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Writer’s Direct Contact 

+1 (858) 720.7932 

WOConnor@mofo.com 

12531 HIGH BLUFF DRIVE 

SAN DIEGO, CALIFORNIA 

92130-2040 

TELEPHONE: 858.720.5100 

FACSIMILE: 858.720.5125 

WWW.MOFO.COM 

MORRISON & FOERSTER LLP

BEIJING , BERLIN , BRUSSELS , DENVER , 

HONG KONG , LONDON , LOS ANGELES , 

NEW YORK , NORTHERN VIRGINIA , 

PALO ALTO , SACRAMENTO , SAN DIEGO , 

SAN FRANCISCO , SHANGHAI , SINGAPORE ,

TOKYO , WASHINGTON , D . C . 

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 for 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 Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Consumers Energy 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 Flight 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) 
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 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 Maintenance Manual, the DJI S1000 User Manual, the A2 Flight 

Control System User Manual, the Consumers Energy Company S1000 Pilot Operating 

Handbook, and the Consumers Energy Company S1000 Training Manual (together, the 

“Manuals”). The Manuals are submitted herewith as confidential under 14 C.F.R. § 11.35(b), 

because they contain commercial and proprietary information that Consumers Energy 

Company has not and will not share with others, is not available 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 accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned 

aircraft systems into the national airspace system.” Pursuant to Section 333 of the Reform 

Act, the FAA Administrator is to permit operation of an unmanned aircraft system where it 

does not create a hazard to users of the national airspace system (NAS) or the public or pose 

a threat to national security based on the following considerations: 

 The size, weight, speed and operational capability; 

 Operation in proximity to airports 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 exemption is in the public interest. See 49 U.S.C. §§ 

106(f), 44701-44716, et seq. A party requesting an exemption 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. 
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III. DESCRIPTION OF CONSUMERS ENERGY COMPANY AND ITS 

SERVICES 

Consumers Energy Company is a public 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 has seven power plants. Consumers Energy 

Company’s largest power plant is the Karn-Weadock coal-fired generating station located on 

Saginaw Bay near Bay City. Other Consumers Energy 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 previously owned by Consumers Energy Company (but still 

serving Consumers Energy Company’s system) are the Palisades Nuclear Generating Station, 

5 miles south of South Haven and The Midland Cogeneration Venture in Midland. 

On the Muskegon River, in Newaygo and Mecosta counties, Consumers Energy Company 

operates 3 Hydroelectric Powerplant complexes. Together, the three dams (Rogers, Hardy 

and Croton) can generate about 45,500 kilowatts. 

Consumers Energy Company has secured nearly 60,000 acres to develop wind generation 

farms in Mason and Tuscola counties. Consumer 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 environment and will bolster 

Michigan’s economy. By combining renewable energy with efficiency measures and new, 

environmentally advanced large-scale electric generation, Consumers Energy Company is 

meeting the needs of its customers, the 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’Connor

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.com
U.S. Department of Transportation 

December 31, 2014 

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IV. DESCRIPTION OF PROPOSED OPERATIONS 

Consumers Energy Company is requesting exemptions from applicable Federal Aviation 

Regulations (FARs) pursuant to Section 333 of the Reform Act to perform research and 

development using the DJI S1000 UAS. Key areas of focus for Consumers Energy 

Company’s research and development are (i) public and worker safety; (ii) safe and timely 

power restoration following storms; and (iii) new methods to effectively inspect power lines, 

electrical facilities, vegetation and rights of way. 

Consumers Energy Company is committed to improving power reliability for customers by 

more safely and quickly restoring power to customers after storm related damage to the 

electrical system. The Michigan Public Service Commission has emphasized to Consumers 

Energy Company the importance of reducing outage 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 incidents involving employees working in adverse 

weather conditions. 

Additionally, current inspections of high voltage (HVD) power lines are done one to two 

times a year by helicopter. Use of the S1000 will allow such inspections at considerable 

savings, as well as reduce safety risks because the drone will not carry 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 (LVD) lines are typically done by motor vehicle 

or on foot. Due to visibility limitations based on the design of utility poles, a certain portion 

of the pole and its facilities is never inspected. Using the S1000 to do LVD inspections will 

increase their effectiveness, decrease their safety risks, and reduce the time needed for the 

inspection cycle. 

Thus, the research and development use proposed 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 creating 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 Company and have low nearby residential 

populations. Two sites will focus on UAS research and development for power line 

monitoring; four sites will focus on UAS research and development for wind turbine 
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inspection. The satellite imagery of each site included below confirms that surrounding 

properties have few structures 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 

inspection 
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Figure 1 – R&D Site Number 1: Cary Rd Sub 

Figure 2 – R&D Site Number 2: Lake Leann Sub 
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Figure 3 – R&D Site Number 3: Clear Lake Sub 

Figure 4– R&D Site Number 3: Cross Winds WTG-46 
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Figure 5 – R&D Site Number 5: Cross Winds WTG-28 

Figure 6 – R&D Site Number 6: Lake Winds WTG-8 
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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 weighs approximately 8.8 pounds 

with a maximum takeoff weight of approximately 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 miles 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. 
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Figure 8 – DJI S1000 Specifications 
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Figure 9 – DJI S1000 

B. The DJI A2 Flight Control System 

The DJI S1000 will be used in conjunction with the A2 multi-rotor stabilization flight control 

system that provides self-leveling 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 high 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 failsafe protection will enable the S1000 to return to home 

and land automatically. The operator can also 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 stopped motor. In this condition, the S1000 is 

still under control and returns home safely, highly reducing 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 position 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 the 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 for all-round shooting of a fixed scenic spot. 
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The A2’s specifications are shown in Figure 10. 

Figure 10 – A2’s Specifications 
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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 operate 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 structure because the proposed operations represent a 

safety enhancement to the protocols currently used by Consumers Energy Company for 

power line and wind turbine monitoring. 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 aircraft is a battery operated octocopter with a 

maximum flight time of 25 minutes. The vehicle 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 incline. 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 clearance 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, when the blades are positioned vertically. 

Figure 11, below, shows the varying sizes of exemplar wind turbines. 

Figure 11: Wind Turbine Size 
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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 unmanned aircraft 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 

S1000. 

Consumers Energy Company’s operations will be in remote areas at least 5 miles from any 

airport and away from population centers, as demonstrated 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 requirements 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 transponders or sense and avoid technology, is 

mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting 

daytime operations only, and requiring that the aircraft be operated within visual line of sight 

and yield right of way to all other manned operations. 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, attached hereto as Attachment 6. 

The petitioner’s aircraft has the capability to operate safely after experiencing certain inflight failures, as specified above in the description of the A2 Flight Control System. The 

aircraft is also able to respond 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 environment within which they will operate, the 

procedures listed below, and pilot certification 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 national security.” Reform Act Section 333(b)(1). 

1. The aircraft is approximately 8.8 pounds. 

2. The aircraft will be identified by serial number, registered with the FAA, and 

have identification (N-Number) markings as large as practicable. 

3. Flights will be operated within visual line of sight of the pilot in command 

(PIC). 
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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 distance of at least 50 feet from any 

persons or property not associated with 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 pilot certificate, a third class medical 

certificate, and a designee from Consumers Energy Company will have 

completed a Factory Certified Basic Operator Course for the S1000. 

13. Prior to the flight, a Mission 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 right 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 feet 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 jurisdictions prior to flight. 
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19. Prior to commencing operations, Consumers Energy Company will obtain a 

Certificate of Waiver or Authorization (COA) from the FAA. 

