, d ecrease their safety risks, and reduce the time needed for the inspection cycle.

Thus, the research and development use pr oposed here will allow Consumers Energy Company to determine the efficacy of the S1000 for increasing public safety, restoring outages in a safe and timely manner, and cr eating new methods for inspecting electrical facilities.

The research and development use will take place on six Michigan research and development test sites (the R&D Sites) located in Jackson County, Tuscola County, and Mason County. The sites are owned by Consumers Energy Co mpany and have low nearby residential populations. Two sites will focus on UAS re search and development for power line monitoring; four sites will focus on UAS research and de velopment for wind turbineU.S. Department of Transportation December 31, 2014 Page Five

5 sd-654307 inspection. The satelli te imagery of each site include d below confirms that surrounding properties have few stru ctures built on them. See Figures 1-7.

Research and Development Sites Chart

Site No. Name Location Type of R&D

1 Cary Rd Sub Columbia Township Jackson County Michigan Power line monitoring

2 Lake Leann Somerset Township Hillsdale County Michigan Power line monitoring

3 Clear Lake Grass Lake Township Jackson County Michigan Power line monitoring

4 Crosswinds WTG-46 Columbia Township Tuscola County Michigan Wind turbine inspection

5 Crosswinds WTG-28 Akron Township Tuscola County Michigan Wind turbine inspection

6 Lake Winds WTG-8 Riverton Township Mason County Michigan Wind turbine inspection

7 Lake Winds WTG-22 Riverton Township Mason County Michigan Wind turbine inspectionU.S. Department of Transportation December 31, 2014 Page Six

6 sd-654307 Figure 1 – R&D Site Number 1: Cary Rd Sub

Figure 2 – R&D Site Number 2: Lake Leann SubU.S. Department of Transportation December 31, 2014 Page Seven

7 sd-654307 Figure 3 – R&D Site Number 3: Clear Lake Sub

Figure 4– R&D Site Number 3: Cross Winds WTG-46U.S. Department of Transportation December 31, 2014 Page Eight

8 sd-654307 Figure 5 – R&D Site Number 5: Cross Winds WTG-28

Figure 6 – R&D Site Number 6: Lake Winds WTG-8U.S. Department of Transportation December 31, 2014 Page Nine

9 sd-654307 Figure 7 – R&D Site Number 7: Lake Winds WTG-22

A. The DJI S1000

Consumers Energy Company will operate the DJI S1000 with the A2 Flight Control System, manufactured by DJI Innovations (the “S1000”). The S1000 is a battery operated octocopter with a maximum flight time of 25 minutes. The vehicle we ighs approximately 8.8 pounds with a maximum takeoff weight of approximate ly 24 pounds. It has retractable landing gear, vibration dampers, small frame air incline and minimalized gimbal mount, which allows for a 360 degree view from the camera. Although the vehicle’s ground speed has a maximum of 45 mph, it will be operated between 5 and 15 mile s per hour, and it will operate at or below 500 feet AGL.

The S1000 manufacturer’s specifications are shown below in Figure 8. The S1000 is shown below in in Figure 9.U.S. Department of Transportation December 31, 2014 Page Ten

10 sd-654307 Figure 8 – DJI S1000 SpecificationsU.S. Department of Transportation December 31, 2014 Page Eleven

11 sd-654307 Figure 9 – DJI S1000

B. The DJI A2 Flight Control System

The DJI S1000 will be used in conjunction with the A2 multi-rotor stabili zation flight control system that provides self-leveli ng and altitude holding. The A2 is a complete flight control system for various multi-rotor platforms, including the S1000. The A2 provides precise positioning and flight control through its hi gh performance antenna and low noise antiinterference front-end RF design. Notable features of the A2 Flight Control System include:

 Auto Return-To Home/One Key Go-Home: If the S1000 disconnects from the A2 during flight, the system’s fa ilsafe protection will enable the S1000 to return to home and land automatically. The operator can al so setup a One Key Go Home function to activate this feature manually.

 Multi-Rotor One-Motor Fail Protection: When the S1000 is in attitude or GPS attitude mode, and one of the motors stops, the aircraft will retain good attitude and rotate around the frame arm with the stoppe d motor. In this condition, the S1000 is still under control a nd returns home safely, highly re ducing the risk of a crash.

 Set Speed Feature: Ability to lock the S1000 craft into its current horizontal speed.

 Point of Interest: Users can record the current po sition of the S1000 as a point of interest by a preset switch on the remote control. The S1000 can achieve a circling flight around the point of interest with th e nose pointing at the POI in an area of 5 meters to 500 meters radius, when the roll command is given. This function is easy to set and simple to operate, it is suitable fo r all-round shooting of a fixed scenic spot.U.S. Department of Transportation December 31, 2014 Page Twelve

12 sd-654307 The A2’s specifications are shown in Figure 10.

Figure 10 – A2’s SpecificationsU.S. Department of Transportation December 31, 2014 Page Thirteen

13 sd-654307 C. Consumer Energy Company’s Proposed Operations Demonstrate an Equivalent Level of Safety

1. General Description of Proposed Flight Operations

Consumers Energy Company proposes to opera te only on the R&D Sites and within the limitations and performance specifications listed in the Manuals, which are summarized below. These limitations provide for at least an equivalent, or higher, level of safety for operations under the current regulatory struct ure because the proposed operations represent a safety enhancement to the protocols currently used by Consumers Energy Company for power line and wind turbine mon itoring. Moreover, the R&D Sites were specifically chosen as appropriate test grounds to determine the efficacy of using the S1000 on a wider scale.

The proposed operations do not create any hazard to users of the national airspace system or pose a threat to national security. The aircra ft is a battery operated octocopter with a maximum flight time of 25 minutes. The ve hicle weighs approximately 8.8 pounds with a maximum takeoff weight of approximately 24 pounds. It has retractable landing gear, vibration dampers, and small frame air inclin e. The vehicle’s ground speed has a maximum of 45 mph but it will be operated between 5 and 15 miles per hour, and it will operate at or below 500 feet AGL. The requirement for clea rance up to 500 feet AGL is necessitated by the size of the wind turbines on the R&D Sites, which can vary greatly in size and may reach as high as 150 meters, or 492.126 feet AGL, wh en the blades are positioned vertically. Figure 11, below, shows the varying sizes of exemplar wind turbines.

Figure 11: Wind Turbine SizeU.S. Department of Transportation December 31, 2014 Page Fourteen

14 sd-654307 Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The S1000 carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the unm anned aircraft being operated by the petitioner reduces the risk to pa rticipating persons in close proximity to the aircraft due to the limited size, weight, operati ng conditions, and design safety features of the S1000.

Consumers Energy Company’s operations will be in remote areas at least 5 miles from any airport and away from population centers, as de monstrated by Figures 1-6 (the R&D Sites). The S1000 will be operated only on the R&D Sites, which are owned by Consumers Energy Company. Additionally, the wind turbine towers on R&D Sites 3-6 are already subject to obstruction marking, lighting and notification requirement s set forth by the FAA.

The FAA has determined that the risk of not having an electronic means to monitor and communicate with other aircraft, such as tran sponders or sense and avoid technology, is mitigated by placing limits on altitude, requi ring stand-off distance from clouds, permitting daytime operations only, and requiring that the ai rcraft be operated within visual line of sight and yield right of way to all other manned opera tions. Additionally, the operator will request a NOTAM prior to operations to alert other users of the NAS. See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 13, atta ched hereto as Attachment 6.

The petitioner’s aircraft has the capability to operate safely after experiencing certain inflight failures, as spec ified above in the description of the A2 Flight Control System. The aircraft is also able to res pond to a lost-link event with a pre-coordinated, predictable, automated flight maneuver.

2. Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted e nvironment within which they will operate, the procedures listed below, and pilot certifica tion requirements, Consumer Energy’s proposed operations using the S1000 would “not create a hazard to users of the national airspace system or the public or pose a threat to nati onal security.” Reform Act Section 333(b)(1).

1. The aircraft is a pproximately 8.8 pounds.

2. The aircraft will be identified by serial number, registered with the FAA, and have identification (N-N umber) markings as large as practicable.

3. Flights will be operated within visual line of sight of the pilot in command (PIC).U.S. Department of Transportation December 31, 2014 Page Fifteen

15 sd-654307 4. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by PIC.

5. Maximum flight time for each operational flight will be 20 minutes.

6. The aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) five minutes of flight time remaining.

7. The aircraft will be operated during daylight and in VFR conditions.

8. Flights will not exceed 500 feet AGL, so as to accommodate inspections of wind turbines.

9. Flights will be operated at a lateral di stance of at least 50 feet from any persons or property not associated wi th the operation who have not given prior permission.

10. Flights will be limited to a groundspeed of 45 mph.

11. Minimum crew for each flight will consist of a PIC and an Observer.

12. The PIC will possess at least a private p ilot certificate, a third class medical certificate, and a designee from Consumers Energy Company will have completed a Factory Certified Basi c Operator Course for the S1000.

13. Prior to the flight, a Missi on Plan will be created setting forth the limitations for the flight as well as contact information for the PIC.

14. The flight operations will yield the ri ght of way to other manned aircraft operations.

15. All persons who are not involved with Consumer Energy’s operations will be required to be at least 500 f eet from flight operations.

16. The aircraft will only operate within the R&D Sites.

17. Consumers Energy Company will provide NOTAM details to the FAA 24 hours prior to each flight.

18. All required permissions and permits will be obtained from territory, state, county or city jurisdic tions prior to flight.U.S. Department of Transportation December 31, 2014 Page Sixteen

16 sd-654307 19. Prior to commencing operations, Co nsumers Energy Company will obtain a Certificate of Waiver or Authorization (COA) from the FAA.

20. If the aircraft loses communications, it wi ll have the capability to return to a pre-determined location within the operational area and land.

21. If the aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location w ithin the operati onal area and land.

22. The flight will be aborted in case of unpredicted obstacles or emergencies.

23. Each flight will be recorded in an Operations Log Book.

24. Maintenance on the aircraft will be recorded in a Maintenance Log Book.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost co mmunications, and lost GPS procedures are documented above, and are more fully documented in the attached A2 Flight Control System information and Consumers Energy Company Pilot Operating Handbook. ( See Attachments 3 and 4).

4. Proposed Flight Areas

Consumers Energy Company is requesti ng to operate in the R&D Sites.

V. SPECIFIC FAR EXEMPTIONS REQUESTED

Consumers Energy Company seeks an exemption from several interrel ated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations using the S1000. Listed below are (1) the specific FAR s ections for which exemption is sought, and (2) the operating procedures and safeguards that Consumers Energy Company has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same app lication. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astr aeus Aerial, Docket No. FAA 2014-U.S. Department of Transportation December 31, 2014 Page Seventeen

17 sd-654307 0352 at 13-14, 22. If, however, the FAA determines that there are some characteristics of the S1000 that fail to meet the requirements of th e Reform Act, an exemption is requested.

Equivalent Level of Safety : The S1000 is safe when taki ng into account its size, weight, speed, and operational capability. The S1000 weighs approximately 8.8 pounds and will be flown at speeds less than 45 miles per hour, in vi sual line of sight of the operator, and in remote and unpopulated airspace, specifically, on the R&D Sites. The S1000 does not carry pilots, passengers, explosive materials, or flammable liquid fuels. The S1000 will be operated within the parameters of the Manuals.

Consumers Energy Company will also provide the FAA with advance notice of all operations via NOTAM and coordination with the local FSDO. The proposed operations will be at least as safe as, or safer than, conventi onal rotorcraft operating with an airworthiness certificate without the restrict ions and conditions proposed he re. The proposed operations will also be as safe, or safer than, traditional power line monitoring and/or wind turbine inspection methods.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural re quirements for airworthin ess certification of normal category rotorcraft. To the extent th e S1000 would otherwise require certification under Part 27, Consumers Energy Company seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requirements

14 C.F.R. §45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light-spor t category aircraft or experimental or provisionally certificated aircra ft, the operator must also di splay on that aircraft near each entrance to the cabin, cockpit, or pilo t station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport, “experimental,” or “provi sional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.U.S. Department of Transportation December 31, 2014 Page Eighteen

18 sd-654307 14 C.F.R. § 91.9(c) states:

No person may operate a U.S.-registered civil ai rcraft unless that aircraft is identified in accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that th e aircraft “have iden tification (N-Number) markings in accordance with 14 CFR part 45, S ubpart C if the markings are “as large as practicable.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14.

Equivalent Level of Safety : Consumers Energy Company will mark all S1000s with their NNumber in a prominent spot on the fuselage with markings that are as large as practicable.

D. 14 C.F.R. § 61.113: Private Pi lot Privileges and Limitations

Consumers Energy Company seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certificate. The purpose of Part 61 is to ensure that th e skill and competency of any PIC matches the airspace in which the PI C will be operating, as well as requiring certifications if the pilot is carry ing passengers or cargo for hire.

While the S1000 will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of Exem ption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique characteristic s of UAS operation outside of controlled airspace did not warrant the addi tional cost and restrictions a ttendant with requiring the PIC to have a commercial pilot certificate and a cl ass II medical certificate. The FAA has also determined that the required knowledge for a co mmercial pilot covers the same fundamental principles as a private pilot.

The PIC will possess at least a private pilot certif icate, a third class medical certificate, and will have completed a DJI Factory-Certified Basi c Operator Course for the S1000. This is a 3-day program that includes ground school and flight training. See the Consumers Energy Company S1000 Training Manual for more info rmation on this Course. (Attachment 5.)

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety factor for the limited operatio ns proposed by the petitioner to be the airmanship skills acquired through UAS-specific f light cycles, flight time, and specific make and model experience, culminating in veri fication through testing.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by requiring th e knowledge and experien ce in S1000 operations described above.U.S. Department of Transportation December 31, 2014 Page Nineteen

19 sd-654307 Furthermore, the security screening conducted by the Transportation Security Administration of certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a threat to national security.

The restrictions Consumers Energy Company has placed on its S1000 operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014- 0352. Consumers Energy Company will operate in restricted areas (the R&D Sites) away from persons and property not involved in the operation. The aircraft will be flown based on VLOS at or below 500 feet AGL, so as to accommodate inspections of wind turbines on R&D Sites 3-6. A NOTAM will be issued at least 24 hours before the flight is to occur, and the flight will be coordinate d with the applicable FSDO.

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Consumers Energy Company seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operate d. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Accordingly, Consumers Energy Company requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S. -registered civil aircraft -

... (2) For which an Airplane or Rotorc raft Flight Manual is required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and curren t airworthiness certificate...U.S. Department of Transportation December 31, 2014 Page Twenty

20 sd-654307 (b) No person may operate a civil aircra ft unless the airwor thiness certificate required by paragraph (a) of this secti on or a special flight authorization issued under § 91.715 is displayed at the cab in or cockpit entr ance so that it is legible to passengers or crew.

Consumers Energy Company does not request an exemption from this section but instead notifies the FAA that, in acco rdance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registra tion certificate and ot her documentation will be kept at the control station with the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19-20, and Grant of Exemption No. 8607.

G. 14 C.F.R. § 91.103: Preflight Action

Consumers Energy Company seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, la nding and takeoff distances an d aircraft performance data before initiation of flight. U nder these circumstances, the FAA has stated that no exemption is required. See Grant of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following the Manuals. The PIC will take all required preflight actions - including performing all required checklists and reviewing weathe r, flight requirements, batte ry charge, landing and takeoff distance, aircraft performance data, and con tingency landing areas - before initiation of flight. The Manuals will be kept at the ground station with the operator at all times.

H. 14 C.F.R. § 91.109(a): Flight Instruction

Consumers Energy Company seeks an exem ption from 14 C.F.R. § 91.109(a), which provides that “[n]o person may ope rate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.” UASs and remotely piloted aircraft, by their design, do not have f unctional dual controls. Instead, flight control is accomplished th rough the use of the A2 Flight Control System/Ground Control Station (GCS) that co mmunicates with the aircraft via radio communications.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on the aircraft and the GCS will be a safe distance from the aircraft and the public, causing noU.S. Department of Transportation December 31, 2014 Page Twenty-One

21 sd-654307 safety hazard. Given the size and speed of the S1000, an equivalent leve l of safe training can still be performed without dual controls becau se no pilot or passengers are aboard the aircraft, and all persons will be a safe distance aw ay in the event that the aircraft experiences any difficulties during flight instruction. In addition, Consumers Energy Company will conduct flight training at a re mote facility away from popul ation centers. These training flights will be conducted on the R&D Sites and w ill otherwise comply with the provisions in the Manuals. Accordingly, Consumer Ener gy’s proposed method of operation provides superior levels of safety.

I. 14 C.F.R. § 91.119(c): Minimum Sa fe Altitudes in Uncongested Areas

Consumers Energy Company requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). Section 91.119( c) prescribes that an aircraft may not be operated closer than 500 f eet to any person, vessel, vehicl e, or structure. The Manuals provide for operations away from congested popul ations areas on the R&D Sites, but in close proximity to wind turbines and towers on R& D Sites 306. The FAA has already determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as thos e imposed by Consumers Energy Company. See Grant of Exemption No. 11062, p. 20-21.

Equivalent Level of Safety: Compared to flight operations w ith rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the S1000, as well as the locations where it is operated – the R&D Site s. In order to avoid any risk to aircraft, flight operations will be restricted to 500 feet AGL or below. Other aircraft are already prohibited from operat ing closer than 500 from the wind turbine structures where Consumers Energy Company proses to operate. This is airspace where other aircraft do not normally operate. As set forth in the Manuals and herein, the S1000 will be operated in the remote R&D Sites, away from persons or structures not involved in the operation. All persons who are not involved w ith Consumers Energy Company’s operations will be required to be at least 500 feet from flight operations. This will pose no risk to the public because other ai rcraft are not operating in these areas.

J. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C. F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight le vel by reference to an altimeter that is set to the elevation of the depart ure airport. The S1000 uses bot h barometric pressure sensors and GPS to determine altitude but does not have the ability to set in a current altimeterU.S. Department of Transportation December 31, 2014 Page Twenty-Two

22 sd-654307 setting. An exemption is required to the exte nt that the S1000 does not have a barometric altimeter setting. The altitude of the aircraft is monitored by the PIC on the ground control station and by the visual observer.

Equivalent Level of Safety: The FAA has stated that an equi valent level of safety can be achieved if the aircraft will be operated at orbelow 400 feet AGL and within visual line-ofsight in addition to GPS based altitude info rmation relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20-21. As the attached Manuals indicate, the S1000 will be operated at or below 500 feet AGL and othe rwise complies with the limitations in the Grant of Exemption No. 11062.