20. If the aircraft loses communications, it will 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 within the operational 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 communications, 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 requesting to operate in the R&D Sites. 

V. SPECIFIC FAR EXEMPTIONS REQUESTED 

Consumers Energy Company seeks an exemption from several interrelated 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 sections 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 application. These criteria are met, and therefore no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014-
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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 the Reform Act, an exemption is requested. 

Equivalent Level of Safety: The S1000 is safe when taking 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 visual 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, conventional rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions proposed here. 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 requirements for airworthiness certification of 

normal category rotorcraft. To the extent the 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-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, 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. 

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. 
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14 C.F.R. § 91.9(c) states: 

No person may operate a U.S.-registered civil aircraft 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 the aircraft “have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart 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 Pilot 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 the skill and competency of any 

PIC matches the airspace in which the PIC will be operating, as well as requiring 

certifications if the pilot is carrying 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 Exemption in FAA Docket No. FAA-2014-0352, the 

FAA determined that the unique characteristics of UAS operation outside of controlled 

airspace did not warrant the additional cost and restrictions attendant with requiring the PIC 

to have a commercial pilot certificate and a class II medical certificate. The FAA has also 

determined that the required knowledge for a commercial pilot covers the same fundamental 

principles as a private pilot. 

The PIC will possess at least a private pilot certificate, a third class medical certificate, and 

will have completed a DJI Factory-Certified Basic 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 information 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 operations proposed by the petitioner to be the 

airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make 

and model experience, culminating in verification 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 the knowledge and experience in S1000 operations 

described above. 
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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 coordinated 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 operated. 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 Rotorcraft 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 current airworthiness certificate... 
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(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section 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. 

Consumers Energy Company does not request an exemption from this section but instead 

notifies the FAA that, in accordance with FAA Office of Chief Counsel’s Opinion dated 

August 8, 2014, the UAS flight manual, registration certificate and other 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, landing and takeoff distances and aircraft performance data 

before initiation of flight. Under 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 weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency 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 exemption from 14 C.F.R. § 91.109(a), which 

provides that “[n]o 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.” 

UASs and remotely piloted aircraft, by their design, do not have functional dual controls. 

Instead, flight control is accomplished through the use of the A2 Flight Control 

System/Ground Control Station (GCS) that communicates 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 no 
U.S. Department of Transportation 

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safety hazard. Given the size and speed of the S1000, an equivalent level of safe training can 

still be performed without dual controls because no pilot or passengers are aboard the 

aircraft, and all persons will be a safe distance away in the event that the aircraft experiences 

any difficulties during flight instruction. In addition, Consumers Energy Company will 

conduct flight training at a remote facility away from population centers. These training 

flights will be conducted on the R&D Sites and will otherwise comply with the provisions in 

the Manuals. Accordingly, Consumer Energy’s proposed method of operation provides 

superior levels of safety. 

I. 14 C.F.R. § 91.119(c): Minimum Safe 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 feet to any person, vessel, vehicle, or structure. The Manuals 

provide for operations away from congested populations 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 those imposed by Consumers Energy Company. See Grant of 

Exemption No. 11062, p. 20-21. 

Equivalent Level of Safety: Compared to flight operations with 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 Sites. 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 operating 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 with 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 aircraft 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 level by reference to an altimeter that is set 

to the elevation of the departure airport. The S1000 uses both barometric pressure sensors 

and GPS to determine altitude but does not have the ability to set in a current altimeter 
U.S. Department of Transportation 

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setting. An exemption is required to the extent 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 equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-ofsight in addition to GPS based altitude information 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 otherwise complies with the limitations in the 

Grant of Exemption No. 11062. 

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

Conditions

Consumers Energy Company requests an exemption from 14 C.F.R. § 91.151(a)’s fuel 

requirements for flight in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing 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 that for at least 45 minutes. 

Here, the technological limitations on S1000 battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30 minute reserve. The aircraft is 

battery powered with a maximum flight time 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 than 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 equivalent level of safety is provided 

if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and 

terminated with at least 25% reserve battery power still available. See Grant of Exemption 

No. 11062, p. 21-22. The Manuals providing an equivalent level of safety by safely landing 

with no less than the greater of (a) 20% battery life remaining or (b) five minutes of flight 

time remaining and otherwise complying with the flight restrictions above. 
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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 maintenance and inspection standards 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 inspected 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 certificate, which the S1000 will not have. 

Equivalent Level of Safety: An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the Manuals. This 

includes maintenance, overhaul, replacement, and inspection requirements for the aircraft 

and procedures to document and maintain maintenance records for the aircraft. This also 

includes preflight inspection 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 aircraft’s components. The Manuals also set 

requirements for maintenance log books and record keeping as well as routine and post-flight 

maintenance. The Manuals set requirements for both annual maintenance and preventative 

maintenance. 

VI. PUBLIC INTEREST 

Granting Consumer Energy’s petition for exemption furthers the public interest. National 

policy set by Congress favors early 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 required under Section 332 of the Reform Act. 

Moreover, use of unmanned aircraft operations will improve power reliability for Consumer 

Energy’s customers by reducing the time necessary to restore power after storm-related 

damage to the electrical system. The use of the S1000 will also decrease safety-related 

incidents involving employees working in adverse weather conditions. 

Additionally, current inspections of high voltage (HVD) power lines are done one to two 

times a year by helicopter. Use of the S1000 will allow such inspections at considerable 

savings, as well as reduce safety risks because the drone will not carry a flammable fuel 

source. Drones will also allow better visual inspection of facilities installed on poles, as 
U.S. Department of Transportation 

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helicopter inspection usually involves less than 5 seconds of visual inspection of a utility 

pole. 

Further, inspections of lower voltage power (LVD) lines are typically done by motor vehicle 

or on foot. Due to visibility limitations based on the design of utility poles, a certain portion 

of the pole and its facilities is never inspected. Using the S1000 to do LVD inspections will 

increase their effectiveness, decrease their safety risks, and reduce the time needed for the 

inspection cycle. 

Thus, the research and development use proposed 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 creating new methods enabling Consumer Energy’s 

customers to save energy every day. 

In addition, unmanned aircraft operations 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 edge 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 significant risk to the individual climbing the 

turbine or operating the manned aircraft in the vicinity of the 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 expected as wind installations spread.1

 Use of an 

unmanned aircraft, like Consumers Energy Company’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 helicopters and small airplanes. The public has 

an interest in reducing the hazards and emissions associated with alternate use of helicopters 

and small airplanes to conduct similar inspection operations. 

Additionally, Consumer Energy’s intended uses for 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.com/Energy/2011/08/14/More-accidents-feared-as-wind-solar-powerinstallations-spread.html. 
U.S. Department of Transportation 

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Energy Company may ultimately determine that it will be able to inspect and survey wind 

turbine blades and towers supporting the renewable 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 injuries, 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 determined 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 access 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 Handbook 
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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 provided 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 considerations - provides more than adequate justification for 

the grant of the requested exemptions to permit Consumers Energy Company to operate the 

S1000 on the R&D Sites. 

Granting the requested exemption will benefit the 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 costs 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 1 

 
Revision 1 December 16, 2014 

DJI S1000

Operations, Inspection, and		

Maintenance Manual

	 	
Revision 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	its	

electrical	generating	infrastructure.	

2. CE	will	designate	a	Director	of	Flight	Operations.	

3. The	Director	of	Flight	Operations	will	ensure	this	Operations,	

Inspection,	and	Maintenance	Manual	is	revised	to	contain	all	current	

information.	

4. The	Director	of	Flight	Operations	will	ensure	that	this	Operations,	

Inspection,	and	Maintenance	Manual	is	distributed	to	all	personnel	

involved	with	UAS	operations	as	well	as	any	revisions	to	this	manual.	

5. The	Director	of	Flight	Operations	will	ensure	all	pilots	are	trained	

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	conducted	using	a	DJI	S1000	with	the	A2	

Flight	Control	System,	manufactured	by	DJI	Innovations	(the	“S1000”).	

2. The	aircraft	will	be	identified	by	serial	number,	registered	with	the	

FAA,	and	have	identification	(N‐Number)	markings	as	large	as	

practicable.	

3. The	aircraft	weighs	approximately	8.8	pounds	with	a	maximum	

takeoff	weight	of	approximately	24	pounds	with	a	payload.	

4. A	complete	description	of	the	S1000	is	contained	in	the	DJI	S1000	

User	Manual	and	the	A2	Flight	Control	System	User	Manual.	

5. Operation	of	the	S1000	is	described	in	Consumers	Energy	S1000	Pilot	

Operating	Handbook.	
Revision 1 December 16, 2014 

C. Aircraft Registration, Log Book and CE Manuals

1. Each	aircraft	will	have	an	Aircraft	Log	Book	to	record	inspections,	

maintenance,	and	flight	operations.	

2. All	required	paperwork	including	Registration,	Log	Book,	and	CE

Manuals	will	be	located	at	the	Ground	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	pilot	

in	command	(PIC)	and	a	visual	observer.	

2. The	PIC	will	possess	at	least	a	private	pilot	certificate,	a	third	class	

medical	certificate,	and	will	be	trained	according	to	Consumers

Energy	Training	Manual.	

E. Training Requirements

1. Training	requirements	are	described	more	fully	Consumers	Energy

Training	Manual.	

F. Flight Areas

1. The	aircraft	will	only	operate	within	the	operating	areas	defined	as	

the	R&D	Sites	in	Consumers	Energy’s	Petition	for	Exemption	to	the	

FAA.	

2. Flight	operations	will	not	be	conducted	within	5	miles	of	an	airport.	

3. Flight	operations	will	not	be	conducted	over	congested	populated	

areas.	

G. Weather Conditions

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

2. The	aircraft	will	not	be	operated	if	wind	gusts	are	greater	than	30	

mph.	
Revision 1 December 16, 2014 

H. Flight Operation Parameters

1. Flights	will	be	operated	within	visual	line	of	sight	of	the	pilot	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	minutes.	

4. 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.	

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	associated	with	the	operation	who	have	

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	Plan	will	be	created	setting	forth	the	

limitations	for	the	flight	as	well	as	contact	information	for	the	PIC.	

9. The	flight	operations	will	yield	the	right	of	way	to	other	manned	

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	permits	will	be	obtained	from	territory,	

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	will	be	

obtained	prior	to	flight.	

15. The	flight	will	be	aborted	in	case	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	System	

User	Manual,	and	the	Consumer	Energy	Pilot	Operating	Handbook.	

J. Lost GPS Procedures

1. Flight	recovery	following	lost	GPS	signal	will	be	performed	according	

to	the	DJI	S1000	User	Manual,	A2	Flight	Control	System	User	Manual,	

and	the	Consumer	Energy	Pilot	Operating	Handbook.	

II. INSPECTION AND FUNCTIONAL TEST FLIGHT

A. Preflight Inspection Procedures

1. Before	each	flight,	either	the	PIC	or	the	visual	observer	will	conduct	a	

preflight	inspection	of	the	aircraft.	

2. The	aircraft	and	Ground	Control	Station	will	be	inspected	for	signs	of	

damage.		Screws	will	be	checked	and	tightened	if	necessary.	

3. The	Ground	Control	Station	will	be	inspected	ensure	there	are	no	

broken	or	loose	antenna	connections,	cracked	casing,	or	broken	or	

loose	joysticks.	

4. Aircraft	propellers	will	be	inspected	to	ensure	they	are	not	damaged,	

loosed,	or	misaligned.	

5. Motors	will	be	inspected	to	ensure	the	motors	are	not	loose	and	the	

supports	are	not	cracked.	

6. Aircraft	batteries	will	be	checked	that	they	are	fully	charged.

7. Ground	Control	Station	batteries	will	be	checked	that	they	fully	

charged.	

8. All	batteries	will	be	charged	and	maintained	according	to	the	S1000	

User	Manual.	

9. A	preflight	maintenance	inspection	will	be	recorded	in	the	aircraft	log	

book.	
Revision 1 December 16, 2014 

B. Functional Test Flight

1. After	a	flight	critical	component,	such	as	a	propeller	or	motor,	has	

undergone	maintenance	or	been	repaired	or	replaced,	the	aircraft	

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	the	aircraft	log	book	of	the	functional	

test	flight.	

C. Postflight Inspection Procedures

1. After	each	flight,	either	the	PIC	or	the	visual	observer	will	conduct	a	

postflight	inspection	of	the	aircraft.	

2. The	aircraft	and	Ground	Control	Station	will	be	inspected	for	signs	of	

damage.		Screws	will	be	checked	and	tightened	if	necessary.	

3. Aircraft	propellers	will	be	inspected	to	ensure	they	are	not	damaged,	

loosed,	or	misaligned.	

4. Motors	will	be	inspected	to	ensure	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	DJI	

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,	maintenance,	

and	flight	operations.	

B. Maintenance Procedures.

1. Each	aircraft	will	be	maintained	using	the	maintenance	procedures	

contained	in	the	DJI	S1000	User	Manual,	the	A2	Flight	Control	System	

User	Manual,	and	the	Consumer	Energy	Pilot	Operating	Handbook.	

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

3. Batteries	will	be	charged	according	to	the	procedures	in	the	DJI	S1000	

User	Manual,	the	A2	Flight	Control	System	User	Manual,	and	the	

Consumer	Energy	Pilot	Operating	Handbook.	

C. Functional Test Flight

1. After	a	flight	critical	component,	such	as	a	propeller	or	motor,	has	

undergone	maintenance	or	been	repaired	or	replaced,	the	aircraft	

must	undergo	a	functional	test	flight.	

2. Every	500	hours	of	flight	time,	the	PIC	will	conduct	a	functional	test	

flight	regardless	of	maintenance	activities.	

3. The	PIC	will	make	an	entry	in	the	aircraft	log	book	of	the	functional	

test	flight.	
Attachment 2 

Submitted confidentially under 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 under 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 S1000 

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	battery	 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	weight	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	not	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%	of	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	avoiding	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	plan)	

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	course	lock	–	do	not	turn	on		

o On	Copter	TX	‐	Set	switches	‐	Throttle	Down,	Return	to	Home	switch	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	‐	HDMI	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	with	correct	heading	for	course	lock.	

o Do	not	touch	the	Copter	until	30	seconds	after	full	GPS	Lock.	Initial	3	red	blinks	is	

normal	meaning	no	GPS	lock.	Wait	until	no	flashes.	Continue	with	checklist.	

o Check	Copter	Voltage	from	GCS	

o Engage	Attitude	Mode	–	Must	Achieve	Double	Amber	Flash	

o Engage	GPS	Mode	–	Must	Achieve	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	achieve	single	amber	flash	in	

Attitude	Mode	and	single	purple	flash	in	GPS	mode	

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

o Freestyle	switch	On	(FPV	Off)	

o Verify	camera	operation	(If	problems,	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	gauge	on	computer/GCS/video	monitor/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	immediately	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	forward/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	green	flash.	Verify	wireless	

link,	GPS	hold,	camera	operation,	gauges,	etc.	are	working	properly.	