K. 14 C.F.R. § 91.151(a): Fuel Requi rements for Flight in VFR Conditions

Consumers Energy Company requests an exem ption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VF R conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather c onditions) there is enough fuel to fly to the first point of intended landi ng and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after th at for at least 45 minutes.

Here, the technological limitations on S1000 batte ry power means that no meaningful flight operations can be conducted while still maintain ing a 30 minute reserve. The aircraft is battery powered with a maximum flight ti me of 30 minutes. Consumers Energy Company proposes that the maximum flight time for each operational flight will be 25 minutes. The aircraft will be safely landed with no less th an the greater of (a) 20% battery life remaining or (b) five minutes of flight time remaining.

Equivalent Level of Safety: The FAA has stated that an equiva lent level of safety is provided if the UAS flight is conducted under day time VFR flight conditions using VLOS, and terminated with at least 25% rese rve battery power still available. See Grant of Exemption No. 11062, p. 21-22. The Manuals provi ding an equivalent level of safety by safely landing with no less than the greater of (a) 20% battery life remaining or (b) fi ve minutes of flight time remaining and otherwise complying w ith the flight rest rictions above.U.S. Department of Transportation December 31, 2014 Page Twenty-Three

23 sd-654307 L. 14 C.F.R. §§ 91.405(a) , 91.407(a)(l), 91.409( a)(2); 91.417(a) and (b): Maintenance Inspections

Consumers Energy Company seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409( a)(2); 91.417(a) and (b). These regulations specify ma intenance and inspection standard s in reference to 14 C.F.R. Part 43. See

, e.g ., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspec ted as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness cer tificate, which the S1000 will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance and inspections will be perfor med in accordance with the Manuals. This includes maintenance, overhaul , replacement, and inspection requirements for the aircraft and procedures to document and maintain main tenance records for the aircraft. This also includes preflight in spection procedures. See Exemption No. 11062, Docket No. FAA 2014- 0352, at p. 14-15.

As provided in the Manuals, flights will not be conducted unless a flight operations checklist is performed that includes all of the airc raft’s components. The Manuals also set requirements for maintenance log books and record keeping as we ll as routine a nd post-flight maintenance. The Manuals set requirements fo r both annual maintenance and preventative maintenance.

VI. PUBLIC INTEREST

Granting Consumer Energy’s petition for exemp tion furthers the public interest. National policy set by Congress favors ear ly integration of UAS into the NAS in controlled, safe working environments such as the R&D Sites proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking require d under Section 332 of the Reform Act.

Moreover, use of unmanned aircraft operations will improve power reli ability for Consumer Energy’s customers by reducing the time necessa ry to restore power after storm-related damage to the electrical system. The use of the S1000 will also decrease safety-related incidents involving employees worki ng in adverse weather conditions.

Additionally, current inspections of high volta ge (HVD) power lines are done one to two times a year by helicopter. Use of the S1000 w ill allow such inspections at considerable savings, as well as reduce safety risks because the drone will not ca rry a flammable fuel source. Drones will also allow better visual inspection of facilities installed on poles, asU.S. Department of Transportation December 31, 2014 Page Twenty-Four

24 sd-654307 helicopter inspection usually invol ves less than 5 seconds of vi sual inspection of a utility pole.

Further, inspections of lower voltage power (L VD) lines are typically done by motor vehicle or on foot. Due to visibility limitations base d on the design of utility poles, a certain portion of the pole and its facilities is never inspect ed. Using the S1000 to do LVD inspections will increase their effectiveness, d ecrease their safety risks, and reduce the time needed for the inspection cycle.

Thus, the research and development use pr oposed here will allow Consumers Energy Company to determine the efficacy of the S1000 for increasing public safety, restoring outages in a safe and timely manner, and cr eating new methods enabling Consumer Energy’s customers to save energy every day.

In addition, unmanned aircraft ope rations will replace the use of rope access or helicopters and small aircraft to monitor wind turbines. Traditionally, monitoring and inspection of the turbines involves an individual using either a manned aircraft or rope access to climb the large tower in order to visually inspect the turbine’s blades for e dge erosion, moisture intrusion, freeze/thaw cycling and lightning strikes, among other damage. Knowing the condition of the turbine’s blades is essential to maximizing blade life. Thus, the inspections are intended to ensure that wind generation as a whole is both safe and reliable.

Yet performing this vital activity presents si gnificant risk to the individual climbing the turbine or operating the manned ai rcraft in the vicinity of th e turbines. For example, a 2011 newspaper article regarding wind- and solar-powered installations noted accidents involving wind turbines have tripled in the last decade. At least 78 wind-turbine related fatalities have occurred since the 1970s, with more e xpected as wind installations spread. 1 Use of an unmanned aircraft, like Consumers Energy Co mpany’s proposed use of the S1000 would significantly reduce the risk associated with turbine inspection.

The S1000 is approximately 8.8 pounds, carries no passengers or crew, has no flammable fuel, as opposed to larger and more powerful he licopters and small airp lanes. The public has an interest in reducing the hazards and emissions associated with altern ate use of helicopters and small airplanes to conduct si milar inspection operations.

Additionally, Consumer Energy’s intended uses fo r the S1000 have real-world benefits for the renewable energy industry and the public at large. Through the R&D Sites, Consumers

1 “More Accidents Feared as Wind, Solar-Powered Installations Spread,” 8/14/2011 Los Angeles Times article located online at http://www.toledoblade.co m/Energy/2011/08/14/More-accident s-feared-as-wind -solar-powerinstallations-spread.html

.U.S. Department of Transportation December 31, 2014 Page Twenty-Five

25 sd-654307 Energy Company may ultimately determine that it will be able to inspect and survey wind turbine blades and towers supporting the re newable energy industry. The use of the S1000 will also reduce the risks to human life associated with the traditional use of rope access for these operations. This program may prevent accidents and inju ries, and there is a strong public interest in making these operations more safe and effective through the use of UASs.

VII. PRIVACY

All flights will occur over the R&D Sites, owned by Consumers Energy Company. All flights will be conducted in accordance with any federal, state or local laws regarding privacy.

VIII. SUMMARY FOR FEDERAL REGISTER

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determ ined that publication is needed:

Consumers Energy Company seeks an exemption from the following rules for the commercial operation of a small unmanned aerial system to inspect wind turbine blades and towers for the renewable energy industry: 14 C. F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109( a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l ); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the operator, the general public and property owners from the substantial hazards associated with performing equivalent work using traditional rope ac cess or using conventional aircraft and rotorcraft.

IX. ATTACHMENTS

Attachment 1: Consumers Energy Company Operations, Inspection, and Maintenance Manual

Attachment 2: DJI S1000 User Manual

Attachment 3: A2 Flight Control System User Manual

Attachment 4: Consumers Energy Company S1000 Pilot Operating HandbookU.S. Department of Transportation December 31, 2014 Page Twenty-Six

26 sd-654307 Attachment 5: Consumers Energy Company S1000 Training Manual

Attachment 6: Exemption No. 11062, Docket No. FAA 2014-0352

Attachments 2 and 3 are confidential documents submitted under 14 C.F.R. § 11.35(b) and are exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements established by the FAA pursuant to Section 333 of the Reform Act). If you have any questions or require any additional information, please do not hesitate to contact the undersigned attorneys for Consumers Energy Company.

X. CONCLUSION

Satisfaction of the criteria pr ovided in Section 333 of the Reform Act - size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security c onsiderations - provides more th an adequate justification for the grant of the requested exemptions to pe rmit Consumers Energy Company to operate the S1000 on the R&D Sites.

Granting the requested exemption will benefit th e public interest as a whole in many ways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger; (2) improving the quality of services Consumers Energy Company can provide to its customers; and (3) decreasing operating co sts compared with traditional power line monitoring and wind turbine inspection.

Respectfully submitted, Morrison & Foerster LLP Counsel for Consumers Energy Company

By William V. O’Connor William D. Janicki Joanna L. Simon Morrison & Foerster LLP 12531 High Bluff Drive, Suite 100 San Diego, CA 92130-2040 Telephone: (858) 720-5100 Facsimile: (858) 720-5125 woconnor@mofo.com wjanicki@mofo.com joannasimon@mofo.com

# Attachment 1Revision 1 December 16, 2014 

# DJI S1000

Operations, Inspection, and Maintenance ManualRevision 1 December 16, 2014 I. FLIGHT OPERATIONS

A. Company Organization and Authority

1. Consumers	Energy	(CE)	will	conduct	flight	operations	using	an unamanned	aircraft	system	(UAS) as	described	in	this	Operations

, Inspection,	and	Maintenance	Manual	to	conduct	inspections	of	it s electrical	generating	infrastructure.

2. CE	will	designate	a	Direct or	of	Flight	Operations.

3. The	Director	of	Flight	Operations	will	ensure	this	Operations, Inspection,	and	Maintenance	Manu al	is	revised	to	contain	all	cu rrent information.

4. The	Director	of	Flight	Operations	will	ensure	that	this	Operati ons, Inspection,	and	Maintenance	Manu al	is	distributed	to	all	person nel involved	with	UAS	operations	as	well	as	any	revisions	to	this	m anual.

5. The	Director	of	Flight	Operations	will	ensure	all	pilots	are	tr ained according	to	Consumers	Energy S1000	Training	Manual	and Consumers	Energy	S1000	Pilot	Operating	Handbook.

B. The Unmanned Aircraft System to be Used

1. Aircraft	operations	will	be	con ducted	using	a	DJI	S1000	with	th e	A2 Flight	Control	System,	manufactu red	by	DJI	Innovations	(the	“S1 000”).

2. The	aircraft	will	be	identified by	serial	number,	registered	wi th	the FAA,	and	have	identification	(N‐Number)	markings	as	large	as practicable.

3. The	aircraft	weighs	approximate ly	8.8	pounds	with	a	maximum takeoff	weight	of	approximatel y	24	pounds	with	a	payload.

4. A	complete	description	of	the	S1000	is	contained	in	the	DJI	S10 00 User	Manual	and	the	A2	Flight Control	System	User	Manual.

5. Operation	of	the	S1000	is	descr ibed	in	Consumers	Energy	S1000	P ilot Operating	Handbook.Revision 1 December 16, 2014 C. Aircraft Registration, Log Book and CE Manuals

1. Each	aircraft	will	have	an	Aircra ft	Log	Book	to	record	inspecti ons, maintenance,	and	flight	operations.

2. All	required	paperwork	including	Registration,	Log	Book,	and	CE Manuals	will	be	located	at	the	Gr ound	Control	Station	in	close proximity	to	the	pilot	in	command.

D. Required Crew Members and Qualifications

1. Unmanned	aircraft	operations	will	require	a	minimum	crew	of	a	p ilot in	command	(PIC)	and	a	visual	observer.

2. The	PIC	will	possess	at	least	a	p rivate	pilot	certificate,	a	th ird	class medical	certificate,	and	will	be trained	according	to	Consumers Energy	Training	Manual.

E. Training Requirements

1. Training	requirements	are	descri bed	more	fully	Consumers	Energy Training	Manual.

F. Flight Areas

1. The	aircraft	will	only	operate	within	the	operating	areas	defin ed	as the	R&D	Sites	in	Consumers	Energy’s	Petition	for	Exemption	to	t he FAA.

2. Flight	operations	will	not	be	con ducted	within	5	miles	of	an	ai rport.

3. Flight	operations	will	not	be	con ducted	over	congested	populate d

areas.

G. Weather Conditions

1. The	aircraft	will	be	operated	du ring	daylight	and	in	VFR	condit ions.

2. The	aircraft	will	not	be	operate d	if	wind	gusts	are	greater	tha n	30 mph.Revision 1 December 16, 2014 H. Flight Operation Parameters

1. Flights	will	be	operated	within	v isual	line	of	sight	of	the	pil ot	in command	(PIC)	or	visual	observer.

2. Prior	to	each	flight,	a	zero	altitude	initiation	point	will	be established and	confirmed	for	accuracy	by	PIC.

3. Maximum	flight	time	for	each	operational	flight	will	be	30	minu tes.

4. The	aircraft	will	be	safely	land ed	with	no	less	than	the	greate r	of	(a) 20%	battery	life	remaining	or	(b)	five	minutes	of	flight	time remaining.

5. Flights	will	be	operated	at	or	below	500	feet	AGL.

6. Flights	will	be	operated	at	a	lateral	distance	of	at	least	500 feet	from any	persons	or	property	not	asso ciated	with	the	operation	who	h ave not	given	prior	permission.

7. Flights	will	be	limited	to	a	groundspeed	of	25	mph	and	vertical ascent will	be	limited	to	20	mph.

8. Prior	to	the	flight,	a	Mission	P lan	will	be	created	setting	for th	the limitations	for	the	flight	as	we ll	as	contact	inf ormation	for	t he	PIC.

9. The	flight	operations	will	yield	the	right	of	way	to	other	mann ed aircraft	operations.

10. All	persons	who	are	not	involved	with	CE’s	UAS	operations	will be required	to	be	at	least	500	feet	from	flight	operations.

11. CE	will	provide	NOTAM	details	to the	FAA	24	hours	prior	to	each flight.

12. All	required	permissions	and	perm its	will	be	obtained	from	terr itory, state,	county	or	city	jurisdictions	prior	to	flight.

13. Prior	to	commencing	operations,	CE	will	obtain	a	Certificate	of Waiver or	Authorization	(COA)	from	the	FAA.

14. Written	or	oral	permission	from	the	relevant	property	owners	wi ll	be obtained	prior	to	flight.

15. The	flight	will	be	aborted	in	ca se	of	unpredicted	obstacles	or emergencies.

16. Each	flight	will	be	recorded in	the	Aircraft	Log	Book.Revision 1 December 16, 2014 I. Lost Communications Procedures

1. Flight	recovery	following	lost	communications	will	be	performed according	to	the	DJI	S1000	User	Manual,	A2	Flight	Control	Syste m User	Manual,	and	the	Consumer	En ergy	Pilot	Operating	Handbook.

J. Lost GPS Procedures

1. Flight	recovery	following	lost	GP S	signal	will	be	performed	acc ording to	the	DJI	S1000	User	Manual,	A2	Flight	Control	System	User	Man ual, and	the	Consumer	Energy	P ilot	Operating	Handbook.

II. INSPECTION AND FUNCTIONAL TEST FLIGHT

A. Preflight Inspection Procedures

1. Before	each	flight,	either	the	P IC	or	the	visual	observer	will conduct	a preflight	inspection	of	the	aircraft.

2. The	aircraft	and	Ground	Control Station	will	be	inspected	for	s igns	of damage.		Screws	will	be	checked and	tightened	if	necessary.

3. The	Ground	Control	Station	will	be	inspected	ensure	there	are	n o broken	or	loose	antenna	connections,	cracked	casing,	or	broken or loose	joysticks.

4. Aircraft	propellers	will	be	inspe cted	to	ensure	they	are	not	da maged, loosed,	or	misaligned.

5. Motors	will	be	inspected	to	ensu re	the	motors	are	not	loose	and the supports	are	not	cracked.

6. Aircraft	batteries	will	be	check ed	that	they	are	fully	charged.

7. Ground	Control	Station	batteries will	be	checked	that	they	full y charged.

8. All	batteries	will	be	charged	and maintained	according	to	the	S 1000 User	Manual.

9. A	preflight	maintenance	inspection	will	be	recorded	in	the	airc raft	log book.Revision 1 December 16, 2014 B. Functional Test Flight

1. After	a	flight	critical	componen t,	such	as	a	propeller	or	motor ,	has undergone	maintenance	or	been	repaired	or	replaced,	the	aircraf t must	undergo	a	functional	test	flight.

2. The	PIC	will	conduct	the	test	flight	in	accordance	with	the	DJI S1000 User	Manual.

3. The	PIC	will	make	an	entry	in	th e	aircraft	log	book	of	the	func tional test	flight.

C. Postflight Inspection Procedures

1. After	each	flight,	either	the	PI C	or	the	visual	observer	will	c onduct	a postflight	inspection	of	the	aircraft.

2. The	aircraft	and	Ground	Control Station	will	be	inspected	for	s igns	of damage.		Screws	will	be	checked and	tightened	if	necessary.

3. Aircraft	propellers	will	be	inspe cted	to	ensure	they	are	not	da maged, loosed,	or	misaligned.

4. Motors	will	be	inspected	to	ensu re	the	motors	are	not	loose	and the supports	are	not	cracked.

5. Aircraft	batteries	will	be	charged.

6. Ground	Control	Station	batteries	will	be	charged.

7. All	batteries	will	be	charged	and maintained	according	to	the	D JI S1000	User	Manual.Revision 1 December 16, 2014 III. MAINTENANCE

A. Aircraft Log Book

1. Each	aircraft	will	have	a	log	book to	record	inspections,	maint enance, and	flight	operations.

B. Maintenance Procedures.

1. Each	aircraft	will	be	maintained	using	the	maintenance	procedur es contained	in	the	DJI	S1000	User	M anual,	the	A2	Flight	Control	S ystem User	Manual,	and	the	Consumer	En ergy	Pilot	Operating	Handbook.

2. All	maintenance	activity	will	be	logged	in	the	aircraft	log	boo k.

3. Batteries	will	be	charged	according	to	the	procedures	in	the	DJ I	S1000 User	Manual,	the	A2	Flight	Contr ol	System	User	Manual,	and	the Consumer	Energy	Pilot	Operating	Handbook.

C. Functional Test Flight

1. After	a	flight	critical	componen t,	such	as	a	propeller	or	motor ,	has undergone	maintenance	or	been	repaired	or	replaced,	the	aircraf t must	undergo	a	functional	test	flight.

2. Every	500	hours	of	flight	time,	the	PIC	will	conduct	a	function al	test flight	regardless	of	mai ntenance	activities.

3. The	PIC	will	make	an	entry	in	th e	aircraft	log	book	of	the	func tional test	flight.

# Attachment 2

Submitted confidentially unde r 14 C.F.R § 11.35(b). Exempt from disclosure under the Freedom of Information Act, 5 U.S.C § 552 et seq.

# Attachment 3

Submitted confidentially unde r 14 C.F.R § 11.35(b). Exempt from disclosure under the Freedom of Information Act, 5 U.S.C § 552 et seq.

# Attachment 4

# DJI **S100 0** 
**Pilot Operating Handbook**

### 1 

## Consumers Energy
PILOT OPERATION HANDBOOK DJI S1000

KEY PARAMETERS

Max	Takeoff	Weight	 24	lbs Weight	with	Zenmuse	and	all	other	equipment	–	no	camera,	no	bat tery	 13.4	lbs Weight	of	Nex5/6/7	camera	 1	lb Weight	of	Canon	5D	camera	 1.75	lbs Max	Battery	Weight	with	Zenmuse/Nex	Camera:	 9.5	lbs Max	Battery	Weight	with	Zenmuse/Canon	5D:	 9	lbs

Flight	Times	using	90%	of	battery:

16,000	mah	battery	Nex	7:		 	 17	min 20,000	mah	battery	Nex	7:		 	 20	min 32,000	mah	battery	Nex	7:		 	 22	min

Flight	times	using	the	Canon	5D or	other	cameras	similar	in	wei ght	will	reduce	the	flight	times	by about	1	minute.		These	times	are averages.		An	operator	may	get longer	or	shorter	flight	times based	on	weight	and	flying	style.