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

o Verify	copter	stability.	If	unstable,	land	and	reset	gains,	recalibrate,	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	monitor	the	informational	LED	and	be	ready	to	take	over	

in	manual	mode	when	necessary.	

o Manual	pilot	to	request	copter	flight	battery	voltage	readout	from	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	of	IMU	and	Compass	is	incorrect	

o Excessive	rocking/instability	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	with	pauses)	–	GPS	loss	(3	is	more	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	Balance/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	availability,	many	COTS	

(commercial	off	the	shelf)	components	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	reference	in	this	document,	with	key	factors	being	emphasized.	

As	with	all	high	technology	products	utilizing	constantly	evolving	software,	it	is	important	to	

periodically	check	for	online	upgrades	to	the	COTS	components,	including	hardware,	firmware	

and	software.	

WARNING:	Great	care	must	be	taken	with	the	batteries.	Much	of	this	manual	and	supplemental	

information	is	devoted	to	the	use	and	care	of	the	batteries,	especially	the	flight	batteries.	They	are	

less	volatile	than	gasoline,	though	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	Reconnaissance)	

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,	Zenmuse	gimbal,	A2	autopilot	system,	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	with	Nex	camera	and	Zenmuse	Gimbal	

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	motors	

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	Distribution	System,	LED	

Indicator	Lighting	System,	Data	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	recommended:	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,	25.2V	maximum	

o Battery	Minimum	Rated	Discharge	Rate:	20C	minimum	

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

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

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	Watts,	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	manual	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	just	before	use.	

o Fully	charged	batteries	which	are	not	to	be	used	within	24	hours	should	be	discharged	

to	20%	‐	50%	charged	state.	

o Discharging	LiPoly	batteries	in	excess	of	80%	of	their	rated	capacity	can	cause	harm	to	

the	batteries.	

o Using	more	than	one	battery	at	a	time	requires	the	proper	wiring	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	balance	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	vary	considerably	on	many	factors	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	after	use	before	charging	

o Leave	an	air	gap	between	batteries	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	flight	to	ensure	batteries	were	installed	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	if	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	the	higher	the	temperature	increase	during	use	

 At	temperatures	above	45°C,	use	of	2	or	more	batteries	is	required	to	lower	the	

load	on	any	one	battery	pack	to	keep	it	cooler.	

WEATHER LIMITS

o Light	dust	and	light	rain	require	the	use	of	a	shield	for	the	electronics	in	the	center	

section.		

o Light	dust	and	light	rain	are	acceptable	for	the	unshielded	motor	and	ESC.	

RANGE LIMITS		

o FUEL	

 Fuel	capacity	is	a	primary	limiting	factor.	

 Flying	into	the	wind	will	use	more	battery	power	to	travel	the	same	ground	

distance.	Higher	air	speeds	will	be	required	to	penetrate	the	wind	which	used	

more	battery	power.	Take	this	into	account	when	flying	a	mission.	

 Where	possible,	fly	upwind	at	the	start	of	a	mission	and	downwind	at	the	end	to	

avoid	depleting	the	battery	before	returning	to	base.	Have	alternative	landing	

sites	available	in	case	of	emergency	landing.	

o WIRELESS	LINK	

 Wireless	links	will	be	stable	in	LOS	(line	of	sight)	in	most	conditions	

 Wireless	links	are	always	susceptible	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	multiple	

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	will	be	increased	in	thrust	automatically	by	the	

flight	controller	to	overcome	the	loss	

 In	cases	where	the	airframe	is	highly	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	the	possibility	of	

damage	to	the	remaining	motors	

COMMUNICATION FAILURE

o Video	link	failure	

 5.8	Ghz	being	the	shortest	wavelength	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	antennas	are	perpendicular	to	the	AV.	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	in	operation.	When	overheated	they	may	have	

thermal	protection	which	interrupts	use	temporarily.	Use	of	a	heat	sink	or	fan	

may	be	required	especially	with	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	theoretically	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	antennas	can	cause	temporary	signal	loss	

especially	a	person.	
20		 	 	 	 	 	 	 	 	 		

 Hold	the	transmitter	up	in	the	air	and	walk	in	the	general	direction	of	the	AV	

(aerial	vehicle).	

 Ensure	that	the	antenna	is	vertical.	Do	not	point	the	antenna	at	the	AV.	

 The	failsafes	on	the	RC	link	should	be	set	so	that	the	AV	returns	to	home.	Should	

this	require	a	heading	change,	the	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	are	noticed	to	

increase	in	frequency	that	is	the	limit	of	the	range.	

 If	using	900	Mhz,	this	is	on	cell	phone	frequency.	If	a	cell	tower	is	nearby	it	can	

swamp	the	signal.	900	Mhz	may	not	be	usable	in	that	area.	Change	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	power,	either	due	to	a	

failure	or	too	long	of	a	flight,	the	warning	light	on	the	AV	will	constantly	flash	

amber.	This	is	the	first	level	of	warning.	

 The	second	warning	level	is	red	flashing	lights	

 Auto	landing	will	occur	when	battery	power	is	low.	It	may	land	in	a	tree	or	a	

lake,	so	this	is	not	desirable.	

 Landing	with	80‐90%	of	battery	depleted	is	best.	Therefore	landing	with	17,000	

mah	used	and	3,000	mah	remaining	of	a	20,000	mah	battery	is	desirable.	

Batteries	should	be	drawn	down	equally	when	in	use	if	they	are	both	charged	

equally	and	both	in	relatively	the	same	condition/age.	

 Do	not	mix	partially	charged	batteries.	Only	use	completely	charged	batteries.	

 Over	discharging	a	battery	below	19.8V	can	permanently	damage	the	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	battery	with	the	appropriate	plug	to	plug	into	the	

charge	jack	for	emergency	use.	Most	chargers	are	19V	output	which	is	roughly	

equivalent	to	a	4‐cell	battery.	3‐cell	batteries	may	work.	

COMPASS CALIBRATION ERROR

 If	the	compass	is	out	of	calibration	the	warning	light	will	flash	red.	This	is	the	

same	signal	as	low	voltage.	If	the	voltage	is	correct,	there	is	a	calibration	error.	

 Recalibrate	the	compass	following	the	instruction	manual	

FIRE

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

 Disconnect	the	battery	ASAP	unless	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	battery	fire.	Use	a	fire	extinguisher	to	put	out	fires	

surrounding	the	battery.	A	CO2	fire	extinguisher	is	better	than	the	powder	or	

chemical	type.	CO2	does	not	leave	a	residue.	Water	can	be	used	though	it	may	

cause	other	electrical	component	failures.	

FORCED LANDINGS

 If	alternate	emergency	landing	zones	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	landing	as	loud	as	necessary	to	alert	people	of	the	

incoming	AV.	
22		 	 	 	 	 	 	 	 	 		

SECTION 4		

SET UP SUGGESTIONS

ELECTRONICS BURN IN

o We	recommend	that	you	put	weights	onto	the	landing	skids	to	keep	the	copter	on	the	

ground	and	run	the	copter	at	about	70%	throttle	for	about	2	hours	to	burn	in	the	

electronics.	Most	electronic	failures	occur	in	the	first	2	hours	of	operation.	

GPS/COMPASS MAST LENGTH

o We	found	that	the	higher	the	mast,	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	video,	though	most	

professionals	use	the	Nex	7.	The	Canon	5D	is	better	than	the	Nex7	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	as	shown	in	the	checklists	above	though	feel	free	to	

modify	to	your	liking	

COPTER COMMAND AND CONTROL

o We	recommend	the	use	of	a	dual	rate	switch	for	main	copter	operation.	