### 2 

# DJI	S‐1000

CHECKLISTS

DJI S

‐ 1000 BENCH SET UP & TESTS

o All	screws/bolts	are	tight

o Timer	alarm	for	flight	time	to	no t	exceed	80%	battery	capacity set	properly

o Batteries	are	secure

o Antennas	are	secure

o Props	balanced

o Props	aligned

o Props	not	chipped

o Check	blades,	arms,	etc.	for	cracks/damage

o Wiring	Tight

o No	excessive	flexing	of	motors	or	booms

o Booms/motors	will	not	twist

o Center	of	gravity	is	correct

o Warning	lights	set	for	low	battery	if	used

o Batteries	charged.	Replace	any	battery	which	cycles	below	80%	o f	rated	capacity

 Laptop	Battery

 Flight	Battery

 Handheld	Rx	Battery

 RC	Tx	Battery

 Video	Rx	Battery

 Spare	Laptop	Battery

### 3 DJI S

‐ 1000 INVENTORY CHECKLIST

o Load	Flight	plan

o Aircraft

o Camera	with	SD	card

o Spare	parts/tools

o Spare	batteries

o Two	RC	transmitters

o Laptop

o Battery	Charger

o Flight	Controller	Cable

o Video	monitor,	stand,	battery,	antennas

o Goggles

o Datalink	&	cable

o Battery	Y‐harness

### 4 DJI S

‐ 1000 PREFLIGHT CHECKLIST

o Determine	emergency	flight	plan and	alternate	landing	zones	avo iding	power	lines	and obstacles

o Check	wind	direction

o Set	a	perimeter	of	50‐100	meters	–	area	must	be	clear	of	people

o All	antennas	installed	and	all pointing	in	correct	directions

o Engage	GCS,	monitor,	laptop,	goggles,	etc.	(bring	up	flight	pla n)

o Remove	lens	cap	/	Clean	lens

o Camera	On

o Ensure	camera	has	SD	card	installed.

o Check	battery	voltage

o Install	battery	on	copter.

o Check	CG

o Level	copter	with	front	pointing in	correct	direction	for	cours e	lock	–	do	not	turn	on

o On	Copter	TX	‐	Set	switches	‐	Th rottle	Down,	Return	to	Home	swi tch	Off,	Manual	Flight Mode

o Switch	On,	Flight	Path	Switch	Off	–	Not	Course	or	Home	Lock

o Copter	Transmitter	On

o Check	Model	Selection	on	Tx

o Check	Tx	battery	voltage	(above	7.4v)

o On	Photo	Tx	–	set	switches	‐	HDM I	switch	Off,	Freestyle	switch On

o Photography	Transmitter	On

o Check	Model	Selection	on	Tx

o Check	Tx	battery	voltage	(above	7.4v)

o Plug	in	battery	black	lead	first.

o Calibrate	GPS/Compass	if	necessary

o If	calibrated,	cycle	battery	wit h	correct	heading	for	course	lo ck.

o Do	not	touch	the	Copter	until	30 seconds	after	full	GPS	Lock.	I nitial	3	red	blinks	is normal	meaning	no	GPS	lock.	Wait until	no	flashes.	Continue	wit h	checklist.

o Check	Copter	Voltage	from	GCS

o Engage	Attitude	Mode	–	Must	Achieve	Double	Amber	Flash

o Engage	GPS	Mode	–	Must	Ach ieve	Double	Purple	Flash

o While	in	GPS	mode	engage	“Course Lock”	mode.	Must	achieve	green Flash

### 5 o Do	not	engage	motors.	Set	throttle	to	center	position.	Must	ach ieve	single	amber	flash	in Attitude	Mode	and	single	purple	flash	in	GPS	mode

o HDMI	switch	On	(video	on	cam era	itself	should	go	off)

o Freestyle	switch	On	(FPV	Off)

o Verify	camera	operation	(If	prob lems,	check	Drive	Mode	–	Remote Cmdr	must	be	“on”, manual	focus,	intelligent	auto)

o Verify	data	link	if	installed	– rolling	copter	manually	should change	gauges

o Upload	flight	plan

o Verify	altitude	is	about	0	via	g auge	on	computer/GCS/video	moni tor/goggles

o Timers	set	properly

### 6 TAKEOFF CHECKLIST

o Engage	GPS	mode	–	Double	purple	flash

o Engage	Course	Lock	mode (double	green	flash)

o Announce	loudly:	“CLEAR	PROP”

o Position	the	sticks	in	the	lower left	hand	corners,	then	immedi ately	raise	the	throttle	2 clicks,	and	center	the	right	stick.

o Advance	throttle	to	1/4	power	for	5	seconds.	Assure	all	motors are	operating.

o Verify	that	left/right	and	forwa rd/back	stick	movement	engages the	proper	motors

o Verify	data	and	video	links	are	still	operational

o Announce	loudly:	“TAKING	OFF”

o Advance	throttle	to	full.	Copter	must	jump	off	of	the	ground.

o Ascend	to	3	meters.	Center	throttle	stick.	Should	be	single	gre en	flash.	Verify	wireless link,	GPS	hold,	camera	operation ,	gauges,	etc.	are	working	prop erly.

o Verify	course	lock	is	operational	by	rotating	90	degrees	and	pu shing	forward	on	stick.

o Verify	copter	stability.	If	unstable,	land	and	reset	gains,	rec alibrate,	or	retest	as
necessary.

o Raise	landing	gear

o Proceed	with	manual	mission

o For	autopilot	operation

 Ascend	to	10	meters	manually

 Engage	autopilot

o Manual	pilot/observer	must	monit or	the	informational	LED	and	be ready	to	take	over in	manual	mode	when	necessary.

o Manual	pilot	to	request	copter	f light	battery	voltage	readout	f rom	camera	operator periodically.

### 7 QUICK PREFLIGHT CHECKLIST

o Landing	zone	clear

o Level	copter	with	correct	heading

o Battery	4.1+	full,	3.8	depleted

o Camera	on.	SD	card	in.

o Both	TX	–	all	switches	down

o Both	TX	on

o Copter	on

o Check	GPS	and	Course	lock	checks

o Video	check

o Photo	check

o Timers	ready

o Takeoff

o Raise	Landing	Gear

o Unplug	6	batteries	upon	landing

### 8 ERROR MESSAGES

o White	flashes

 IMU	malfunction.	Land	and	determine	cause.	Possibilities:

 GPS/Compass	not	pointing	forward

 IMU	not	pointing	forward

 Set	up	of	X,	Y,	Z	for	location	o f	IMU	and	Compass	is	incorrect

o Excessive	rocking/instabi lity	possible	causes:

 Weak	motor

 Structure	flexing	from	fatigue	or	cracks

 Motor	mount

 Main	frame

 Booms

 Loose	Bolts	causing	flexing	or	misalignment

 Props

 Mounts

 Props	out	of	balance

 Props	misaligned

 Excessive	wind	speeds	or	gusts

 Excessive	Gains

 Excessive	motor	power.	Max	motor power	must	a	little	more	than typical	ascent
power.

o Red	Flashes	(1,	2	or	3	flashes	w ith	pauses)	–	GPS	loss	(3	is	mo re	serious).	Land	if	loss lasts	for	more	than	30	seconds.	Possible	causes:

 Clouds

 Structures

 GPS	mal‐function

 GPS	too	close	to	electrical	components

 GPS	vibration

### 9 LANDING CHECKLIST

o Landing	area	clear

o Lower	landing	gear

o Note	obstacles	in	flightpath

o Announce	loudly:	“LANDING”

o First	cut	power	to	the	aircraft

o Note	elapsed	time	of	flight

o Adjust	any	parameters	(camera	servo	speed,	exponential,	etc)

o Turn	power	off	to	transmitters, camera,	goggles,	monitors,	Rxs, etc.

o Touch	motors	to	verify	temperatures	are	similar

o Complete	flight	log

 Date	and	time	of	flight

 Batteries	used

 Time	of	Flight

### 10 TABLE OF CONTENTS

 Section	1:	General

 Section	2:	Limitations

 Section	3:	Emergency	Procedures

 Section	4:	Normal	Procedures

 Section	5:	Performance

 Section	6:	Weight	and	B alance/Equipment	List

 Section	7:	Air	Vehicle	and	Systems	Description

 Section	8:	Handling,	Service	and	Maintenance

 Section	9:	Supplements

### 11 

### SECTION 1 GENERAL

NOTE:	In	an	effort	to	minimize	costs	and	maximize	spare	parts	a vailability,	many	COTS (commercial	off	the	shelf)	compo nents	have	been	utilized.	Some may	have	slight	modifications	to better	suit	this	application.	Most	COTS	products	have	separate data	sheets,	assembly	manuals	and instruction	manuals.	They	are	re ference	in	this	document,	with key	factors	being	emphasized.

As	with	all	high	technology	prod ucts	utilizing	constantly	evolv ing	software,	it	is	important	to periodically	check	for	online	up grades	to	the	COTS	components, including	hardware,	firmware and	software.

WARNING:	Great	care	must	be	take n	with	the	batteries.	Much	of	t his	manual	and	supplemental information	is	devoted	to	the	use	and	care	of	the	batteries,	es pecially	the	flight batteries.	They	are less	volatile	than	gasoline,	thou gh	they	should	be	treated	with the	same	respect.	Become	very familiar	with	proper	techniques	of	their	use.

GENERAL CHARACTERISTICS

o Primarily	for	ISR	(Intelligence,	Surveillance,	and	Reconnaissan ce)

o Economical	due	to	extensive	use	of	COTS	products

o Low	Visual	Signature

o Low	Aural	Signature

o Quick	Launch	and	Recovery

o Short	Training	Period

o Simple	Operation

o Waypoint	Navigation

o Backpackable

o VTOL

o Quick	Repairs

o Redundant	Flight	Systems

o Safety	Return	to	Home	during lost	link	or	low	battery

o High	Degree	of	Mission	Success

o GPS	navigation	aid

o Various	sensors

o 24	lb	max	takeoff	weight

o Operating	Temp	Range:	‐5°C	to	+60°C

o Flight	Modes:	Manual	and	GPS aided	waypoint	navigation

### 12 o Maximum	Operating	Altitude:	1000	meters

o Maximum	Operation	Wind	Conditions:	10	m/s

o Propulsion	System:	LiPoly	batteries

o Takeoff:	Manual	or	Automatic

o Landing:	Manual	or	Automatic

o Takeoff/Recovery	Area:	5m	square

IMPORTANT DIMENSIONS

o Distance	rotor	to	rotor	across	the	center:	41”

o Height	with	GPS/Compass	folded	down:	21”

o Height	with	GPS/Compass	up:	25”

o Length	of	landing	gear	skids:	18”

o Distance	between	landing	gear	skids:	21”

IMPORTANT WEIGHTS

o Weight	including	Nex	7	camera,	Z enmuse	gimbal,	A2	autopilot	sys tem,	landing	gear, data	transceiver,	RC	transceiver,	video	transmitter,	regulators and	all	wiring	– everything	except	battery:	13.4	lbs

o Maximum	Takeoff	Weight:	24	lbs

o Battery	Weight:	up	to	9.5	lbs	wit h	Nex	camera	and	Zenmuse	Gimba l

MOTORS

o Manufacturer:	DJI‐Innovations

o Number	of	motors:	8

o Motor	type:	41mm	x	14mm

o Motor	Model	Number:	4114‐11

o Motor	KV/RPM:	400

o Motor	max	@	25.2V:	10,000	rpm

o Motor	Max	Power:	500	Watts

o Power	rating:	4000	Watts	maximum	power	consumption	for	all	8	mo tors

o Current	Max:	100	amps

o Amp	Draw	Typical	Average:	65	amps

### 13 PROPELLERS

o Manufacturer:	DJI‐Innovations

o Material:	Composite

o Number	of	propellers:	8

o Propeller	model	number:	DJI	15	x	5.2

o Number	of	blades:	2	‐	folding

o Propeller	Diameter:	15”

o Propeller	Pitch	(fixed):	5.2”

o Max	rpm:	10,000	rpm

ELECTRONIC SPEED CONTROLS

o Manufacturer:	DJI‐Innovations

o Number	of	speed	controls:	8

o Speed	control	model	number:	DJI	40A	Opto

o Rating	in	amps:	40	Amps	continuous

o Signal	Frequency:	30	‐	450	Hz

o Drive	PWM	Frequency:	8	KHz

AUTOPILOT

o Manufacturer:	DJI‐Innovations

o Autopilot	Model	Number:	DJI	A2

o Components:	GPS/Compass,	IMU,	Master	Controller,	Power	Distribu tion	System,	LED Indicator	Lighting	System,	Dat a	Transceiver,	GCS	Software

o Power	Consumption:	5W

o Operating	Temp	Range:	‐5°C	to	+60°C

o Software	Compatible:	Windows	XP	sp3	/	Windows	7

o Hovering	Accuracy:	Vertical	: ±	0.5m;	Horizontal:	±	2m

### 14 WIRELESS LINKS

o Distributor:	DJI‐Innovations

o Frequencies:

 2.4	Ghz	datalink	with	WiFi

 2.4	Ghz	Command	&	Control

 5.8	Ghz	Video

o Power	Consumption:	1	watt

o Usable	Range:	Less	than	2	km.

FUEL/FLIGHT BATTERY

o Manufacturers:	Various	COTS	suppliers

o Battery	chemistry	recomme nded:	Lithium	Polymer

o Battery	Capacity:	16,000	‐	42,000	mah

o Battery	cell	count	required:	6S	(6	cells	in	series)

o Battery	Voltage:	21	V	minimum	during	hover,	22.2V	nominal,	25.2 V	maximum

o Battery	Minimum	Rated	Disch arge	Rate:	20C	minimum

o Battery	Minimum	Charge	Rate:	1C	(3C	preferable)

o Battery	Rest	Time	between	discharging	and	charging:	0‐30	minute s

o Batteries	used	simultaneously:	1‐4

o Recommended	Battery	Discharge	Amount:	80‐90%

FLIGHT PARAMETERS

o Flight	Time:	up	to	30	minutes

o Payload	Max:	11	lbs

o Power	Consumption	in	a	Hover	at 21	lb	takeoff	weight:	1500	Watt s,	65	amps

### 15 WARNINGS

o Never	power	a	video	transmitter or	receiver	without	an	antenna connected	or	overload failure	will	occur.

o Read	all	information	regarding	batteries	contained	in	this	manu al	and	supplements.

o Batteries	are	highly	flammable	and	can	explode,	especially	when fully	charged. Improper	charging,	vibration,	impact,	high	discharge,	etc.	can lead	to	explosion	and	fire. Batteries	must	be	charged	under	constant	supervision	and	using proper	precautions.

o Batteries	fully	charged	must	be	handled	with	extreme	care.

o Batteries	must	not	be	stored	above	50%	charged	state.

o Store	batteries	between	20%	‐	50%	charged	state.	Fully	charge	j ust	before	use.

o Fully	charged	batteries	which	are not	to	be	used	within	24	hour s	should	be	discharged to	20%	‐	50%	charged	state.

o Discharging	LiPoly	batteries	in	excess	of	80%	of	their	rated	ca pacity	can	cause	harm	to the	batteries.

o Using	more	than	one	battery	at	a	time	requires	the	proper	wirin g	harness	so	that	the voltage	is	no	more	than	25.2V.	Over	voltage	will	cause	serious damage	to	electrical equipment.

o Using	more	than	one	battery	at	a	time	requires	weight	and	balan ce	checks.	Proper	CG	is critical	to	performance.	Airframe	must	not	be	overloaded.

o Propellers	must	be	balanced	to	avoid	excessive	vibration.

o GPS/Compass	must	be	facing	forward.

o Do	not	use	GPS	Mode	without	GPS	lock.

o Use	low	strength	thread	locking	compound	on	all	screws.

o Wireless	Video	and	Data	ranges	va ry	considerably	on	many	factor s	including	weather, equipment,	and	obstructions.	Be	prepared	for	com	failures.

### 16 

### SECTION 2 LIMITATIONS

AIRSPEED LIMITATIONS

o Vne	–	Velocity	to	Never	Exceed:	15	m/s

o Va	–	Typical	Maneuvering	Speed	–	5	m/s

POWER & POWERPLANT LIMITATIONS

o 40	Amps	max	per	motor

o 40	Amps	max	per	speed	control

o 320	Amps	max	total

o Do	not	exceed	80‐90%	discharge of	rated	battery	capacity

o Do	not	charge	batteries	which	are	warmer	than	air	temperature

o Allow	batteries	to	cool	aft er	use	before	charging

o Leave	an	air	gap	between	batteri es	when	multiple	batteries	are used	simultaneously

WEIGHT LIMITS

o Takeoff	Weight	Max:	24	lbs

 Must	be	checked	prior	to	takeoff if	any	change	in	equipment	is made

CENTER OF GRAVITY LIMITS

o 3mm	from	the	center	of	any	of	the	three	pairs	of	arms

 Must	be	checked	before	every	fli ght	to	ensure	batteries	were	in stalled	in	the proper	location.

 Check	all	4	pairs	of	arms	before	flight

MANEUVER LIMITS

o This	aircraft	is	intended	for	non‐aerobatic	operations

o G‐loading	maximum:	2G

### 17 TEMPERATURE LIMITS

o Operating	Temp	Range:	‐10°C	to	+40°C

o In	cold	temperatures

 Keep	IMU	at	room	temperature	i f	possible	before	the	flight

 Keep	Batteries	above	5°C	before	flight

 Do	not	fly	with	any	frost	or	ice	on	the	propellers

o In	warm	temperatures

 Batteries	heat	up	when	discharged

 The	higher	the	discharge	rate	th e	higher	the	temperature	increa se	during	use

 At	temperatures	above	45°C,	use	o f	2	or	more	batteries	is	requi red	to	lower	the load	on	any	one	battery	pack	to	keep	it	cooler.

WEATHER LIMITS

o Light	dust	and	light	rain	requir e	the	use	of	a	shield	for	the	e lectronics	in	the	center section.

o Light	dust	and	light	rain	are	a cceptable	for	the	unshielded	mot or	and	ESC.

RANGE LIMITS

o FUEL

 Fuel	capacity	is	a	primary	limiting	factor.

 Flying	into	the	wind	will	use	mo re	battery	power	to	travel	the same	ground distance.	Higher	air	speeds	will be	required	to	penetrate	the	w ind	which	used more	battery	power.	Take	this	in to	account	when	flying	a	missio n.

 Where	possible,	fly	upwind	at	the start	of	a	mission	and	downwi nd	at	the	end	to avoid	depleting	the	battery	befo re	returning	to	base.	Have	alte rnative	landing sites	available	in	case	of	emergency	landing.

o WIRELESS	LINK

 Wireless	links	will	be	stable	in	L OS	(line	of	sight)	in	most	co nditions

 Wireless	links	are	always	suscept ible	to	shorter	ranges	due	to

 Atmospheric	conditions

 Other	transmission	devices	in	the	area

 Jamming

 Antennas	not	aligned	properly

### 18  Improper	voltage

 Antenna	blockage	from	AV	in	certain	positions

 Multipath	–	reflection	off	buildings	or	ground	which	cause	mult iple signals	to	arrive	at	different	times	and/or	phase.

### 19 

### SECTION 3 EMERGENCY PROCEDURES

MOTOR FAILURE

o Operation	is	possible	with	one	motor/ESC/propeller	failure

 The	two	adjacent	motors/ESCs	wil l	be	increased	in	thrust	automa tically	by	the flight	controller	to	overcome	the	loss

 In	cases	where	the	airframe	is	h ighly	loaded	the	maximum	rating of	40	amps may	be	exceeded	by	these	two	motors/ESCs

 Operation	should	be	terminated	as	soon	as	possible	to	reduce	th e	possibility	of damage	to	the	remaining	motors

COMMUNICATION FAILURE

o Video	link	failure

 5.8	Ghz	being	the	shortest	wavel ength	in	general	AV	use	has	the least	ability	to penetrate.	This	link	should be	the	first	to	be	lost.

 It	is	best	to	lose	video	first! It	is	the	least	likely	to	cause a	crash	when	it	fails. 5.8	Ghz	can	lose	link	with	little	warning.

 Ensure	that	the	GCS	station	ante nnas	are	perpendicular	to	the	A V.	Do	not	point the	antenna	at	the	AV.

 Yaw	the	AV	to	change	the	antenna	position

 Other	links	should	still	be	good. Return	back	to	the	GCS	until link	is	restored. Transmitters	produce	heat	when	i n	operation.	When	overheated	th ey	may	have thermal	protection	which	interrupts	use	temporarily.	Use	of	a	h eat	sink	or	fan may	be	required	especially	wit h	high	ambient	temperatures.

 Higher	gain	antennas	may	be	used ,	but	do	so	with	caution.	High gain	antennas are	directional.

 Multiple	antennas	using	“diversity”	can	be	used.	Diversity	is	a device	which determines	the	best	signal,	and	uses	that.

 5.8	Ghz	even	at	high	wattages	th eoretically	has	less	range	than lower frequencies.	Changing	to	1.3	Ghz is	an	option,	though	there	are other	issues	to	be considered.

o RC	link	failure

 2.4	Ghz	antennas	can	lose	link	with	little	warning.

 Anything	in	between	the	two	ante nnas	can	cause	temporary	signal loss especially	a	person.

### 20  Hold	the	transmitter	up	in	the	a ir	and	walk	in	the	general	dire ction	of	the	AV (aerial	vehicle).

 Ensure	that	the	antenna	is	vertic al.	Do	not	point	the	antenna	a t	the	AV.

 The	failsafes	on	the	RC	link	sho uld	be	set	so	that	the	AV	retur ns	to	home.	Should this	require	a	heading	change,	t he	antenna	may	move	into	a	more desirable position	and	link	will	be	restored.

 The	onboard	equipment	may	block the	signal.	Yaw	the	AV	so	that the	antennas point	towards	the	GCS.

 A	LRS	(long	range	system)	can	be	used	as	a	permanent	solution. This	is	higher	in wattage	and	usually	on	433	Mhz.

Data Link Failure

 900	Mhz	do	not	lose	link	without	some	warning.	When	drop	outs	a re	noticed	to increase	in	frequency	that	is	the	limit	of	the	range.

 If	using	900	Mhz,	this	is	on	ce ll	phone	frequency.	If	a	cell	to wer	is	nearby	it	can swamp	the	signal.	900	Mhz	may	no t	be	usable	in	that	area.	Chang e	to	a	different freq.	or	remain	closer	to	the	AV

LOW BATTERY POWER

 Fail‐safes	can	be	set	such	that in	the	event	of	low	battery	pow er,	either	due	to	a failure	or	too	long	of	a	flight,	the	warning	light	on	the	AV	wi ll	constantly	flash amber.	This	is	the	first	level	of	warning.

 The	second	warning	level	is	red	flashing	lights

 Auto	landing	will	occur	when	bat tery	power	is	low.	It	may	land in	a	tree	or	a lake,	so	this	is	not	desirable.

 Landing	with	80‐90%	of	battery	dep leted	is	best.	Therefore	land ing	with	17,000 mah	used	and	3,000	mah	remaining of	a	20,000	mah	battery	is	des irable. Batteries	should	be	drawn	down	eq ually	when	in	use	if	they	are both	charged equally	and	both	in	relatively	the	same	condition/age.

 Do	not	mix	partially	charged	bat teries.	Only	use	completely	cha rged	batteries.

 Over	discharging	a	battery	below 19.8V	can	permanently	damage	t he	battery.

### 21 GCS FAILURE

 Takeover	by	the	external	pilot	should	happen	ASAP	using	the	RC link.

 Most	often	happens	due	to	a	low	battery.

 Keep	a	spare	3	cell	LiPoly	batte ry	with	the	appropriate	plug	to plug	into	the charge	jack	for	emergency	use.	M ost	chargers	are	19V	output	whi ch	is	roughly equivalent	to	a	4‐cell	battery .	3‐cell	batteries	may	work.

COMPASS CALIBRATION ERROR

 If	the	compass	is	out	of	calibrat ion	the	warning	light	will	fla sh	red.	This	is	the same	signal	as	low	voltage.	If	t he	voltage	is	correct,	there	is a	calibration	error.

 Recalibrate	the	compass	follo wing	the	instruction	manual

FIRE

 Fires	can	occur	due	to	a	short circuit	or	battery	failure.

 Disconnect	the	battery	ASAP	unle ss	there	is	danger	in	doing	so if	there	is	any electrical	issue.

 It	is	not	possible	to	put	out	a	battery	fire.

 Do	not	attempt	to	put	out	a	batte ry	fire.	Use	a	fire	extinguish er	to	put	out	fires surrounding	the	battery.	A	CO2	fi re	extinguisher	is	better	than the	powder	or chemical	type.	CO2	does	not	leav e	a	residue.	Water	can	be	used though	it	may cause	other	electrical	component	failures.

FORCED LANDINGS

 If	alternate	emergency	landing	z ones	should	be	chosen	ahead	of time.

 Be	sure	that	the	LZ	is	clear	of people	to	avoid	any	incidents.

 Land	in	the	nearest	LZ	which	is	clear	of	people.

 Announce	your	intentions	of	land ing	as	loud	as	necessary	to	ale rt	people	of	the incoming	AV.

### 22 

### SECTION 4 SET UP SUGGESTIONS

ELECTRONICS BURN IN

o We	recommend	that	you	put	weight s	onto	the	landing	skids	to	kee p	the	copter	on	the ground	and	run	the	copter	at	abo ut	70%	throttle	for	about	2	hou rs	to	burn	in	the electronics.	Most	electronic	fai lures	occur	in	the	first	2	hour s	of	operation.

GPS/COMPASS MAST LENGTH

o We	found	that	the	higher	the	mas t,	the	better	the	GPS	reception

Nex5N vs. Nex7 vs. Canon 5D vs. Panasonic GH3

o These	cameras	are	excellent	for	stills,	and	very	good	for	video .	The	best	for	video	is	the Panasonic	GH4	with	4k	capabilities.

o We	found	that	the	Nex	5N	takes	exceptional	quality	stills	and	v ideo,	though	most professionals	use	the	Nex	7.	The Canon	5D	is	better	than	the	Ne x7	due	to	its	larger

sensor.

o Use	the	Panasonic	GH4	if	you	primarily	shoot	video

RADIO SET UP

o Follow	the	instructions	in	the	manual

o We	prefer	the	switch	assignment	a s	shown	in	the	checklists	abov e	though	feel	free	to modify	to	your	liking

COPTER COMMAND AND CONTROL

o We	recommend	the	use	of	a	dual	r ate	switch	for	main	copter	oper ation.

 High	rate	–	used	to	initialize	t he	motors.	The	flight	controlle r	will	not	engage unless	it	sees	full	down	throttle, full	left	rudder,	full	left cyclic	and	full	back cyclic.	However,	these	may	be	t oo	high	for	normal	flying.	On	hi gh	rate	it	is	helpful to	utilize	fairly	high	exponenti al	to	make	the	stick	feel	soft around	center.	Adjust to	your	preference.

 Low	rate	–	used	for	typical	flying.	Set	the	end	point	adjustmen ts	such	that	full stick	deflection	offers	the	maxi mum	speed	required	in	normal	fl ying.	If conditions	require	higher	flight	speeds,	switch	to	high	rate.	O n	low	rate	it	is	also helpful	to	utilize	a	small	amount	of	exponential	to	make	the	st ick	feel	soft	around center.	Adjust	to	your	preference.

### 23 ZENMUSE COMMAND AND CONTROL

o We	recommend	the	use	of	a	dual	rate	switch	for	gimbal	operation

.

 High	rate	–	used	to	initialize	t he	gimbal.	The	gimbal	may	not	e ngage	unless	it sees	full	motion.	However,	these may	be	too	high	for	shooting	v ideo	smoothly. This	is	best	for	still	photograph y	so	as	to	put	the	camera	on	t arget	quickly.	On high	rate	it	is	helpful	to	utili ze	fairly	high	exponential	to	m ake	the	stick	feel	soft around	center.	Adjust	to	your	preference.

 Low	rate	–	used	for	videography. Set	the	end	point	adjustments such	that	full stick	deflection	offers	the	maxi mum	speed	required	for	videogra phy.	If conditions	require	higher	gimbal speeds,	switch	to	high	rate.	O n	low	rate	it	is also	helpful	to	utilize	a	small amount	of	exponential	to	make	t he	stick	feel	soft around	center.	Adjust	to	your	preference.

TIMERS

o Use	of	the	countdown	timer	is	a good	backup	method	to	ensure	la nding	with	battery
power.

 Set	the	timer	for	20	minutes	(or what	you	deem	appropriate)	and have	it	start when	the	throttle	is	over	1/4.	T hen	adjust	the	timer	upwards	un til	the	amount	of battery	used	is	about	80‐90%	of	the	total	available.	If	using	2 0,000	mah batteries,	a	total	of	17,000	mah would	be	the	target.	Set	the	t imer	such	that	you have	a	minute	or	so	to	land	afte r	the	alarm	sounds	so	that	you have	adequate time	to	return	to	base.	Ad just	to	your	preference.

BATTERIES

o Replace	the	transmitter	standard	battery	with	a	Lipoly	battery to	extend	use	times	to	8 hours.	Supplied	batteries	o ften	last	about	2	hours.

### 24 NORMAL PROCEDURES

PREFLIGHT CHECKLIST

o Confirm	all	communication	radios	are	operational

 Radios	with	others	in	the	group

o Set	a	perimeter	of	100	meters

 Area	must	be	clear	of	pe ople	to	avoid	collision

o Check	for	overhead	power	lines	and	other	obstacles	to	avoid

o Check	structural	integrity

 In	event	of	prior	crash,	inspect all	booms,	props	and	motor	mou nts	for	excessive flex	indicating	structural	fatigue/failure

o Have	a	manual	flight	plan	avoiding	obstacles.

o Load	auto	flight	plan	if	using	one

 Be	sure	that	the	total	flight	ti me	is	under	10	minutes	to	avoid low	battery

o Clean	lens

 Remove	lens	cap

o Ensure	camera	has	SD	card	installed

 Many	flights	have	been	wasted	due	to	this!

o Install	batteries

 Ensure	that	the	straps	are	tight and	the	Velcro	keeps	the	batte ries	from	moving which	will	avoid	a	shift	in	the	C G	(Center	of	Gravity	–	or	that it	balances	evenly)

o Check	CG	(Center	of	Gravity)

 Lift	the	copter	on	each	of	the	3 pairs	of	arms.	The	copter	shou ld	balance properly.	If	not,	do	not	fly.	Re arrange	the	equipment	such	that the	CG	is

o IMU	pointing	forward

 The	Inertial	Measurement	Unit	is set	so	that	it	must	face	forwa rd

o GPS/Compass	installed,	limited	free	play,	pointing	forward

 This	device	must	be	installed	with	a	screw	to	hold	it	in	place. It	cannot	vibrate easily.	If	it	does	not	point	for ward,	the	corrections	in	ATTI	a nd	GPS	mode	will	be incorrect	and	it	will	crash.	The	FC	will	provide	a	warning	with constant	flashing white	lights.

o Level	copter	using	a	bubble	leve l	with	front	pointing	in	correc t	direction	for	course	lock –	do	not	turn	on

 Keep	in	mind	the	best	angle	for pointing	the	landing	gear	in	th e	direction	that will	keep	the	landing	gear	out	of	the	shot	when	flying.

### 25 o Turn	on	Pilot	Tx

o If	using	the	rate	gyro,	set	it	at	the	correct	position.	This	is usually	a	slider	switch.	Gains should	have	the	range	set	from 200	–	350.	Use	the	highest	gain possible	which	does	not cause	oscillation.

o Check	Model	Selection	on	Tx	to	be	S800

o Throttle	on	Tx	Down

o Return	to	Home	switch	Off

o Adjust	gain	to	correct	position	(if	required)

o Manual	Flight	Mode	Switch	to	m anual	(not	ATTI	or	GPS	mode)

o Flight	Path	Switch	Off	–	Not	Course	or	Home	or	POI

o Check	Tx	battery	voltage	(above	7.5v)

 These	settings	above	are	require d	to	initialize	the	copter	prop erly.	If	the switches	are	in	the	incorrect	position,	it	will	not	initialize properly	which	may cause	some	of	the	functions	like	course	lock	or	GPS	mode	to	not operate properly.

 If	the	copter	does	not	function	properly	after	takeoff,	land	im mediately	and disconnect	the	copter	power.	The n	put	all	the	switches	in	the	p roper	position	for initialization	and	turn	the	power	back	on	to	the	copter.

o Count	down	timer	should	be	set	t o	20	minutes.	This	can	be	adjus ted	to	your	flying	style. The	timer	should	engage	at	1/4	throttle	and	trigger	an	alarm	at the	proper	time.	This	is a	backup	alarm	in	case	the	indic ator	lights	on	the	copter	are	n ot	visible.

o Turn	on	Photography	Tx

o Check	Model	Selection	on	Tx	–	should	read	Zenmuse

o Check	Tx	battery	voltage	(above	7.5v)

o HDMI	switch	Off

o Freestyle	switch	Off	(FPV	On)

 These	settings	above	are	require d	to	initialize	the	Zenmuse	pro perly.	If	the switches	are	in	the	incorrect	position,	it	will	not	initialize properly	which	may cause	some	of	the	functions	like	live	video	or	gimbal	operation to	not	operate properly.

 If	the	camera	or	gimbal	do	not	f unction	properly,	disconnect	th e	copter	power. Then	put	all	the	switches	in	the	proper	position	for	initializa tion	and	turn	the power	back	on	to	the	copter.

o Engage	power	to	copter

 Plug	in	the	2	battery	packs.	Typi cally	the	battery	packs	use	re d	T‐style connectors	in	a	parallel	wire	har ness.	This	Y‐harness	has	a	yel low	connector.	It	is preferable	to	connect	the	batter ies	to	the	Y‐harness	first,	the n	plug	in	the	yellow connector.	This	reduces	(but	does	not	eliminate)	electrical	arc ing.

### 26  6	quick	chirps	should	be	heard	c onfirming	6S	LiPoly	batteries	a re	recognized	by the	ESCs.

 Hearing	less	than	6	chirps	indic ates	fewer	cell	battery	packs	a re	being recognized	which	is	incorrect.	Check	for	improper	or	damaged	ba tteries.

o Do	not	move	or	vibrate	the	Squad copter	until	30	seconds	after	f ull	GPS	Lock

 Initial	3	red	blinks	is	normal	meaning	no	GPS	lock.	No	red	flas hes	indicates	full GPS	lock.

 Continue	with	checklist	as	you	are	waiting	for	full	GPS	lock,	b ut	do	not	move	the copter.

 If	the	GPS	takes	more	than	5	minutes	to	lock,	there	is	a	proble m	with	the	area.	It is	not	receiving	the	proper	sign als	from	the	satellites.	GPS	si gnals	are	weak,	so trees,	people,	buildings,	terrain,	weather,	have	an	effect.	Mov e	the	copter	into	a more	open	area	where	it	can	more	easily	see	the	satellites.

o Check	Copter	Voltage	from both	Tx’s	(transmitters)

 The	transmitters	receive	a	signal	from	the	corresponding	receiv ers.	The	voltages are	regulated	to	about	5v.	If	th e	voltage	is	below	4.4v	or	abov e	6v	do	not	fly. There	may	be	power	regulation	issues.	The	receivers	cannot	work outside	this voltage	consistently.	Also	there is	some	issue	if	the	voltage	i s	outside	that	range which	should	be	resolved	before	flying.

o Engage	Attitude	Mode	–	Must	achieve	double	amber	flash

o Engage	GPS	Mode	–	Must	achieve	double	purple	flash

o Engage	course	cock	mode	–	Must	achieve	double	green	flash

o Disengage	course	lock	mode.	Must achieve	double	purple	flash.	S tay	in	this	mode	until just	prior	to	takeoff,	after	tak eoff	at	any	time,	or	do	not	use

.

o Do	not	engage	motors.	Set	throttle	to	center	position.	Must	ach ieve	single	purple	flash when	in	GPS	mode.

 To	verify	that	the	sticks	are	all	centered	properly:

 With	throttle	in	the	center	posi tion,	use	the	trim	buttons	on	t he	transmitter	to check	that	the	sticks	are	centered.	Trim	the	roll	(the	stick	lo cated	on	the	right side	of	the	transmitter	when	mov ed	to	the	right	and	left)	to	th e	right,	counting the	number	of	clicks	until	a	dou ble	flash	occurs.	Then	center	t he	trim.	Then	move the	trim	to	the	left,	counting	t he	number	of	clicks	until	a	dou ble	flash	occurs.	An equal	number	of	clicks	should	be counted	each	side	of	center.

 Do	this	check	for	the	3	stick	mo vements	other	than	throttle.