 High	rate	–	used	to	initialize	the	motors.	The	flight	controller	will	not	engage	

unless	it	sees	full	down	throttle,	full	left	rudder,	full	left	cyclic	and	full	back	

cyclic.	However,	these	may	be	too	high	for	normal	flying.	On	high	rate	it	is	helpful	

to	utilize	fairly	high	exponential	to	make	the	stick	feel	soft	around	center.	Adjust	

to	your	preference.	

 Low	rate	–	used	for	typical	flying.	Set	the	end	point	adjustments	such	that	full	

stick	deflection	offers	the	maximum	speed	required	in	normal	flying.	If	

conditions	require	higher	flight	speeds,	switch	to	high	rate.	On	low	rate	it	is	also	

helpful	to	utilize	a	small	amount	of	exponential	to	make	the	stick	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	the	gimbal.	The	gimbal	may	not	engage	unless	it	

sees	full	motion.	However,	these	may	be	too	high	for	shooting	video	smoothly.	

This	is	best	for	still	photography	so	as	to	put	the	camera	on	target	quickly.	On	

high	rate	it	is	helpful	to	utilize	fairly	high	exponential	to	make	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	maximum	speed	required	for	videography.	If	

conditions	require	higher	gimbal	speeds,	switch	to	high	rate.	On	low	rate	it	is	

also	helpful	to	utilize	a	small	amount	of	exponential	to	make	the	stick	feel	soft	

around	center.	Adjust	to	your	preference.	

TIMERS

o Use	of	the	countdown	timer	is	a	good	backup	method	to	ensure	landing	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.	Then	adjust	the	timer	upwards	until	the	amount	of	

battery	used	is	about	80‐90%	of	the	total	available.	If	using	20,000	mah	

batteries,	a	total	of	17,000	mah	would	be	the	target.	Set	the	timer	such	that	you	

have	a	minute	or	so	to	land	after	the	alarm	sounds	so	that	you	have	adequate	

time	to	return	to	base.	Adjust	to	your	preference.	

BATTERIES

o Replace	the	transmitter	standard	battery	with	a	Lipoly	battery	to	extend	use	times	to	8	

hours.	Supplied	batteries	often	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	people	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	mounts	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	time	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	batteries	from	moving	

which	will	avoid	a	shift	in	the	CG	(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	should	balance	

properly.	If	not,	do	not	fly.	Rearrange	the	equipment	such	that	the	CG	is	

o IMU	pointing	forward	

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

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	forward,	the	corrections	in	ATTI	and	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	level	with	front	pointing	in	correct	direction	for	course	lock	

–	do	not	turn	on		

 Keep	in	mind	the	best	angle	for	pointing	the	landing	gear	in	the	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	manual	(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	required	to	initialize	the	copter	properly.	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	immediately	and	

disconnect	the	copter	power.	Then	put	all	the	switches	in	the	proper	position	for	

initialization	and	turn	the	power	back	on	to	the	copter.	

o Count	down	timer	should	be	set	to	20	minutes.	This	can	be	adjusted	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	indicator	lights	on	the	copter	are	not	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	required	to	initialize	the	Zenmuse	properly.	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	function	properly,	disconnect	the	copter	power.	

Then	put	all	the	switches	in	the	proper	position	for	initialization	and	turn	the	

power	back	on	to	the	copter.	

o Engage	power	to	copter	

 Plug	in	the	2	battery	packs.	Typically	the	battery	packs	use	red	T‐style	

connectors	in	a	parallel	wire	harness.	This	Y‐harness	has	a	yellow	connector.	It	is	

preferable	to	connect	the	batteries	to	the	Y‐harness	first,	then	plug	in	the	yellow	

connector.	This	reduces	(but	does	not	eliminate)	electrical	arcing.	
26		 	 	 	 	 	 	 	 	 		

 6	quick	chirps	should	be	heard	confirming	6S	LiPoly	batteries	are	recognized	by	

the	ESCs.	

 Hearing	less	than	6	chirps	indicates	fewer	cell	battery	packs	are	being	

recognized	which	is	incorrect.	Check	for	improper	or	damaged	batteries.	

o Do	not	move	or	vibrate	the	Squadcopter	until	30	seconds	after	full	GPS	Lock	

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

GPS	lock.	

 Continue	with	checklist	as	you	are	waiting	for	full	GPS	lock,	but	do	not	move	the	

copter.	

 If	the	GPS	takes	more	than	5	minutes	to	lock,	there	is	a	problem	with	the	area.	It	

is	not	receiving	the	proper	signals	from	the	satellites.	GPS	signals	are	weak,	so	

trees,	people,	buildings,	terrain,	weather,	have	an	effect.	Move	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	receivers.	The	voltages	

are	regulated	to	about	5v.	If	the	voltage	is	below	4.4v	or	above	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	is	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.	Stay	in	this	mode	until	

just	prior	to	takeoff,	after	takeoff	at	any	time,	or	do	not	use.	

o Do	not	engage	motors.	Set	throttle	to	center	position.	Must	achieve	single	purple	flash	

when	in	GPS	mode.	

 To	verify	that	the	sticks	are	all	centered	properly:	

 With	throttle	in	the	center	position,	use	the	trim	buttons	on	the	transmitter	to	

check	that	the	sticks	are	centered.	Trim	the	roll	(the	stick	located	on	the	right	

side	of	the	transmitter	when	moved	to	the	right	and	left)	to	the	right,	counting	

the	number	of	clicks	until	a	double	flash	occurs.	Then	center	the	trim.	Then	move	

the	trim	to	the	left,	counting	the	number	of	clicks	until	a	double	flash	occurs.	An	

equal	number	of	clicks	should	be	counted	each	side	of	center.	

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

 Center	the	trim	such	that	when	the	stick	is	in	the	neutral	position	that	there	are	

equal	numbers	of	clicks	in	each	direction.	This	ensures	that	when	the	sticks	are	

neutralized	that	the	flight	controller	will	recognize	this	signal	and	engage	GPS	

mode.	
27		 	 	 	 	 	 	 	 	 		

o Calibrate	GPS/Compass	before	the	first	flight	each	day	or	if	receiving	continuous	red	

blinks	or	continuous	white	blinks.	

 Flip	the	GPS	mode	switch	7	times	very	quickly	from	manual	to	GPS.	End	with	the	

switch	in	the	manual	position.	The	indicator	light	will	be	blue.	Rotate	the	copter	

about	1.5	turns	in	a	horizontal	position.	A	green	flashing	light	indicates	that	this	

is	complete.	Then	hold	the	copter	vertically	and	rotate	about	1.5	turns.	A	white	

flashing	light	indicates	that	this	is	complete.	Repeat	if	necessary	until	this	is	

completed.	

o After	calibration,	reset	the	copter	by	cycling	battery	with	copter	pointed	in	the	correct	

heading	for	course	lock.	

o Engage	Camera	

o HDMI	switch	On	

 This	will	stop	video	from	playing	on	the	back	of	the	camera	and	will	send	the	

video	signal	to	the	video	transmitter	via	the	HDMI	connection.	

o Freestyle	switch	On	(FPV	Off)	

 This	allows	the	camera	to	be	operated	freely	through	the	transmitter	

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	side	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	right,	it	will	appear	on	the	gauge	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	altitude	settings	for	the	waypoints	will	be	off	by	this	

amount.	This	could	cause	the	copter	to	fly	at	10	meters	or	30	meters	if	the	

waypoint	is	set	for	20	meters	and	the	altitude	is	off	by	10	meters	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	the	ground	to	achieve	what	it	believes	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	are	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	bottom	left	corners	to	engage	the	motors.	Within	1	

second	move	the	throttle	up	1/8	–	1/4.	The	copter	should	not	lift	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	disengage	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	ground	to	avoid	one	skid	

coming	up	before	the	other	skid,	and	the	skid	on	the	ground	getting	caught	and	flipping	

the	copter	over	sideways.	

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

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

o Verify	that	the	copter	is	holding	position	within	.5m	in	all	directions.	

o Verify	camera	operation	

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

o Verify	copter	stability.	If	unstable,	land	and	reset	gains,	recalibrate,	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	monitor	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	guidance	and	

any	GPS	hold	and	put	into	manual	mode.	
29		 	 	 	 	 	 	 	 	 		

 Red	indicator	light	battery	warning	requires	immediate	landing	

o Manual	pilot	to	request	copter	flight	battery	voltage	readout	from	AVO	periodically.	

 Reset	the	first	and	second	indicator	lights	as	required	for	your	set	up.	

 When	recharging	the	batteries,	the	goal	is	to	put	4,000	mah	into	a	5,000	mah	

battery	pack.	Adjust	the	voltage	warnings	to	your	style	of	flying.	

 Also	use	the	countdown	timer	on	the	transmitter.	This	gives	a	good	indication	of	

battery	level	because	the	current	used	is	fairly	constant	from	flight	to	flight.	

POST LANDING

o Note	flight	time	from	transmitter.	Write	this	down	in	the	log	book.	

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

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

o Check	motor	temperatures	by	touching	them	with	your	fingers.	Any	motors	which	are	

excessively	hot	should	be	further	inspected	and	possibly	replaced.	

o Check	battery	temperatures	by	touching	them	with	your	fingers.	Battery	temperatures	

should	not	be	hot	to	the	touch.	Battery	temperatures	should	be	slightly	above	ambient.	

o Inspect	all	components	especially	the	propellers	for	wear.	

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

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,	alterations,	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	much	less	efficient	than	

flying	on	a	wing,	thus	flight	times	are	low	compared	to	fixed	wing	aircraft.	

o All	the	weight	of	the	AV	is	supported	by	power	from	the	batteries.	As	the	batteries	are	

used	in	a	flight,	the	amount	of	power	available	decreases.	Therefore	the	power	reserve	

is	constantly	decreasing	as	the	battery	is	being	used.	Thus	loading	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	efficiency.	The	rotors	act	similar	to	

fixed	wings	at	higher	speeds.	This	increase	in	efficiency	may	be	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	communication	for	LOS.	

o In	general:	

 LOS	is	required	

 The	higher	the	GCS	antennas,	the	better	the	range	

 Any	freq.	at	may	have	severe	degradation	due	to	location	to	other	admitters	such	

as	cell	towers	

 RSSI	(Received	Signal	Strength	Indication)	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	batteries	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	their	placement.	

o The	CG	should	be	tested	by	lifting	the	UV	with	fingers	on	the	bottom	of	the	arms.	Check	

all	3	pairs	of	arms.	The	CG	should	be	no	more	than	2mm	off	in	any	on	the	3	checks.	The	

closer	the	CG	is	to	the	centerlines	of	the	arms	the	more	efficient	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	battery	power,	there	is	no	wing	to	

assist	in	providing	lift.	

o As	the	batteries	are	operated,	they	lose	power.	At	full	charge	they	have	about	25v.	At	

20%	remaining	capacity	they	have	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	reserve	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	required:	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	maximum	

o Battery	Minimum	Rated	Discharge	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	communication	for	LOS.	

o In	general:	

o LOS	is	required.	

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

o Lower	freqs	have	longer	range	than	high	freqs	

o Higher	freqs	can	transfer	more	data	than	lower	freqs	

o Higher	freqs	use	smaller/shorter	antennas	

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

o Any	freq	at	may	have	severe	degradation	due	to	location	to	other	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	must	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	impact	dust,	dirt	or	more.	

BATTERY CARE AND USE		

o Refer	to	instruction	sheet	included	from	the	battery	manufacturer.	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	considered	damaged	and	must	not	be	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	should	be	discarded.	

o Cycle	test	each	battery	after	every	50	cycles	or	if	a	battery	is	suspected	to	have	lost	as	

significant	amount	of	its	capacity	to	determine	the	current	capacity.	

o Properly	dispose	of	batteries.	First	discharge	the	battery	fully	using	a	battery	cycler.	

Bring	to	a	recycler	such	as	a	home	improvement	store.	

o Always	charge	flight	batteries	under	“balance”	mode.	

o Flight	Battery	Recommended	Charge	Rate:	1	C	which	takes	approximately	1	hour	to	

charge	

o Flight	Battery	Maximum	Charge	Rate:	May	exceed	5C.	Charge	rates	higher	than	1C	will	

decrease	life	cycles.	Maximum	charge	rating	per	the	manufacturer	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	ambient,	especially	if	the	

temperature	is	above	20°C.	The	outer	surface	is	cooler	than	the	inner	core	after	use.	

Damage	will	occur	when	charging	a	warm	battery.	

o Recommended	Battery	Discharge	Amount:	80%.	Using	more	of	the	capacity	of	the	

battery	will	decrease	the	life	cycles	

o As	battery	temperature	approaches	freezing	the	capacity	of	Lithium	Polymer	batteries	

decrease.	Keep	warmer	than	5°C	before	installing	into	the	UV	(unmanned	vehicle).	
35		 	 	 	 	 	 	 	 	 		

o Battery	capacity	decreases	at	higher	discharge	rates.	Using	more	batteries	decreases	

the	discharge	rate	of	each	battery	thereby	extending	individual	battery	capacity	slightly.	

o Lower	discharge	rates	improve	the	life	cycles.	

o Batteries	are	rated	at	greater	than	300	life	cycles.	1,000+	life	cycles	are	possible.	

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

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

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

o Fully	charged	batteries	which	are	not	to	be	used	within	24	hours	should	be	discharged	

to	40%	‐	60%	charged	state	using	the	battery	discharger.	

o Using	more	than	one	battery	at	a	time	requires	the	proper	wiring	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	all	components	for	wear	and	replace	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	all	components	for	wear	and	replace	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	utilized	in	the	construction	of	this	AV.		All	instruction	manuals,	

operating	handbooks,	warning	notices,	and	more	are	available	as	separate	documents.			Keep	

these	significant	documents	and	keep	in	a	notebook	with	the	copter	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	SYSTEM	SPEED	CONTROLS	(ESCs)	

VIDEO	CAPTURE	HARDWARE	

VIDEO	CAPTURE	SOFTWARE	

VIDEO	WIRELESS	LINK	
Attachment 5 

 
Revision 1 December 16, 2014 

DJI S1000

Training Manual

	 	
Revision 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 Procedures
Revision 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	Phantom	
Revision 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 6 
AFS-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 

 

ASTRAEUS AERIAL Regulatory Docket No. FAA-2014-0352

 

for an exemption from part 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, Code of Federal Regulations 

 

GRANT OF EXEMPTION

 By letter dated May 27, 2014, Jonathan B. Hill, Cooley LLC, Counsel for Astraeus Aerial, 

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 part 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, Code of Federal Regulations (14 CFR). The proposed exemption, 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, production approvals, airworthiness certificates, and 

airworthiness approvals.