 Center	the	trim	such	that	when	t he	stick	is	in	the	neutral	posi tion	that	there	are equal	numbers	of	clicks	in	each	direction.	This	ensures	that	wh en	the	sticks	are neutralized	that	the	flight	cont roller	will	recognize	this	sign al	and	engage	GPS mode.

### 27 o Calibrate	GPS/Compass	before	the first	flight	each	day	or	if	re ceiving	continuous	red blinks	or	continuous	white	blinks.

 Flip	the	GPS	mode	switch	7	times very	quickly	from	manual	to	GP S.	End	with	the switch	in	the	manual	position.	T he	indicator	light	will	be	blue .	Rotate	the	copter about	1.5	turns	in	a	horizontal position.	A	green	flashing	ligh t	indicates	that	this is	complete.	Then	hold	the	copte r	vertically	and	rotate	about	1 .5	turns.	A	white flashing	light	indicates	that	this	is	complete.	Repeat	if	neces sary	until	this	is completed.

o After	calibration,	reset	the	cop ter	by	cycling	battery	with	cop ter	pointed	in	the	correct heading	for	course	lock.

o Engage	Camera

o HDMI	switch	On

 This	will	stop	video	from	playin g	on	the	back	of	the	camera	and will	send	the video	signal	to	the	video	transm itter	via	the	HDMI	connection.

o Freestyle	switch	On	(FPV	Off)

 This	allows	the	camera	to	be	oper ated	freely	through	the	transm itter

o Verify	camera	operation

 Operate	the	shutter

 Set	the	focus	to	auto	or	manual. Manual	setting	is	usually	set to	infinity	to	stop constant	focusing	of	the	camera.

o Verify	data	link	if	installed

 Roll	the	copter	about	45	degrees	on	its	side	by	lifting	one	sid e	of	the	copter	and resting	one	side	of	the	landing	gear	on	the	ground

 A	corresponding	roll	should	be	seen	on	the	gauge.

 If	the	copter	is	rolled	to	the	r ight,	it	will	appear	on	the	gau ge	that	the	horizon rolls	to	the	left	–	not	the	right because	the	view	from	inside the	copter	is	that	the horizon	rolls	the	opposite	direction	of	the	copter.

o Verify	altitude	is	about	0	via	gauge	on	computer

 If	it	is	not	about	0,	the	altitu de	settings	for	the	waypoints	w ill	be	off	by	this amount.	This	could	cause	the	cop ter	to	fly	at	10	meters	or	30	m eters	if	the waypoint	is	set	for	20	meters	and the	altitude	is	off	by	10	met ers	one	way	or another.	If	the	copter	thinks	it	is	at	10	meters	when	it	is	on the	ground,	then	it will	only	rise	10	meters	above	t he	ground	to	achieve	what	it	be lieves	it	to	be	20 meters	above	the	ground.

 The	altitude	can	be	reset	using the	ground	control	software	by going	to	altitude offset.	o	Alternate	Emergency	Landing	Sites	Established

### 28 NORMAL TAKEOFF

o Engage	GPS	mode	–	Double	purple flash	when	the	throttle	is	down

.

o Switch	to	Course	Lock	flight	mode	if	required.	Purple	flashes	a re	replaced	with	green flashes.	Flying	in	course	lock	is	not	required,	but	helpful	in many	instances.

o Announce	loudly:	“CLEAR	PROP”

o Move	both	of	the	sticks	to	the	b ottom	left	corners	to	engage	th e	motors.	Within	1 second	move	the	throttle	up	1/8	–	1/4.	The	copter	should	not	li ft	off	until	about	%	stick is	reached.

o Verify	data	and	video	links	before	lifting	off.	If	anything	is not	working	properly,	move the	throttle	stick	to	low	to	dise ngage	the	motors	and	determine a	solution.

o If	all	flight	checks	are	passed, announce	loudly:	“TAKING	OFF”

o Advance	throttle	to	about	3/4.	Copter	must	jump	off	of	the	grou nd	to	avoid	one	skid coming	up	before	the	other	skid, and	the	skid	on	the	ground	get ting	caught	and	flipping the	copter	over	sideways.

o Ascend	to	3	meters.	Then	decrease	throttle	to	%	to	engage	the	G PS	hold.

o Verify	links,	GPS,	Attitude,	etc. Should	be	single	purple	flash

.

o Verify	that	the	copter	is	holdin g	position	within	.5m	in	all	di rections.

o Verify	camera	operation

o Verify	course	lock	is	operational	by	rotating	90	degrees	and	pu shing	forward	on	stick.

o Verify	copter	stability.	If	unstable,	land	and	reset	gains,	rec alibrate,	or	retest	as
necessary.

o Proceed	with	manual	mission	or

o For	autopilot	operation

 Ascend	to	10	meters

 Command	AVO	to	proceed	with	mission.

 Pilot	should	say	“It’s	yours”

 Response	from	AVO	“I	have	it”

o Manual	pilot/observer	must	monit or	the	informational	LED	and	be ready	to	take	over in	manual	mode	when	necessary.

 White	flashes	indicates	flight	controller	issue

 Amber	flashes	indicates	low	battery

 Red	flashes	indicate	loss	of	GPS or	severe	battery	condition

 Quick	decisions	are	required	when	red	flashes	are	indicated

 10	seconds	or	more	of	loss	of	GPS signal	will	stop	waypoint	gui dance	and any	GPS	hold	and	put	into	manual	mode.

### 29  Red	indicator	light	battery	warning	requires	immediate	landing

o Manual	pilot	to	request	copter	f light	battery	voltage	readout	f rom	AVO	periodically.

 Reset	the	first	and	second	indic ator	lights	as	required	for	you r	set	up.

 When	recharging	the	batteries,	th e	goal	is	to	put	4,000	mah	int o	a	5,000	mah battery	pack.	Adjust	the	voltage warnings	to	your	style	of	flyi ng.

 Also	use	the	countdown	timer	on the	transmitter.	This	gives	a	g ood	indication	of battery	level	because	the	current used	is	fairly	constant	from flight	to	flight.

POST LANDING

o Note	flight	time	from	transmitte r.	Write	this	down	in	the	log	b ook.

o Note	battery	power	used	during	t he	flight.	Write	this	down	in	t he	log	book.

o ALWAYS	disconnect	the	main	power to	the	AV	first,	then	turn	off the	transmitter.

o Check	motor	temperatures	by	touc hing	them	with	your	fingers.	An y	motors	which	are excessively	hot	should	be	furthe r	inspected	and	possibly	replac ed.

o Check	battery	temperatures	by	tou ching	them	with	your	fingers. Battery	temperatures should	not	be	hot	to	the	touch. Battery	temperatures	should	be slightly	above	ambient.

o Inspect	all	components	especia lly	the	propellers	for	wear.

o Note	in	logbook	which	batteries	were	used	to	calculate	life	cyc le.

AIRCRAFT FLIGHT LOG BOOK

o Keep	a	log	of	all	flights.

 Date

 Time	of	Day

 Time	in	Operation	(in	hours)

 Battery	serial	numbers

 Mah	used	in	flight

 Location

 Pilot,	Observer,	Sensor	Operator	Names

 Flight	Objective

 Remarks

### 30 AIRCRAFT MAINTENANCE LOG BOOK

o Keep	a	log	of	significant	inspections,	tests,	repairs,	alterati ons,	equipment	changes.

 Date	maintenance	is	performed

 Accumulated	hours	of	operation

 Remarks

PILOT LOG BOOK

o Keep	a	log	of	all	flights. Include	the	following:

 Aircraft	flown

 Aircraft	serial	number

 Date

 Time	of	Day

 Time	in	Operation	(in	hours)

 Location

 Flight	Objective

 Remarks

### 31 

### SECTION 5 PERFORMANCE

FLIGHT TIMES

o The	AV	is	designed	to	hover	at	high	efficiency.	Hovering	is	muc h	less	efficient	than flying	on	a	wing,	thus	flight	times	are	low	compared	to	fixed	w ing	aircraft.

o All	the	weight	of	the	AV	is	suppo rted	by	power	from	the	batteri es.	As	the	batteries	are used	in	a	flight,	the	amount	of	power	available	decreases.	Ther efore	the	power	reserve is	constantly	decreasing	as	the	battery	is	being	used.	Thus	loa ding	a	rotorcraft	above	its limit	is	not	recommended.	While	the	AV	may	have	enough	power	to lift	off	initially	on	a full	charge,	the	power	reserve	at partial	charge	may	be	too	low to	allow	for maneuvering	and	will	result	in	a	crash.

o High	lateral	speeds	will	add	lift	to	slightly	improve	efficienc y.	The	rotors	act	similar	to fixed	wings	at	higher	speeds.	This	increase	in	efficiency	may	b e	negated	by	the increased	power	consumption	of	forward	flight.

o High	winds	or	gusts	decrease	efficiency/flight	time.	The	motors work	harder	to	hold position.

o As	weight	increases	flight	times	decrease.

WIRELESS TRANSMISSION

o Refer	to	the	specific	manuals	for	performance	ratings.

o Wireless	communications	utilized provide	acceptable	communicati on	for	LOS.

o In	general:

 LOS	is	required

 The	higher	the	GCS	antennas,	the	better	the	range

 Any	freq.	at	may	have	severe	deg radation	due	to	location	to	oth er	admitters	such as	cell	towers

 RSSI	(Received	Signal	Strength	Ind ication)	should	be	monitored for	indication	of communication	drop	out.

### 32 

### SECTION 6 WEIGHT AND BALANCE EQUIPMENT LIST

CG

o CG	is	critical	to	the	efficient	operation	of	any	AV

o When	components	are	shifted,	the	CG	will	be	altered.

o The	main	components	which	are	moved	on	a	regular	basis	are	the sensors	and	the batteries.

o The	sensors	are	typically	in	the front	of	the	AV,	and	the	batte ries	are	located	in	the correct	position	to	offset	all	the	components	on	the	AV.

o The	CG	must	be	tested	after	any change	to	the	components	or	the ir	placement.

o The	CG	should	be	tested	by	lifti ng	the	UV	with	fingers	on	the	b ottom	of	the	arms.	Check all	3	pairs	of	arms.	The	CG	shou ld	be	no	more	than	2mm	off	in	a ny	on	the	3	checks.	The closer	the	CG	is	to	the	centerli nes	of	the	arms	the	more	effici ent	and	the	more	stable	the AV	will	be.

WEIGHT

o Weight	is	critical	to	the	operation	of	any	aircraft

o Weight	is	especially	critical	to a	rotor	wing	aircraft.	At	full throttle	the	motors	have	a finite	amount	of	thrust.	All	the weight	is	lifted	by	the	batter y	power,	there	is	no	wing	to assist	in	providing	lift.

o As	the	batteries	are	operated,	t hey	lose	power.	At	full	charge they	have	about	25v.	At 20%	remaining	capacity	they	hav e	about	21v.	This	is	a	loss	of	8 %	of	the	power	available which	is	significant.

o Do	not	overload	the	aircraft	or there	will	not	be	sufficient	re serve	power	to	maneuver at	low	battery	levels.

### 33 

### SECTION 7 AIR VEHICLE AND SYSTEMS DESCRIPTION

FUEL/BATTERY REQUIRED

o Manufacturers:	Various	COTS	suppliers.

o Refer	to	manufacturer	data	sheet.

o Battery	chemistry	requi red:	Lithium	Polymer

o Battery	Capacity:	16,000	mah	(minimum)

o Battery	cell	count	required:	6S	(6	cells	in	series)

o Battery	Voltage:	21	V	minimum	at hover,	22.2V	nominal,	25.2V	ma ximum

o Battery	Minimum	Rated	Disch arge	Rate:	20C	minimum

o Batteries	used	simultaneously:	1‐4	typical

o Recommended	Battery	Discharge	Amount:	80‐90%

WIRELESS COMMUNICATIONS

o Refer	to	the	specific	manuals	for	performance	ratings.

o Never	power	a	video	transmitter or	receiver	without	an	antenna connected	or	overload failure	will	occur.

o Wireless	communications	utilized provide	acceptable	communicati on	for	LOS.

o In	general:

o LOS	is	required.

o Lower	frequencies	penetrate	objects	such	as	trees	better	than	h igher	freqs.

o Lower	freqs	have	longer	range	than	high	freqs

o Higher	freqs	can	transfer	mo re	data	than	lower	freqs

o Higher	freqs	use	small er/shorter	antennas

o The	higher	the	GCS	antennas,	the	better	the	range	and	reception

o Any	freq	at	may	have	severe	degr adation	due	to	location	to	othe r	admitters	such	as	cell
towers

o Range	must	be	constantly	monitored.

o Alternate	antenna	types	may	be	utilized	to	improve	link/range. Patch,	helical,	omni,	etc. can	be	substituted.	They	mus t	be	verified	before	use.

o Alternate	freqs	may	be	utilized	to	improve	link/range.

### 34 

### SECTION 8 HANDLING, SERVICE AND MAINTENANCE

PROPELLER CARE

o Propellers	must	be	checked	each	flight	for	nicks	or	cracks

o Propellers	are	designed	to	last indefinitely	if	they	do	not	imp act	dust,	dirt	or	more.

BATTERY CARE AND USE

o Refer	to	instruction	sheet	inclu ded	from	the	battery	manufactur er.	Typical	information follows.

o Batteries	are	highly	flammable	and	can	explode,	especially	when fully	charged. Improper	charging,	vibration,	impact,	high	discharge,	etc.	can lead	to	explosion	and	fire. Batteries	must	be	charged	under	constant	supervision	and	using proper	precautions.

o Batteries	fully	charged	must	be	handled	with	extreme	care.

o Any	battery	which	puffs	up	is	con sidered	damaged	and	must	not	b e	used.	It	is	in	a dangerous	state.	Never	charge	a	puffed	up	battery.

o Any	battery	which	holds	less	than 80%	of	its	rated	capacity	sho uld	be	discarded.

o Cycle	test	each	battery	after	eve ry	50	cycles	or	if	a	battery	i s	suspected	to	have	lost	as significant	amount	of	its	capaci ty	to	determine	the	current	cap acity.

o Properly	dispose	of	batteries.	F irst	discharge	the	battery	full y	using	a	battery	cycler. Bring	to	a	recycler	such	as a	home	improvement	store.

o Always	charge	flight	batter ies	under	“balance”	mode.

o Flight	Battery	Recommended	Charge	Rate:	1	C	which	takes	approxi mately	1	hour	to charge

o Flight	Battery	Maximum	Charge	Rate:	May	exceed	5C.	Charge	rates higher	than	1C	will decrease	life	cycles.	Maximum	ch arge	rating	per	the	manufacture r	will	provide	300+ cycles.	Use	the	lowest	charge	rate	which	is	practical.

o Battery	Rest	Time	between	discharging	and	charging:	30	minutes minimum,	1	hour maximum.

o Do	not	charge	if	the	battery	is more	than	2°C	warmer	than	ambie nt,	especially	if	the temperature	is	above	20°C.	The	o uter	surface	is	cooler	than	the inner	core	after	use. Damage	will	occur	when	charging	a	warm	battery.

o Recommended	Battery	Discharge	Amo unt:	80%.	Using	more	of	the	ca pacity	of	the battery	will	decrease	the	life	cycles

o As	battery	temperature	approaches freezing	the	capacity	of	Lith ium	Polymer	batteries decrease.	Keep	warmer	than	5°C	b efore	installing	into	the	UV	(u nmanned	vehicle).

### 35 o Battery	capacity	decreases	at	hig her	discharge	rates.	Using	mor e	batteries	decreases the	discharge	rate	of	each	batte ry	thereby	extending	individual battery	capacity	slightly.

o Lower	discharge	rates	improve	the	life	cycles.

o Batteries	are	rated	at	greater	th an	300	life	cycles.	1,000+	lif e	cycles	are	possible.

o Batteries	must	not	be	stored	above	60%	charged	state	for	extend ed	periods.

o Batteries	should	be	stored	below	25°C	for	extended	periods

o Store	batteries	between	40%	‐	60%	charged	state.	Fully	charge	j ust	before	use.

o Fully	charged	batteries	which	are not	to	be	used	within	24	hour s	should	be	discharged to	40%	‐	60%	charged	state	usi ng	the	battery	discharger.

o Using	more	than	one	battery	at	a	time	requires	the	proper	wirin g	harness	so	that	the voltage	is	no	more	than	25.2V.	Over	voltage	will	cause	serious damage	to	electrical equipment.

PREVENTATIVE MAINTENANCE

o ANNUAL	INSPECTION

 If	the	airframe	has	in	excess	of 300	hours	in	a	one	year	period ,	an	annual inspection	must	be	completed.

 Disassemble	the	AV	and	inspect	a ll	components	for	wear	and	repl ace	any components	as	required.

 Test	all	batteries	for	capacity.

 Upgrade	firmware	and	software	to	latest	revisions

o 500	HOUR	PM

 Disassemble	the	AV	and	inspect	a ll	components	for	wear	and	repl ace	any components	as	required.

 Replace	all	8	motors.

 Test	all	batteries	for	capacity.

 Upgrade	firmware	and	software	to	latest	revisions.

### 36 

### SECTION 9 SUPPLEMENTS

COTS	components	have	been	utilize d	in	the	construction	of	this AV.		All	instruction	manuals, operating	handbooks,	warning	not ices,	and	more	are	available	as separate	documents.			Keep these	significant	documents	and keep	in	a	notebook	with	the	cop ter	at	all	times.