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

capital letter “N” and the registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally certificated aircraft, the operator 
2

must also display on that aircraft near each entrance to the cabin, cockpit, 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 private 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 compensation 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. 

Section 91.7(a) prescribes, in pertinent part, that no 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 each pilot in command shall, before 

beginning a flight, become familiar with all available information concerning that 

flight, to include—

(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 known 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 Rotorcraft 

Flight Manual containing takeoff and landing distance data is 

required, the takeoff and landing distance data contained therein; 

and
3

(2) For civil aircraft other than those specified in paragraph (b)(1) of 

this section, other reliable information appropriate 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, except when necessary for takeoff or landing, no person 

may operate an aircraft below the following 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 air 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 populated 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 property 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 by 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 reference 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 no person may begin a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing 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 that for at least 45 minutes. [emphasis added]

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft 

unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an 

effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second copy of the Aircraft Registration Application as provided for 

in § 47.31(c). Section 91.203(b) prescribes, in pertinent part, that no person may 

operate a civil aircraft 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 operating an aircraft 

that has undergone maintenance, preventive maintenance, rebuilding, or alteration 

unless it has been approved for return to service by a person authorized under § 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 an inspection for the 

issuance of an airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each 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; and 
5

(iii) The signature, and certificate number of the person approving 

the aircraft 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, rotor, 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 inspection 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 directive 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 currently 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 repeated 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 furnished 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. The petitioner submitted additional information in response to the FAA’s 

August 7, 2014 request which is posted to the docket. The FAA has organized the petitioner’s 

information into three sections: 1) the unmanned aircraft system, 2) the UAS Pilot In 

Command (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 

variant, serial #001 onward (hereafter referred to as V.3). This aircraft has eight rotors and 

eight motors in a quadcopter configuration (X8). The petitioner states that given the size, 

weight, speed, and limited operating area associated with the aircraft to be utilized by the 

applicant, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates), subject 

to certain conditions and limitations, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 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 part 21, Subpart H and not subject to the proposed conditions and limitations.

The petitioner states that 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 exclusively 

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 limited operating area. The 

petitioner further describes that, in the event the UAS loses communications or its GPS signal, 

the UA will have the capability to return to a pre-determined location within the Security 

Perimeter and land. It will also have the capability to abort a flight in the event of unpredicted 

obstacles or emergencies. 

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

exemption may be needed from 14 CFR § 45.23 as the UA will have no entrance to the cabin, 

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 having the UA marked with the word 

“experimental” on the fuselage in compliance with 14 CFR § 45.29(f), in a location where the 

pilot, observer, and others working with the UA will see the identification.
7

The petitioner states that the maintenance requirements in the pertinent sections of 14 CFR 

part 91 are only applicable to aircraft with an airworthiness certificate in accordance with part 

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 “oncondition” 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 operating 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 restricted 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 

industry image-capture operations. Astraeus further asserts that there 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 operated within a secure 

environment, which no one will be allowed to 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 the 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 operated within visual line of sight (VLOS) of a 

pilot and/or observer, and that the UA flights 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 allowed within 100 feet of the UA operation, but this radius may 

be reduced to 30 feet based 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, weight, 
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 participating 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 aircraft 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 an equivalent level of safety will be achieved by the PIC taking all preflight actions as set 

forth in their MPTOM and FOPM, including reviewing weather, flight battery requirements, 

landing and takeoff distances, and aircraft performance data before initiation 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 required 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 limited 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 safety 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. The petitioner asserts that an 

equivalent level of safety will be achieved, as outlined in its MPTOM. 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 “falls 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 which 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 public benefit, including enhanced safety, reduction in 
9

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 Public Comments:

A summary of the petition was published in the Federal Register on June 26, 2014 (79 FR

36378). Eighty-six comments were received.

Of the 86 comments received, including eight from associations, 50 comments supported the 

exemption request, 22 opposed, and 14 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 and 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. Supporting 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 petition for exemption, 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 expressed concern regarding certain conditions outlined in Astraeus’ petition. ALPA 

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 appropriate 

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 operating 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 currently in effect do not address the licensing 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 other 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 

above 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 altitude 
10

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 

operation 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 noted the same in its comments. The 

FAA agrees with ALPA and NAAA and addresses this concern in its analysis of 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 

participants 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 licensed as 

commercial applicators. NAAA members operate in low-level airspace, and clear low-level 

airspace is vital to the safety of these operators.

NAAA stated that seeing 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 collisions. NAAA believes that UA

operations at low altitudes will increase the potential of collision hazards with agricultural 

aircraft. In its comments, the USHPA submitted similar concerns relative 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 the petitioner’s MPTOM. However, 

NAAA maintains, as does the USHPA, that in addition to this, issuance of a NOTAM 

advising nonparticipating pilots of the planned activity is vital to disseminating 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 identification when enforcement of flight regulations is required. The 

USHPA commented similarly, noting that while the current identification standards 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 agrees 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. Further 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 addressed 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, USHPA believes operation of any UA in three-dimensional space presents unique 

challenges in accurately determining position in relation to 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 navigational 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 common 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 has 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 weather 

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 personnel. 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 near 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 outlined in the petitioner’s FOPM and 

MPTOM are sufficient mitigations to this risk so that the operations will not adversely affect 

safety. Further information is contained in the analysis of the UAS below.

One commenter suggested that the FAA should require 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 conditions 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 plans 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 FSDO will be the primary 

office responsible for oversight of the operations.

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 333 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, the 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 it, 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 process. 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 are 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 filmed. 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:

Unmanned aircraft system (UAS)

Regarding the petitioner’s requested relief from 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 operations would not adversely affect safety compared to similar 
13

operations conducted with aircraft that have been issued an airworthiness certificate under 

14 CFR part 21, Subpart H.

Commercial motion picture and television aerial filming operations with manned aircraft are 

typically conducted with aircraft holding standard airworthiness certificates issued under 

part 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 aerial filming can weigh 6,000 

lbs. or more and are operated by an onboard pilot, in addition to other onboard crewmembers, 

as necessary. The petitioner’s UA will weigh less than 55 lbs. with no onboard pilot or crew. 

The pilot and crew will be remotely located from the aircraft. The limited weight significantly 

reduces the potential for harm to participating and nonparticipating individuals or property 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 an 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 issued Certificate of Waiver, aircraft can be operated in very close proximity to 

participating persons. The safety of these individuals is maintained through use of an aircraft 

with standard airworthiness certification under 14 CFR part 21, Subpart H, operation of the 

aircraft by a qualified and competent pilot, and operating according to limitations necessary to 

ensure safety. In these situations, the filming subject and production personnel are exposed to 

risk by virtue of their close proximity to an aircraft 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 to all other manned operations. Additionally, the exemption 

provides that the operator will request a NOTAM prior to operations to alert other users of the 

NAS.

The petitioner’s UAS has the capability to operate safely after experiencing certain in-flight 

failures. The UA is also able to respond to a lost-link event with a pre-coordinated, 

predictable, automated flight maneuver. With regard to USHPA’s concerns about dual control 

systems, current FAA regulations permit motion picture and television filming operations by 

manned aircraft that do not require a copilot. Additionally, under this exemption, the FAA

requires that the UAS PIC hold a current third class medical certificate. Historically, instances 

of complete PIC incapacitation are rare. In 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 procedure outlined within the FOPM. The 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 consideration 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 flight crew complement of one.

These safety features also provide for no adverse safety affect to participating and 

nonparticipating 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 333 of PL 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 Transportation 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 requested relief from 14 CFR § 45.23(b) Display of marks, the 

petitioner’s request is made under the assumption that marking with the word “experimental” 

will be required as a condition of an exemption request. This marking is reserved for aircraft 

that are issued experimental certificates under § 21.191. Since the 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 number, registered in accordance with 14 

CFR part 47, and have identification (N-Number) markings in accordance with 14 CFR part 

45, Subpart C. Markings must be as large as practicable.

Regarding the petitioner’s requested relief from 14 CFR §§ 91.405(a) Maintenance 

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, because 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 were 

reviewed and do not sufficiently 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 

maintenance and alteration requirements of 14 CFR §§ 91.405(a)(1), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b), provided changes are made to the MPTOM and 

FOPM as required by the conditions and limitations included in this exemption. These 

changes 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 UAS 
15

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 ensure the petitioner’s proposed 

UAS operations do not adversely affect safety in the NAS and of people and property on the 

ground. Therefore, the FAA finds that exemption from 14 CFR §§ 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b) is warranted subject to the conditions and 

limitations 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, comments 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 pilot 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 model intended to be used. Similar 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 that operations conducted for 

compensation or hire necessitate a commercial pilot certificate and at least a second class 

medical certificate. In considering the petitioner’s requested relief from 14 CFR § 61.113(a)

and (b), the FAA must consider the following factors as they relate specifically to Astraeus’

proposed operations:

Separation from manned aircraft operations: Astraeus proposes operations in a “sterile 

environment” of closed-set motion-picture filming. In this controlled environment, their 

operations will remain within visual line of site (VLOS) and below 400 feet AGL. 

Additionally, 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 airspace requirements and notification 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 also be required to avoid and yield right-of-way to all manned

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 for 

that of a commercial pilot versus a private pilot. The results show that the required areas of 

knowledge for a commercial versus private pilot cover the same fundamental principles, 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 log 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 Aviation 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 

Transportation 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 the 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 operation 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 aeronautical 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 avoidance 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 training is required for the private per §

61.107 and § 61.109. For this comparison, highaltitude operations are considered not applicable.** 

(15) Procedures for operating within the National 

Airspace System; and 

(3) Use of the applicable portions of the “Aeronautical 

Information Manual” and FAA advisory circulars; 

(13) Preflight action that includes— (i) How to obtain 

information on runway lengths at airports of intended 
17

use, data on takeoff and landing distances, weather 

reports and forecasts, and fuel requirements; 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 

considered 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 

certificate 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) Preflight 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 specifically** (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’ PIC(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 exemption. 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 hours 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.

The FAA’s analysis regarding PIC requirements: The parallel foundation of aeronautical 

knowledge required for private and commercial pilots is shown in the above table. Private 
18

pilot airmanship skills are furthered through manned flights in the NAS. Commercially 

certificated 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 encountered 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 environment 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, culminating 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 aeronautical 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. 

The 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 

designated 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 these closed-set filming operations from other manned operations, 2) the parallel nature of 

private pilot aeronautical knowledge requirements to those of commercial 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 proposed 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 

conditions and limitations outlined below, would not adversely affect the safety of the NAS.

Another consideration supporting the certificate requirement is that pilots holding a private 

pilot certificate are subject to security screening by the Department of Homeland Security.

This requirement should ameliorate security concerns over UAS operations under this 

exemption.

Operating parameters of the UAS

Astraeus has stated that it plans to comply with the waiver process as described in FAA Order 

8900.1, Volume 3, Chapter 8, Section 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 Certificate of Waiver, because the section did not originally provide for
19

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

section of Order 8900.1 provides no way to relieve Astraeus from the pilot requirements. 

Also, the sample form 7711-1 used for issuing the Certificate of Waiver 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 include the required notifications and coordination 

with jurisdictional FSDOs through the conditions and limitations listed below. Motion picture 

and television filming waivers similar to Astraeus’ operation are normally issued from one 

jurisdictional 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 operations manual(s) and levy any additional local special 

provisions. Since Astraeus’ operation deals specifically with UAS, this exemption will take 

the place of the Certificate of Waiver normally issued by a jurisdictional FSDO under 8900.1 

V3, C8, S1. Every FSDO with jurisdiction over the area that Astraeus plans to operate within 

must still be notified, just as with manned filming 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 

process 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 operations. The conditions 

and limitations below prescribe the requirement 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 no 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 issued, exemption from § 91.7(a) is not necessary.

In 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 safety checklists 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: 

Certifications required, the 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, the requested relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is 

not necessary.

Regarding the petitioner’s requested relief from 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). The 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, flight 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 VLOS 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 traffic, 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 exemption 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 controls 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 

qualification 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.

Regarding 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 altitude 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 within 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 performance of the actual filming. In accordance with the petitioner’s stated intention to 

adhere to Order 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 proposed 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 safety 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 nonparticipating 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 below. However, all nonparticipating 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 Altimeter 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-screen display, to be a sufficient method for ensuring the UAS 

operations do not adversely affect safety. The altitude information will be generated by 

equipment installed onboard the aircraft, as specified using GPS triangulation, or digitally 

encoded barometric 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 relief to 

14 CFR § 91.121.

Regarding the petitioner’s requested relief from 14 CFR § 91.151(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 Exemption 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 (VFR) conditions. The petitioner states 

that its UAS operations will be conducted in a controlled closed-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 (whichever 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, per FAA Order 8900.1 V16, C5, S3 

General Operational Requirements, to avoid collision hazards at night. All previous UASspecific grants of relief from 14 CFR § 91.151(a) have restricted flights to daytime VFR 

conditions only. While the FAA acknowledges the petitioner’s stated film set lighting 

techniques to mitigate the risks of nighttime operations, the petitioner has not provided 
22

sufficient data and analysis regarding the 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 nighttime 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 perimeter, 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 finds that a grant of exemption is in the public interest. The enhanced 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, carrying 

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 degree 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)

Part 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) granted 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 limitations

91.407(a)(1) Granted with conditions and limitations
23

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 FAA’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 granted 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 the operator.

The Flight Operations and Procedures Manual (FOPM) and Motion Picture and Television 

Operations Manual (MPTOM) are hereafter collectively referred to as the operator’s manual.

Failure to comply with any of the conditions and limitations of this 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 pounds (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 level 

(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 modified 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 human 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 maintains 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. The 

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 responsibility 

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 necessary 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 included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft 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. The 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 follow 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. Mechanical 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 certificate and at least a 

current third-class medical certificate. The PIC must also meet the flight review 

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

her pilot certificate.

11. Prior to operations conducted for the purpose of motion picture 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 with 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 under 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 nonparticipants, and the PIC must operate the UA with appropriate distance 

from nonparticipants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the 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 accomplish 
26

the required flight time and 90 day currency. During training, proficiency, experiencebuilding, and take-off and landing currency flights all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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 of 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 demonstration, 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 have 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 distance 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 participating persons, no further FSDO or aviation safety inspector 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 Issue a Certificate of Waiver for Motion Picture and Television Filming.

17. Regarding distance from nonparticipating 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 debris in the event of an accident. This is also consistent 

with 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 predetermined 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 the following conditions and limitations:

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 (NNumber) markings in accordance 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 parts, 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 criteria. 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 components, 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 FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS filming 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 in 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; the list of those who gave 

permission must be made available to the inspector upon request;

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 state over which filming will be conducted and the altitudes essential to 

accomplish the operation.

29. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These 

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

upon request.

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 

operations 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 the 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 than 3 statute miles from the PIC.
29

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

FAA. The UA may not operate within 5 nautical miles of the geographic center of a nontowered 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 operation that transgresses the lateral or vertical 

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

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the 

incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

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 terminates 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