AIRFRAME

AUTOPILOT	SYSTEM

BATTERIES

BATTERY	CHARGER

CAMERA	MANUAL

CAMERA	GCS

DATA	WIRELESS	LINK

GIMBAL	CAMERA	MOUNT

GIMBAL	CAMERA	MOUNT	SERVOS

LAPTOP	COMPUTER

MOTORS

ONBOARD	REGULATOR

PROPELLERS RC/MANUAL	COMMAND	&	CONTROL	S YSTEM	SPEED	CONTROLS	(ESCs)

VIDEO	CAPTURE	HARDWARE

VIDEO	CAPTURE	SOFTWARE

VIDEO	WIRELESS	LINK

# Attachment 5Revision 1 December 16, 2014 

# DJI S1000

Training ManualRevision 1 December 16, 2014 I. CONSUMERS ENERGY PIC TRAINING REQUIRMENTS

A. The PIC will have the following qualifications.

1. Private Pilot Certificate

2. Third Class Medical Certificate

3. Completion of DJI Factory

‐ Certified Basic Operator Course

B. Description of DJI Factory

‐ Certified Basic Operator Course

1. Ground Training

16 hour webinar topics

General UAV characteristics, types, uses Principals of Flight Weight and Balance ‐ Center of Gravity calculations and methods Operational limitations (vertical speed, horizontal speed, weight, horizontal distance, altitude, endurance, weather, etc.) Subsystem Operation and Maintenance (Flight controller, IMU, GPS, Compass, Gyros, Accelerometers, Brushless motors, Speed controllers, Propeller, Retractable landing gear, Airframe, Video Transmission and Reception, Antennas, Video displays, etc.) Battery care Transponder operation

Maintenance
Record Keeping, Logbooks, and other Documentation

Insurance Requirements

Remote sensing theory and practical application Autopilot operation and Mission Planning Aircraft flight simulation Federal, State, and Local laws, rules, regulations, policies, and good practice Right of Way rules

FAA Certificate of Authority (COA) process
Pilot in Command (PIC) qualifications and responsibilities
Observer qualifications and responsibilities

Sensor Operator qualifications and responsibilities Recognizing and setting Early Warning Alarms/Signals Emergency ProceduresRevision 1 December 16, 2014 Integration with other aircraft in the national airspace Reading a sectional map for aircraft Preflight Checklist

In flight Checklist

Post flight Checklist

Autonomous Flight Preflight briefing

Checklist reviews Flight Certification Testing

How to start a UAV business Typical income for UAV businesses Typical charges for photography

2. Flight Training

a) Flight Training Day 1

– Quadcopters

 Preflight briefing on quadcopter operation

 LOS (Line of Sight) and FPV (First Person View) pilot flight training using quadcopters

Equipment Used: DJI	PhantomRevision 1 December 16, 2014 b) Flight Training Day 2

– Fixed Wing Aircraft

 Preflight briefing on fixed wing operation

 LOS (Line of Sight) and FPV (First Person View) pilot flight training using fixed wing aircraft

Equipment Used: TBM	Skyhunter,	MyFlyDream	Antenna	Tracker

. c) Flight Training Day 3

– Autopilot Operation

 Autopilot Mission Training

 Create autopilot missions

 Pilot flight training via autopilot missions created by the student

Equipment Used: DJI	S1000	fully	equipped

# Attachment 6AFS

- 14

- 320

- E Exemption No. 11062

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591

In the matter of the petition of

AS TRAEUS AERIAL Regulatory Docket No. FAA

- 201 4

- 0352

for an exemption from p art 21; § § 45.23 (b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103 ; 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91. 407(a)(1); 91.409(a)(2); and 91.417(a) and (b)

o f Tit le 14, Code of F ederal Regulations

GRANT OF EXEMPTION

By letter dated May 27, 2014, Jonathan B. Hill, Cooley LLC, Counsel for Astraeus A erial, and John McGraw

, Aerospace Consulting, LLC, Agent for Astraeus Aerial, 1299 Pennsylvania Avenue, NW

. , Suite 700, Washington, DC 20004 petitioned the Federal Aviation Administration (FAA) on behalf of Astraeus Aerial (Astraeus) for an exemption from p art 21

, § § 45.23(b)

, 61.113(a) and (b)

, 91.7(a)

, 91.9(b)(2)

, 91.103

, 91.109

, 91.119

, 91.121

, 91.151(a)

, 91.203(a) and (b)

, 91.405(a)

, 91.407(a)(1)

, 91.409(a)(2)

, and 91.417(a) and (b) of Title 14, C ode of Federal Regulations (14 CFR). The proposed exempti on, if granted, would allow operation of unmanned aircraft systems (UAS) for the purpose of scripted

, closed

- set filming for the motion picture and television industry.

The petitioner requests relief from the following regulations:

Part 21 prescribes

, in pertinent part, the procedural requirements for issuing and changing design approvals, prod uction approvals, airworthiness certificates, and airworthiness approvals

.
Section 45.23(b) prescribes, in pertinent part, that w hen marks include only the Roman

ca pital letter “N” and the registration number is displayed on limited, restricted or light

sport category aircraft or experimental or provisionally certificated aircraft, the operator2
must also display on that aircraft near each entrance to the cabin, cockp it, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

Section 61.113(a) and (b) prescribes that

—

(a) no person who holds a priv ate pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

(b) a private pilot may, for compe nsation or hire, act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

S ection 91.7(a) prescribes, in pertinent part, that n o person may operate a civil aircraft unless it is in an airworthy condition.

Section 91.9(b) (2) prohibits operation of U.S.

- registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Section 91.103 prescribes, in pertinent part, that e ach pilot in command shall, before beginning a flight, become familiar with al l available inf ormation concerning that flight , to in clude

—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any k nown traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorc raft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and3
(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropr iate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Section 91.109 prescribes , in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

Section 91.119 prescribes that, e xcept when necessary for takeoff or landing, no person may operate an aircraft below the f ollowing altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open a ir assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populate d areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or pr operty on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters b y the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Section 91.121 requires , in pertinent part, each person operating an aircraft to maintain cruising altitude by referenc e to an altimeter that is set “ to the elevation of the departure airport or an appropriate altimeter setting available before departure.”4

Section 91.151(a) prescribes that n o p e rson m a y b e g in a f l i g ht i n a n a irpl a ne und e r VF R c ondi t io ns unless ( c onsid e ring wind a nd f o r e ca st w ea ther c ondi t ions) the r e is

enou g h fu e l t o fly to t he fi r st po i nt of in t e nd e d landing a nd, a ssu m ing norm a l

c r uis i ng spe e d

, (1) d uring the da y , to f ly after that for at l e ast 30 minutes ; or (2) At night, to fly afte r that for at least 45 minutes. [ e mph a sis added ]

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) a n appropriate and current airworthiness certificate ; and (2) a n effective U.S. regist ration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft R egistration Application as provided for in § 47.31(c) . Section 91.203(b) prescribes , in pertinent part, that n o person may operate a civil a ircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall

, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter

.

Section 91.407(a)(1 ) prohibits, in pertinent part, any person from operat ing an aircraft that has undergone maintenance, preventive maintenance, r ebuilding, or alteration unless i t has been approved for return to service by a person authorized un der § 43.7 of the same chapter

.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had a n inspection for the issuance of an airworthiness certificate in accord ance with part 21 of this chapter.

Section 91.417(a) and (b) prescribe s , in pertinent part, that

—

(a) E ach registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor , and appliance of an aircraft

. The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and5

(iii ) The signature, and certificate number of the person approving the aircr aft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, r otor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspecti on required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety dir ective number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and cu rrently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repe ated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.

(3 ) A list of defects furnishe d to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.6

The petitioner supports its request with the following information: The petitioner has provided the following information

– contained in its petition and supplemental proprietary Flight Operations and Procedures Manual (hereafter FOPM) and Motion Picture and Television Operations Manual (hereafter MPTOM)

– in support of its exemption request

. T he petitioner submitted additional information in response to the FAA’s August 7, 2014 request which is posted to the docket. T he FAA has organized the petitioner’s information into three sections : 1) the unmanned aircraft system, 2) the UAS Pilot In Co mmand (PIC), and 3) the UAS operating parameters

. Unmanned Aircraft System

The UAS proposed by the petitioner is a proprietary design, conceived and constructed by Astraeus Aerial, and referred to as the Astraeus Aerial Cinema System V.3CS UAS aircraft

var iant, serial #001 onward ( hereafter referred to as V.3). This aircraft has eight rotors and eight motors in a quadcopter configuration (X8)

. T he petitioner states that given the size

, weight, speed, and limited operating area associated with the aircraft t o be utilized by the applicant, an exemption from 14 CFR p art 21, S ubpart H (Airworthiness Certificates)

, subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR p art 11 and S ect ion 333 of the FAA Modernization and Reform Act of 2012 (PL 112

- 95)

. The petitioner further states that UAS operated without an airworthiness certificate in the restricted environment and under the conditions and limitations proposed by the petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 CFR p art 21, S ubpart H and not subject to the proposed conditions and limitations. The petitioner states tha t the unmanned aircraft ( UA ) to be operated under this request is less than 55 lbs. fully loaded , flies at a speed of no more than 50 knots, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclu sively within a secured area as set out in the MPTOM . In addition, the petitioner has integrated safety features into the design of the UAS, as described in the petitioner’s FOPM

, to ensure the safety of persons and property within and surrounding the limi ted operating area. The petitioner further describes that

, i n the event the UAS loses communications or its GPS signal, the UA will have the capability to return to a pre

- determined location with in the Security Perimeter and land. It will also have the cap ability to abort a flight in the event of unpredicted obstacles or emergencies.

T he petitioner states that even though its UAS will have no airworthiness certificate, an

ex emption may be needed from 14 CFR § 45.23 as the UA will have no entrance to the ca bin, cockpit, or pilot station on which the word “experimental” can be placed. Given the size of the UA

, the petitioner notes that the two

- inch lettering will be impossible. The petitioner asserts that an equivalent level of safety will be provided by havi ng the UA marked with t he word “experimental” on the fusela ge in compliance with 14 CFR § 45.29(f), in a location where the pilot, obser ver , and other s working with the UA will see the identification

.7

The petitioner states that the maintenance requirements in the pertinent sections of 14 CFR
p art 91 are only applicable to aircraft with an airworthiness certificate in accordance with p art 43. The petitioner states that its V.3 UAS does not have specific maintenance instructions ; therefore the petitioner has developed and documented in its MPTOM and FOPM an “on

condition” maintenance process for the V.3 UAS affected by this exemption. The petitioner has also stated that it intends to follow any manufacturers ’ recommended instructions and procedures when those procedures exist for certain components of its V.3 UAS.
UAS Pilot In Command (PIC) The petitioner asserts that since the UA will not carry a pilot or passengers on board, the proposed operations will not adversely affect safety by requiring the PIC operati ng the aircraft to have a private pilot’s license rather than a commercial pilot’s license. In support of its position, the petitioner argues that

, since there are no standards for either private or commercial UAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the UAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. Furthermore, the petitioner explains that, given the restrict ed and controlled airspace within which operations will take place, the key factors needed by the PIC are knowledge of the airspace within which the “closed

- set filming” operation will take place and how that airspace fits into the National Airspace System (NAS). The petitioner also states that it cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre

- approved airspace. The petitioner asserts that there are relatively few certificated pilots who are also qualified to fly the type of UAS utilized in motion picture indu stry image

- capture operations. Astraeus further asserts that t here are even fewer commercially certificated pilots that can fly these UAS, to the point that to do both is considered rare. Additionally, the petitioner states that the aircraft will be opera ted within a secure environment, which no one will be allowed t o enter unless they are part of the production, have been fully briefed of the risks prior to operation of the UAS, and have consented to the risks associated with being in the operating area. Should there be a mishap, the UA being flown pose significantly less of a threat than the helicopters and fixed wing aircraft now being employed because they are a fraction of the size, carry no flammable fuel, and do not carry crew or passengers. This is in stark contrast to conventional aircraft that are flown to th e site,
carry flammable fuel, carry passengers and crew, and operate in a much larger area. UAS Operating Parameters The petitioner states that all flights will be operate d within visu al line of sight (VLOS) of a pilot a nd/or observer, and that the UA flig hts will be limited to a maximum altitude of 400 feet AGL. The petitioner further states that an operator will ensure that only consenting production personnel will be al lowed within 100 feet of the UA operation, but this radius may be reduced to 30 feet b ased upon an equivalent level of safety determination, as stated in their MPTOM, with the advance permission of the local Flight Standards District Office ( FSDO )

. The petitioner asserts that an equivalent level of safety can be achieved given the size, wei ght,8

and speed of the UAS

, as well as the location where it is operated

. The petitioner states that the UAS will be operated within a safe operating perimeter, the boundaries of which will be determined by production personnel and the UAS PIC based on the site

- specific filming activities and speed of the UAS required for the operation, and coordinated with the jurisdictional FAA FSDO and local government officials as applicable, as outlined in the MPTOM and FOPM. The petitioner states that only participatin g and consenting production personnel will be allowed within this perimeter; the petitioner also states their intention to comply with the guidelines outlined in Order 8900.1 V3, C8, S1 with regard to nonparticipating personnel outside the safety perimeter

. The petitioner argues that

, compared to flight operations with aircraft or rotorcraft weighing far more than its maximum 55 lb . UA

, and the lack of flammable fuel, any risk associated with its UAS operations is far less than those with conventional aircr aft operating at or below 500 feet AGL in the movie industry. With respect to preflight actions, the petitioner notes it may need an exemption from 14 CFR § 91.103

, because it will not have approved rotorcraft flight manuals. The petitioner asserts that a n equivalent level of safety will be achieved by t he PIC taking all preflight actions as set forth in their M P T OM and FOPM, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before initia tion of flight. Additionally, the petitioner states that a briefing will be conducted prior to each day’s filming regarding planned UAS operations, and all personnel who will be performing duties within the boundaries of the safety perimeter will be requir ed to attend. With respect to the fuel requirements, the petitioner notes that

, in order to meet the 30 minute reserve requirements in 14 CFR § 91.151, UAS flights would have to be limit ed to approximately 10 minutes. The petitioner argues that

, given the limitations on the UA’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. The petitioner believes that an equivalent level of saf ety can be achieved by limiting flights to 30 minutes or 25% of battery power, whichever occurs first. The petitioner notes that it may need an exemption from 14 CFR § 91.121, as its UAS may have a GPS altitude read out instead of a barometric altimeter. T he petitioner asserts that an equivalent level of safety will be achieved, as outlined in its M P T OM. Specifically, the altitude information will be provided to the UAS PIC via a digitally encoded telemetric data feed. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the PIC

. Public Interest The petitioner states that, given the small size of the UA involved and the restricted sterile environment within which it will operate, its proposed operation “fal ls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence immediately.” Also due to the size of the UA and the restricted areas in whi ch the UAS will operate, approval of the application presents no national security issue. The petitioner states that, given the clear direction in Section 333, the strong equivalent level of safety surrounding the proposed operations, and the significant p ublic benefit, including enhanced safety, reduction in9
environmental impacts, and including reduced emissions associated with allowing UAS for movie and television operations, granting the requested exemptions is in the public interest.

Discussion of Publ ic Comments : A summary of the petition was published in the Federal Register on June 2 6 , 2014 (79 FR 36378 ). Eighty

- six comments were received.

Of the 86 comments received, in cluding eight from associations, 50 comment s supported the exemption request, 22 opposed

, and 1 4 were neutral. The petition received comments on the following topics: economic impact, UAS, PIC , operational capabilities, airspace, privacy, sense and avoid, and data link. Comments supporting the exemption request came from individuals an d industry groups, including the Association of Unmanned Vehicle Systems International (AUVSI), Aerospace Industries Association (AIA) , the National Association of Realtors, the News Media Coalition, and the National Press Photographers Association. Suppor ting comments cited the petitioner’s intent to use controlled access airspace, licensed airmen, and preflight safety briefings, as well as the economic benefits of UAS. Several trade organizations submitted letters to the docket, expressing various issues and

concerns with the Astraeus p etition for e xemption, including the Air Line Pilots Association International (ALPA), the National Agricultural Aviation Association (NAAA), and the United States Hang Gliding and Paragliding Association (USHPA )

. ALPA expr essed concern regarding certain conditions outlined in Astraeus’ petition. A LPA notes that the proposed operations will be for “compensation or hire,” and ALPA believes that the pilot must hold at least a current FAA Commercial Pilot Certificate with an ap propriate category and class rating for the type of aircraft being flown as well as specific and adequate training on the UAS make and model intended to be used. Similarly, a current 2nd Class FAA Medical certificate should be required for a UAS pilot oper ating an aircraft for compensation or hire commercial operations as is required in the NAS today. NAAA and USHPA also commented on pilot qualification. Specifically,
NAAA believes that the Part 61 regulations current ly in effect do not address the licensin g of pilots of an unmanned aircraft used for commercial purposes. We believe it is necessary for the FAA to evaluate pilots of these aircraft on their knowledge and skills in UAV operations. Requirements for this licensing should be developed along with ot her rigorous rules and qualifications to ensure safe integration of the unmanned aircraft into the NAS. The FAA has carefully reviewed the knowledge and training required by holders of both private and commercial certificates , as well as the separation of Astraeus’ proposed operations from other manned operations

. Additional details are available in the ensuing analysis of this issue with regards to 14 CFR § 61.113. ALPA commented that although the anticipated operation is expected to occur below 400 feet

a bove the surface, the petition also makes reference to operations 200 feet above structures of unspecified and therefore unlimited height. This would put the aircraft at the same altitude10
strata as other aircraft in the NAS, with only geographic separation to mitigate the risk of collision. However, in subsequent materials posted to the docket, Astraeus has removed
oper ation from elevated platforms. All operations will be limited to 400 feet AGL, which is specified in the conditions and limitations below. ALPA further notes that the aircraft “may not have a barometric altimeter” so the ability to accurately maintain altitude must be addressed. NAAA n oted the same in its comments. The FAA agrees with ALPA and NAAA and addresses this concern in its analysis o f the exemption from 14 CFR § 91.121, finding that the alternative means of compliance proposed by Astraeus does not adversely affect safety.

ALPA and an individual comment that Command and Control (C2) link failures are one of the most common failures on a UAS, and that lost link mitigations should require safe modes to prevent fly

- aways or other scenarios. The FAA agrees and carefully examined the proposed operation to ensure that the vehicle design and the petitioner’s MPTOM and FOPM addressed potential hazards related to C2 failure. The FAA finds that the UAS to be operated by Astraeus has sufficient design features to address these hazards. The FAA also finds that the MPTOM and FOPM have incorporated safety procedures to be followed by all operational
p articipants should a C2 failure occur. Further detail is contained in the analysis of the UAS below.

NAAA stated that it represents the interests of small business owners and pilots lice nsed as commercial applicators. NAAA members operate in low

- level airs pace , and clear low

- level airspace is vital to the safety of these operators.

NAAA stated that s eeing and avoiding other aircraft and hazardous obstructions is the backbone for agricultural safety

, and agricultural pilots depend on pilots of other aircraft to perform their see and avoid functions needed to prevent col lisions. NAAA believes that UA operations at low altitudes will increase the potential of collision haza rds with agricultural aircraft. In its comments, the USHPA submitted similar concerns rel ative to activities of other low altitude user groups including ballooning, skydiving, powered ultralights, etc. NAAA acknowledged Astraeus’ plan to submit a written Plan of Activities to the FSDO three days before the proposed operations, as required by t he petitioner’s MPTOM

. However, NAAA maintains, as does the USHPA, that in addition to this, issuan ce of a NOTAM advising non participating pilots of the planned activity is vital to dissemin ating this safety information. The FAA agrees and has incorporated this into the conditions and limitations of this exemption. Further detail is contained in the analysis of the operating parameters below. NAAA commented that UA should have assigned numbers that can be read from a suitable distance to aid in identificati on when enforcement of flight regulations is required. The USHPA commented similarly, noting that while the current identification standar ds are not feasible on small UA given their reduced size, identification appropriate for these design parameters could be defined and created without undue burden or negative impacts on UAS operations. The FAA partially agre es with NAAA and USHPA. UA operated under this exemption will be marked in accordance with 14 CFR part 45 or as otherwise authorized by the FAA. Furth er detail is contained in the analysis of the UAS below.11

USHPA states that it is a nonprofit member organization with the specific and primary purpose to engage exclusively for scientific and educational purposes in the development, study, and use of fuel

- less flight systems and aircraft capable of being launched by human power alone. USHPA commented that it believes with proper notification of time and place, along with other considerations, safety can be maintained. USHPA’s notification concerns will be a ddressed by the conditions and limitations that will require an Air Traffic Organization issued Certificate of Waiver or Authorization (COA) to address airspace requirements and notification. Further detail is contained in the analysis of the UAS operating parameters below. Related to the operation of the UA within visual line of sight (VLOS) of the pilot and/or observer, U SHPA believes operation of any UA in three

- dimensional space presents unique challenges in accurately determining position in relation t o stationary or mobile objects. USHPA comments that utilization of an observer for operational redundancy is prudent and encouraged, but should not be considered a viable replacement for the pilot in command. USHPA believes that the identification of navig ational requirements and accurately conveying them to the pilot in command would not be provided with adequate precision or sufficient response time in a crisis situation and recommends that dual control systems be utilized as a redundant safety measure co mmon in commercial aviation environments. The FAA notes USHPA’s concerns ; additional detail is provided in the analysis of the UAS below

. USHPA also asserts that manned flight should always maintain right of way over all UA operations. The FAA agrees and h as incorporated this into the conditions and limitations of this exemption. Several comments noted that small UAS can be hard to see during the day, due to their small size and factors such as sun glare . Commenters also noted concerns with regard to weathe r and wind conditions affecting operations. The FAA addressed these concerns by adding operating restrictions in the conditions and limitations regarding stand

- off distance from clouds

, altitude restrictions , and operating distance from non

- participating p ersonnel . Further detail is contained in the analysis of the UAS operating parameters below. The petition received several comments suggesting that UAS operated under this exemption should have the ability to monitor and communicate with other aircraft or install transponders, or that the UAS should not operate until they can sense and avoid other aircraft. One commenter suggested that the FAA should implement a buffer between these UAS operations and manned operations, while another raised concern with nea r misses with other aircraft. Two comments noted that UAS are susceptible to accidents and GPS jamming. The FAA believes the limitations under which the petitioner will operate (i.e. VLOS and at or below 400 feet AGL) and the UAS emergency procedures as ou tlined in the petitioner’s FOPM and MPTOM are sufficient mitigation s to this risk so that the operations will not adversely affect safety. F urther information is contained in the analysis of the UAS below. One commenter suggested that the FAA should requir e testing of software and systems prior to operation, including testing to RTCA standards. The FAA believes the preflight checks discussed in the analysis of the UAS operating parameters are sufficient to mitigate this risk, and addresses this in the condi tions and limitations below.12
The FAA also received comments not related to the UA and its operation as proposed by the petitioner, but rather addressing more general UAS issues, which are discussed below. The FAA received two comments asking how the FAA pl ans to monitor or conduct surveillance of the petitioner’s UAS operations. The FAA expects operators to comply with its regulations and the terms of the exemption. The jurisdictional F SDO will be the primary office responsible for oversight of the operatio ns. The FAA received several comments that integrating UAS operations via a broadly applicable rule was a more suitable method than the exemption process, and that industries other than the motion picture industry should be allowed to participate. Section 333 provides interim authority to the Secretary of Transportation, which facilitates limited, controlled UAS operations prior to the completion of a UAS regulatory structure. The FAA is using its exemption process to facilitate implementation of Section 33 3 and to address FAA rules that would be applicable to the proposed operations. We have received and are considering exemption petitions from a broad array of industries and applications for this technology. Additionally, t he FAA is engaged in a rulemaking process that will allow broader applications of UAS operations. Two commenters suggested this exemption process should be available to anybody, regardless of organizational size or resources. The FAA will consider any request for exemption submitted to i t
, no matter the source. One commenter stated that meaningful public review of the petition was not possible because some of the documents submitted by the petitioner are confidential. The FAA routinely considers confidential materials in its exemption pro cess. The FAA reviewed and considered the petitioner’s information in its analysis of the petition. The petition received several comments on privacy. A commenter expressed concern that the UAS could be used for spying. Other commenters stated that there a re strong privacy regulations in place. Specifically, a commenter states that the petitioner addressed privacy issues in its request by mandating that all filming be within a contained environment with all participants fully aware that they are being filme d. The petitioner states that all UAS flights will occur over private or controlled access property with the property owner’s prior consent and knowledge, and that only people who have consented or otherwise have agreed to be in the area where filming will take place will be filmed. The FAA notes that the terms of this grant of exemption are consistent with the petitioner’s proposal in this area.

The FAA's analysis is as follows :
U nmanned aircraft system (UAS ) Regarding the petitioner’s requested relief f rom 14 CFR part 21 Certification procedures for products and parts

, the FAA finds that

, based on the limited size, weight, operating conditions, design safety features, and the imposed conditions and limitations, the petitioner has demonstrated that its op erations would not adversely affect safety compared to similar13
operations conducted with aircraft that have been issued an airworthiness certificate under 14 CFR p art 21, S ubpart H. Commercial motion picture and television aerial filming operations with ma nned aircraft are typically conducted with aircraft holding standard airworthiness certificates issued under
p art 21, subpart H. These aircraft are normally modified via the Supplemental Type Certificate ( STC ) process to install cameras and other equipment not included in the original aircraft design. Manned helicopters conducting motion picture and television ae rial filming can weigh 6,000 lbs . or more and are operated by an onboard pilot, in addition to other onboard crewmembers,
as necessary. The petiti oner’s UA will weigh less than 55 lbs. with no onboard pilot or crew. The pilot and crew will be remo tely located from the aircraft. The limited weight significantly reduces the potential fo r harm to participating and non participating individuals or prope rty in the event of an incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial filming operation

. Manned aircraft are at risk of fuel spillage and fire in the event of a n incident or accident. The UA carries no fuel

, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. During motion picture and television aerial filming with manned aircraft under the conditions of an FAA is sued Certificate of Waiver, aircraft can be operated in very close proximity to participating persons

. The s afety of these individuals is maintained through use of an aircraft with standard airworthiness certification under 14 CFR part 21, S ubpart H, opera tion of the aircraft by a qualified and competent pilot

, and operating according to limitati ons necessary to ensure safety. In these situations, the filming subject and production personnel are exposed to risk by virtue of their close proxi mity to an aircr aft in flight. Compared to manned aircraft, the UA being operated by the petitioner reduces the risk to participating persons in close proximity to the aircraft due to the limited size, weight, operating conditions, and design safety features of the UAS. This exemption does not require an electronic means to monitor and communicate with other aircraft , such as transponders or sense and avoid technology . Rather the FAA is mitigating the risk of these operations by placing limits on altitude, requiring stand

- off distance from clouds, permitting daytime operations only, and requiring that the UA be operated within visual line of sight and yield right of way t o all other manned operations. Additionally, the exemption provides that the operator will request a NO TAM prior to operations to alert other users of the NAS. The petitioner’s UAS has the capability to operate safely after experienci ng certain in

- flight failures. The UA is also able to respond to a lost

- link event with a pre

- coordinated, predictable, auto mated flight maneuver. With regard to USHPA’s concerns about dual control systems, c urrent FAA regulations permit motion picture and television filming operations by manned aircraft that do not require a copilot

. Additionally, u nder this exemption, the FAA requires that the UAS PIC hold a current th ird class medical certificate. Historically, instances of complet e PIC incapacitation are rare. I n all other cases other than complete incapacitation,14
the PIC has the ability to terminate the flight operation or initiate the automated return to home proce dure outlined within the FOPM. T he FAA also believes that the multiple control redundancies described in the petitioner’s FOPM are sufficient to mitigate risks associated with the loss of GPS signal

. In considerat ion of these factors and the UA size, weight, speed and other operating limitations associated with this aerial filmmaking operation, the FAA finds that there is no adverse safety affect relative to similar operations conducted by manned aircraft with a fl ight crew complement of one. These safety features also provide for no adverse safety affect to participating and

non participating individuals compared to a manned aircraft that holds a standard airworthiness certificate performing a similar operation.

In accordance with the statutory criteria provided in Section 33 3 of P L 112

- 95 in reference to 49 USC 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transport ation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21 , and any associated noise certification and testing requirements of part 36, is not necessary. Regarding the petitioner’s reque sted relief from 14 CFR § 45.23 (b) Display of marks , t he petitioner’s request is made under the assumption that marking with the word “experimental” will be required as a condition of an exemption request. T his marking is reserved for ai rcraft that are issued experim ental certificates under § 21.191. Since t he petitioner’s UAS will not be certificated under 14 CFR § 21.191, a grant of exemption for 14 CFR § 45.23 (b) is not
necessary. The petitioner’s UA must be identified by serial numbe r, 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. Regarding the petitioner’s requested relief from 14 CFR § § 91.405(a) Mainte nance required

, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration

, 91.409(a)(2) Inspections , and 91.417(a ) and (b) Maintenance records , the FAA has determined that relief from 91.409(a)(1) is also necessary

, becaus e it is an alternate inspection requirement of 91.409(a)(2)

. The petitioner ’s FOPM contains the maintenance requirements for the V.3 UAS, to include

“ on

- condition ” maintenance and modifications. The petitioner ’ s MPTOM and FOPM wer e reviewed and do not suf ficiently support the regulatory relief sought under 14 CFR part 91

, Subpart E. The FAA has carefully considered the petitioner ’ s supplemental information and determined that its operations will not adversely affect safety with regard to the regulatory mai ntenance and alteration requirements of 14 CFR § § 91.405(a) (1), 91.40 7 (a)(1), 91.409(a)(1) and (2) , and 91.417(a) and (b)

, provided changes are made to th e MPTOM and FOPM as required by the conditions and limitations included in this exemption. These chang es include : requirements to develop and document maintenance, overhaul, replacement, and inspection requirements in the absence of manufacturer’s requirements; procedures to document and maintain maintenance records with regard to the petitioner’s UAS; and UAS15
technician qualification criteria. They also require the petitioner’s FOPM to include preflight inspection procedures that account for any discrepancies not already covered in the manual. The FAA finds these additional requirements are necessary to en sure the petitioner’s proposed UAS operations do not adversely affect safety in the NAS and of people and property on the ground. Therefore, t he FAA finds that exemption from 14 CFR § § 91.405(a), 91.407(a)(1), 9 1 .409(a) (1) and (2), and 91.417 (a) and (b) is warranted subject to the conditions and limitatio ns below.

Pilot In Command of the UAS Regarding the petitioner’s requested relief from 14 CFR § 61.113 (a) and (b) Private pilot privileges and limitations

, c omments were received that voiced concerns about pilot certification

. One such comment came from ALPA

, which states that one of the “areas that must be addressed to ensure safe operations” is Astraeus ’ proposal to use a private pilot with a third class medical as its UAS PIC . ALPA believes that the UAS p ilot should possess a commercial pilot certificate with appropriate category and class rating for the type of aircraft being flown and the corresponding second class medical certificate, as well as specific and adequate training on the UAS make and mo del i ntended to be used. S imilar concerns were also raised by other associations such as USHPA and NAAA. Given these grounds, the FAA must determine the appropriate level of pilot certification for Astraeus’ proposed operation. Title 14 CFR part 61 requires tha t operations conducted for compensation or hire necessitate a commercial pilot certificate and at least a sec ond class medical certificate. In considering the petitioner ’s requested relief from 14 CFR § 61.113(a) and (b)

, the FAA must consider the followin g factors as they relate specifically to Astraeus ’ proposed oper a tions: Separation from manned aircraft operations : Astraeus proposes operations in a “sterile environment” of closed

- set motion

- picture filming. In this controlled environment, t heir operati ons will remain within visual line of site (VLOS) and below 400 feet AGL

. Additionall y, the FAA has added further conditions and limitations that will require a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization to address a irspace requirements and notific ation requiring Astraeus to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. Astraeus will al so be required to avoid and yield right

- of

- way to all manne d operations.

The current aeronautical knowledge requirements for a private pilot compared to a commercial pilot : The FAA analyzed the areas of knowledge specified in 14 CFR part 61 f or that of a commercial pilot versus a private pilot. The results show t hat the required areas of knowledge for a commercial v ersus private pilot cover the same fundamental princip les, as shown in the following table.16

Commercial Knowledge Private Knowledge **Airplane Single Engine Land (ASEL) used for comparison** § 61.125 Aeronautical knowledge. (a) General. A person who applies for a commercial pilot certificate must receive and log ground training... § 61.105 Aeronautical knowledge. (a) General. A person who is applying for a private pilot certificate must receive and lo g ground training... (b) Aeronautical knowledge areas. (b) Aeronautical knowledge areas. (1) Applicable Federal Aviation Regulations of this chapter that relate to commercial pilot privileges, limitations, and flight operations; (1) Applicable Federal Avia tion Regulations of this chapter that relate to private pilot privileges, limitations, and flight operations; (2) Accident reporting requirements of the National Transportation Safety Board; (2) Accident reporting requirements of the National Transportat ion Safety Board; (3) Basic aerodynamics and the principles of flight; (10) Principles of aerodynamics, powerplants, and aircraft systems; (4) Meteorology to include recognition of critical weather situations, windshear recognition and avoidance, and t he use of aeronautical weather reports and forecasts; (6) Recognition of critical weather situations from the ground and in flight, windshear avoidance, and the procurement and use of aeronautical weather reports and forecasts; (5) Safe and efficient op eration of aircraft; (7) Safe and efficient operation of aircraft, including collision avoidance, and recognition and avoidance of wake turbulence; (6) Weight and balance computations; (9) Weight and balance computations; (7) Use of performance charts; (8) Effects of density altitude on takeoff and climb performance; (8) Significance and effects of exceeding aircraft performance limitations; **Related to other areas within the private requirements but not referenced specifically** (9) Use of aeronau tical charts and a magnetic compass for pilotage and dead reckoning; (4) Use of aeronautical charts for VFR navigation using pilotage, dead reckoning, and navigation systems; (10) Use of air navigation facilities; (4) Use of aeronautical charts for VFR navigation using pilotage, dead reckoning , and navigation systems ; (5) Radio communication procedures; (11) Aeronautical decision making and judgment; (12) Aeronautical decision making and judgment; and (12) Principles and functions of aircraft systems; (10) Principles of aerodynamics, powerplants, and aircraft systems; (13) Maneuvers, procedures, and emergency operations appropriate to the aircraft; (7) Safe and efficient operation of aircraft, including collision avoidance, and recognition and avoid ance of wake turbulence; (11) Stall awareness, spin entry, spins, and spin recovery techniques for the airplane and glider category ratings; (14) Night and high

- altitude operations;  Although not mentioned in § 61.105, 3 hours of night flight trainin g is required for the private per § 61.107 and § 61.109. For this comparison, high

altitude operations are considered not applicable.**  (15) Procedures for operating within the National Airspace System; and (3) Use of the applicable portions of the “Aer onautical Information Manual” and FAA advisory circulars; (13) Preflight action that includes

— (i) How to obtain information on runway lengths at airports of intended17

use, data on takeoff and landing distances, weather reports and forecasts, and fuel requ irements; and (ii) How to plan for alternatives if the planned flight cannot be completed or delays are encountered. (16) Procedures for flight and ground training for lighter

- than

- air ratings.** **For this comparison (ASEL), these operations are conside red not applicable.** § 61.127 Flight proficiency. (a) General. A person who applies for a commercial pilot certificate must receive and log ground and flight training § 61.107 Flight proficiency. (a) General. A person who applies for a private pilot

ce rtificate must receive and log ground and flight training (b) Areas of operation. (1) For an airplane category rating with a single

- engine class rating: (b) Areas of operation. (1) For an airplane category rating with a single

- engine class rating: (i) Pr eflight preparation; (i) Preflight preparation; (ii) Preflight procedures; (ii) Preflight procedures; (iii) Airport and seaplane base operations; (iii) Airport and seaplane base operations; (iv) Takeoffs, landings, and go

- arounds; (iv) Takeoffs, landings, and go

- arounds; (v) Performance maneuvers; (v) Performance maneuvers; (vi) Ground reference maneuvers; (vi) Ground reference maneuvers; (vii) Navigation; (vii) Navigation; (viii) Slow flight and stalls; (viii) Slow flight and stalls; (ix) Emergency operations; (x) Emergency operations; (x) High

- altitude operations; and **For this comparison, high

- altitude operations are considered not applicable.** (xi) Postflight procedures. (xii) Postflight procedures. **Not referenced specifi cally** (ix) Basic instrument maneuvers; **Not referenced specifically** (xi) Night operations, except as provided in §61.110 of this part; and

The specific UAS airmanship skills required for Astraeus’ PIC(s) : Some of the requirements for Astraeus’ PI C ( s ) are provided in their proprietary documents. However, as with other exemptions that contain specific pilot qualifications, e.g. Exemption Nos

. 7830, 6802K, and 6540N, those pilot requirements become conditions and limitations within the grant of exemp tion. An abbreviated summary of those PIC requirements include the following:

a. The PIC must possess a Private Pilot’s Certificate and a valid third

- class medical certificate;

b. The PIC must have accumulated and logged a minimum of 200 flight cycles and 25 hou rs of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type (single blade or multirotor).

c. The PIC must have accumulated and logged a minimum of five hours as UAS pilot with the make and model of UAS to be utilized for operations under the exemption and three take

- offs and landings in the preceding 90 days.

d. The PIC must have successfully completed the qualification process as specified in the MPTOM and FOPM, to include a knowledge and skill test.

T he FAA’ s a nalysis regarding PIC requirements : The parallel foundation of aeronautical knowledge required for private and commercial pilots is shown in the above table. Private18
pilot a irmanship skills are furthered through manned flights in the NAS. Commercially

ce rtificated pilots build additional experience through these manned flights as well . The additional experience and airmanship skills obtained by commercially certificated airmen contribute to their ability to overcome adverse situations that could be encoun tered in flights conducted for compensation or hire . However, the experience obtained beyond a private pilot certificate in pursuit of a commercial pilot certificate in manned flight does not necessarily aid a pilot in the operational environm ent proposed by the petitioner; the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS

- specific flight cycles, flight time, and specific make and model experience , culminatin g in verification through testing

. The FAA shares ALPA’s concerns regarding appropriate training on the UAS being utilized. The FAA has reviewed the petitioner’s knowledge and experience criteria for its PICs. The FAA finds that the combination of aeronaut ical knowledge, UAS airmanship skills, and verification through testing is a sufficient method for Astraeus to evaluate a pilot’s qualifications, given that operations will be conducted within the limitations outlined in this exemption.

T he knowledge and airmanship test qualifications have been developed by Astraeus for the UAS operations proposed in their petition for exemption

. There are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company desi gnated examiners. The petitioner will conduct these tests in accordance with its FOPM and the conditions and limitations noted below. Given the constraints of the proposed operations, the FAA believes this would not adversely affect the safety of the NAS. The petitioner plans to operate in a unique and limited environment. Given the 1) separation of the se closed

- set filming operations from other manned operations

, 2) t he parallel nature of private pilot aeronautical knowledge requirements to those of commer cial requirements , and 3) the UAS airmanship skills of Astraeus’ PICs, the FAA finds that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Astraeus’ specific propose d operations. Upon consideration of the overall safety case presented by the petitioner and the concerns of the commenters, the FAA finds that granting the requested relief from 14 CFR § 61.113 (a) and (b) , provided the

c onditions and l imitations outlined b elow, would not adversely affect the safety of the NAS. Another consideration supporting the certificate requirement is that p ilots holding a private pilot certificate are subject to security screening by the Department of Homeland Security

. This requirem ent should ameliorate security concerns over UAS operations under this exemption. Operating parameters of the UAS

Astraeu s has stated that it plan s to comply with the waiver process as described in FAA Order 8900.1, V olume 3 , C hapter 8 , S ection 1 (V3, C8

, S1) Issue a Certificate of Waiver for Motion Picture and Television Filming

. The FAA agrees with this philosophy ; however, the current section of Order 8900.1 has specific processes that preclude a jurisdictional FAA FSDO from issuing the required C ertifi cate of Waiver

, because the section did not originally provide for19

UA operations. One example of this is the minimum pilot qualifications

– t he pertinent section of Order 8900.1 provides n o way to reli e ve Astraeus from the pilot requirements. Also, the sam ple form 7711

- 1 used for issuing the Certificate of Wai ver specifically states

“ this section not used for Unmanned Air Vehicle authorizations.” Therefore, the FAA will exempt Astraeus from the applicable regulations normally waived during that process . The FAA will then in clude the required notification s and coordination with jurisdictional FSDOs through the conditions and li mitations listed below. M otion picture and television filming waivers similar to Astraeu s’ operation are normally issued from one juri sdictional FSDO and can be used in locations covered by other geographically responsible FSDOs through notification . Those local FSDOs then have the ability to review the proposed plan of activities and associated o perations manual (s) and levy any addition al local special provisions

. Since Astraeu s’ operation deals specifically with UAS, this exempt ion will take the place of the Certificate of W aiver normally issued by a jurisdictional FSDO under 8900.1 V3, C8, S1

. Every FSDO with jurisdiction over the area that Astr aeu s plans to op erate within must still be notified

, just as with manned fi lming operations

, and those FSDOs will have the ability to coordinate further conditions and limitations with the UAS Integration Office to address any local concerns

, as stated below in the conditions and limitations section of this exemption. The petitioner must also obtain a Certificate of Waiver or Authorization (COA) from the FAA’s Air Traffic Organization (ATO) prior to conducting any operations. This is an existing
p rocess that not only makes local Air Traffic Control ( ATC ) facilities aware of UAS operations

, but also provides ATO the ability to consider airspace issues that are unique to UAS operations. The COA will require the operator to request a Notice to Airman (NOTAM)

, which is the mechanism for alerting other users of the NAS to the UAS activities being conducted. Therefore, the FAA believes that adherence to this process is the safest and most expeditious way to permit Astraeus to conduct their proposed UAS op erations. The conditions and limitations below prescribe the requireme nt for Astraeus to obtain an ATO

- issued COA. Regarding the petitioner’s requested relief from 14 CFR § 91.7 (a) Civil Aircraft Airworthiness

, Astraeus ’ request is based on the fact that n o airworthiness certificate will be issued for the UAS . As previously noted, the petitioner’s UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate will not be is sued, exemption from § 91.7(a) is not necessary

. I n accordance with the pertinent part of 14 CFR § 91.7(b), the PIC of the UAS is responsible for determining whether the aircraft is in condition for safe flight. The petitioner’s manuals for maintenance and operations include s afety check lists to be used prior to each flight. Regarding the petitioner’s requested relief from 14 CFR § 91.9 (b)(2) Civil aircraft flight manual, marking, and placard requirements and § 91.203 (a) and (b) Civil aircraft: Certificatio ns required

, t he original intent of these regulations was to display an aircraft’s airworthiness, certification, and registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandum subject “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station

, ”20
dated August 8, 2014, t he request ed relief from 14 CFR § § 91.9(b)(2) and 91.203(a) and (b) is

no t necessary

. Regarding the petitioner’s requested relief fr om 14 CFR § 91.103 Preflight action

, although there will be no approved Airplane or Rotorcraft Flight Manual as specified in paragraph (b)(1)

, the FAA believes that the petitioner can comply with the other applicable requirements in 14 CFR § 91.103(b)(2). T he procedures outlined in the petitioner’s MPTOM and FOPM address the FAA’s concerns regarding compliance with § 91.103(b). The petitioner has also stated its intent to comply with § 91.103 (a): “The PIC will take all actions including reviewing weather, f light battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. ” The FAA has imposed stricter requirements with regard to visibility and distance from clouds; this is to both keep the UA from departing V LOS and to preclude the UA from operating so close to a cloud as to create a hazard to other aircraft operating in the NAS. The FAA also notes the risks associated with sun glare; the FAA believes that the PIC’s and VO’s ability to still see other air traf fic, combined with the PIC’s ability to initiate a return

- to

- home sequence, are sufficient mitigations in this respect. The PIC will also account for all relevant site

- specific conditions in their preflight procedures. Therefore, the FAA finds that exempti on from 14 CFR § 91.103 is not necessary. Regarding the petitioner’s requested relief from 14 CFR § 91.109 Flight instruction; Simulated instrument flight and certain flight tests, the petitioner did not describe training scenarios in which a dual set of c ontrols would be utilized or required , i.e. dual flight instruction, provided by a flight instructor or other company

- designated individual, that would require that individual to have fully functioning dual controls

. Rather, Astraeus evaluates the qualific ation of its PICs based on their experience with the UAS to be operated and verifies through testing, in lieu of formalized training. As such, the FAA finds that the petitioner can conduct its operations without the requested relief from 14 CFR § 91.109

. R egarding the petitioner’s requested relief from 14 CFR § 91.119 Minimum safe altitudes, the petitioner failed to specify the pertinent part of 14 CFR § 91.119 from which they require relief. Relief from 14 CFR § 91.119(a) , which requires operating at an a ltitude that allows a safe emergency landing if a power unit fails, is unprecedented and unwarranted. Relief from § 14 CFR 91.119(b) , operation over congested areas, is not applicable

, because the petitioner states that operations will only be conducted wi thin the sterile area described in the MPTOM. Although the petitioner specifically mentioned relief from 14 CFR § 91.119(d), the FAA finds that relief is only needed from 14 CFR § 91.119(c), which is consistent with the relief typically provided to manned operations in FAA Order 8900.1 V3, C8 , S1 Issue a Certificate of Waiver for Motion Picture and Television Filming. This Order allows for relief from § 91.119(c) with respect to those participating persons, vehicles, and structures directly involved in the per formance of the actual filming. In accordance with the petitioner’s stated intention to adhere to O rder 8900.1 V3, C8, S1, persons other than participating persons 1 are not allowed

1 Per Order 8900.1 V3, C8, S1, participating persons are all persons associated with the filming production, and they must be briefed on the potential risk of the p roposed flight operation(s) and must acknowledge and accept those risks. Nonparticipating persons are the public, spectators, media, etc., not associated with the filming production.21

within 500 feet of the operating area. This provision may be reduced to no less than 200 feet if an equivalent level of safety can be achieved and the Administrator has approved it. For example, an equivalent level of saf ety may be determined through evaluation by an aviation safety inspector of the filming production area to note terrain features, obstructions, buildings,
etc . Such barriers may protect non participating persons (observers, the public, news media, etc.) from debris in the event of an accident.

The FAA notes the petitioner’s additional guidelines in its MPTOM to protect its participating production personnel , and finds that relief from 14 CFR § 91.119(c) is warranted, provided adherence to the procedures outlined in the petitioner’s MPTOM and FOPM , and the FAA’s additional conditions and limitations outlined belo w. However, all non participating personnel will be required to be at least 500 feet from flight operations , with possible relief to allow reductions to 200 feet, as specified above. Regarding the petitioner’s requested relief from 14 CFR § 91.121 Altimete r Settings

, the FAA believes that an altitude reading is a critical safety component of the petitioner’s proposed operation. Although the petitioner will not have a typical barometric altimeter onboard the aircraft, the FAA finds the petitioner’s intention to operate the UA within VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to provide altitude information to the UAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- scre en display , to be a sufficient method for ensuring the UAS operations do not adversely affect safety

. The altitude information will be gene rated by equipment installed on board the aircraft, as specified using GPS triangulation, or digitally encoded baromet ric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC

. The FAA has determined that good cause exists for granting the requested re lief to 14 CFR § 91.121. Regarding the petitioner’s requested relief from 14 CFR § 91.15 1 (a) Fuel requirements for flight in VFR conditions, relief has been granted for manned aircraft to operate at less than the minimums prescribed in 14 CFR § 91.151(a), including Exempt ion Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (V FR) conditions. The petitioner states that its UAS operations will be cond ucted in a controlled c losed

- set filming environment, with UA under 55 pounds , at speeds below 50 Knots, and within VLOS . These factors, combined with Astraeus’ stated intention to terminate flights after 30 minutes or with 25% remaining battery power (whi chever occurs first)

, provides the FAA sufficient reason to grant the relief from 14 CFR § 91.151(a) as requested in accordance with the conditions and limitations proposed by Astraeus

. With respect to the petitioner’s request to operate at night, the FAA finds that the petitioner has not provided a sufficient safety case and mitigations, p er FAA Order 8900.1 V16, C5, S3 General Operational Requirements, to avoid collision hazards at night. All previous UAS

specific grants of relief from 14 CFR § 91.151(a) have restricted flights to daytime VFR conditions only

. While t he FAA acknowledges the petitioner’s stated film set lighting techniques to mitigate the risks of nighttime operations

, the petitioner has not provided22

sufficient data and analysis regarding t he PICs’ and VOs’ ability to maintain VLOS with the UA and conduct their functions to see and avoid other potential obstacles and air traffic, relative to the lighting configuration on the film set. There is a limitation outlined below that precludes night time UAS operations. The petitioner may provide additional data and seek an amendment to its exemption to permit night operations. Additionally, in evaluating the petitioner’s proposed operating parameters with regard to VLOS and a safe operating perimete r, the FAA considered operations from a moving device or vehicle. Since the petitioner did not discuss provisions for these circumstances, the conditions and limitations below preclude operations from moving devices or vehicles.

Public Interest

The FAA f inds that a grant of exemption is in the public interest. T he e nhanced safety achieved using a UA with the specifications described by the petitioner and carrying no
passengers or crew , rather than a manned aircraft of significantly greater proportions, ca rrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. The FAA also finds that UAS provide an additional tool for the filmmaking industry, adding a greater deg ree of flexibility, which supplements the current capabilities offered by manned aircraft. The table below summarizes the FAA’s determinations regarding the relief sought by the petitioner:
Relief sought by petitioner (14 CFR) FAA determination (14 CFR)

P art 21 Not necessary
45.23(b) Not necessary
61.113(a) and (b) Granted with conditions and limitations
91.7(a) Not necessary
91.9(b)(2) Not necessary

91.103 Not necessary with conditions and limitations

91.109 Not necessary

91.119 Paragraph (c) grant ed with conditions and limitations

91.121 Granted with conditions and limitations

91.151(a) 91.151(a)(1), day, granted with conditions and limitations; 91.151(a)(2), night, denied
91.203(a) and (b) Not necessary
91.405(a) Granted with conditions and li mitations
91.407(a)(1) Granted with conditions and limitations23

91.409(a)(2) Granted with conditions and limitations; relief from 91.409(a)(1) also granted with conditions and limitations
91.417(a) and (b) Granted with conditions and limitations

The FA A’s Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest

. Therefore, pursuant to the authority contained in 49 U.S.C. § § 106(f), 40113

, and 44701

, delegated to me by the Administrator, Astraeus Aerial is gr anted an exemption from 14 CFR § § 61.113(a) and (b); 91 .119 (c) ; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a) (1) and (2); and 91.417(a) and (b) to the extent necessary to allow Astraeus to operate unmanned aircraft systems (UAS) for the purpose of scripted, closed

- set filming for the motion picture and television industry. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

Relative to this grant of exemption, Astraeus is hereafter referred to as th e o perator.

The Flight Operations and Procedures Manual (FOPM) and Motion Picture and Television Operations Manual (MPTOM) are hereafter collectively referred to as the o perator’ s m anual.

Failure to comply with any of the conditions and limitations of th is grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

The operator proposed the following conditions and/or limitations, which were accepted by the FAA. 2

1. The unmanned aircraft (UA) must weigh less than 55 po unds (25 Kg), including energy source(s) and equipment. Operations authorized by this grant of exemption are limited to the following aircraft described in the operator’s manual : Astraeus Aerial Cinema System V.3CS UAS aircraft variant, serial #001 onward (V.3). Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. The UA may not be flown at a ground speed exceeding 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground l evel (AGL) , as indicated by the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL.

2 Conditions and limitations outlined by the operator may have been modi fied for clarity.24

4. 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 h uman vision unaided by any device other than corrective lenses , as specified on the PIC’s FAA

- issued medical certificate

.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always main tains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

6. The operator’s manual is considered acceptable to the FAA, provided the additional requirements identified in these conditions and limitations are added or amended. T he operator’s manual and this grant of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator’s manual.

The operator may update or revise its operator’s manual. It is the operator’s responsibil ity to track such revisions and present updated and revised documents to the Administrator upon request

. The operator must also present updated and revised documents if it petitions for extension or amendment. If the operator determines that any update or revision would affect the basis for which the FAA granted this exemption, then the operator must petition for amendment to their exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operator’s manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the nec essary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be include d in the preflight inspection. All maintenance and alterations must be properly documented in the aircr aft records.

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 in accordance with the operator’ s manual. Th e PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s manual.

9. The operator must fo llow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements

. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator’ s manual. At a minimum, requirements for the following must be included in the operator’s manual:25

a. Actuators / Servos ;

b. Transmission (single rotor) ;

c. Powerplant (motors) ;

d. Propellers ;

e. Electronic speed controller ;

f. Batteries ;

g. Mec hanical dynamic components (single rotor) ;

h. Remote command and control ;

i. Ground control station (if used) ; and

j. Any other components as determined by the operator ;

10. The Pilot In Command (PIC) must possess at least a private pilot c ertificate and at least a

cu rrent third

- class medical certificate

. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft i n which the PIC is rated on his or her pilot certificate.

11. P rior to operations conducted for the purpose of motion pict ure filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot w ith a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted u nder this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience

- building flights

, all persons not essential for flight operations are considered non participants , and the PIC must operate t he UA with appropriate distance from non participants in accordance with 14 CFR § 91.119

.

12. P rior to operations conducted for the purpose of motion picture filming (or similar operations), t he PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish26
the required flight time and 90 day currency. During training, proficiency, experience

building, and take

- off and landing currency flights all persons not es sential for fligh t operations are considered non participants , and the PIC must operate the UA wit h appropriate distance from non participants in accordance with 14 CFR § 91.119

.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and VO must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion o f the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar operations), a flight demonst ration, administered by an operator

- approved and

- qualified pilot must be successfully completed and documented . This documentation must be available for review upon request by the Administrator . Because the knowledge and airmanship test qualifications hav e been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operator’ s manual.

15. The UA may not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.

16. Regarding the dist ance from participating persons, the operator’s manual has safety mitigations for authorized and consenting production personnel. At all times, those persons must be essential to the closed

- set film operations. Because these procedures are specific to part icipati ng persons, no further FSDO or a viation s afety i nspector approval is necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8

, S1 Is sue a Certificate of Waiver for Motion Picture and Television Filming.

17. Regarding distance from non participating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and
necessary for the filming production. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector ’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debri s in the event of an accident. This i s also consistent wi th the same FAA Order 8900.1, V3, C8 , S1.27

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

determined location within the security perimeter and land or be recovered in accordance with the operator’s manual

.

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual

.

20. Each UAS operation must be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first.

In addition to the conditions and limitations proposed by the operator, the FAA has determined that any operations conducted under this grant of exemption must be done pursuant to t he following c onditions and l imitations:

21. The operator must obtain an Air Traffic Organization (ATO ) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. 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 accordan ce with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component pa rts, and the total time in service of the UAS. These procedures must be added to the operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

25. The operator must develop UAS technician qualification crit eria. These criteria must be added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable compo nents, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements

.28

28. At least three days before scheduled filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the F SDO. The plan of activities must include at least the following:

a. Dates and times for all flights ;

b. Name and pho ne number of the operator f or the UAS film ing production conducted under this grant of exemption ;

c. Name and phone number of the person responsible for the on

- scene operation of the UAS ;

d. Make, model, and serial or N

- number of UAS to be used ;

e. Name and certificate number of UAS PICs involved i n the filming production event ;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; t he list of those who gave permission must be made availabl e to the inspector upon reques t ;

g. Signature of exemption

- holder or representative ; and

h. A description of the flight activity

, including maps or diagrams of any area, city, town, county, and/or s tate over which filming will be conducted and the altitudes essent ial to accomplish the oper ation

.

29. The documents required under 14 CFR § § 91.9 and 91.203 must be available to the PIC at the G round C ontrol S tation of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement offi cial upon request.

30. The UA must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

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

. All

o perations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

32. The UAS may not be operated by th e PIC from any moving device or vehicle

.

33. 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 tha n 3 statute miles from the PIC

.29

34. The UA may not operate in Class B, C, or D airsp ace without written approval from the FAA

. The UA may not operate within 5 nautical miles of the geographic center of a non

towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA

. The letter of agreement with the airport management must be made available to the Administrator upon request.

35. Any incident, accident, or flight oper ation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA ’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Saf ety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. Further flight operations may not be conducted until the incident , accident

, or transgression is reviewed by AFS

- 80 and authorization to res ume operations is provided.

Unless otherwise specified in this grant of exemption, the UAS

, the UAS PIC

, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61

, and 91.

This exemption termin ates on September 30

, 2016 , unless sooner superseded or rescinded.

Issued in Washington, DC, on September 25, 2014.

.

/s/ Michael J. Zenkovich Deputy Director, Flight Standards Service