Comment: Petition for Exemption/Rulemaking

Robert Mendez

Facility Intellect

1471 E. Commercial Dr.

Meridian, ID 83642

208-602-0442

facilityintellect@gmail.com

Section 333 Exemption

Facility Intellect is seeking exemption for section 333. We provide Video, Scanning & 

Photographic surveying, coordination and inspection services through the use of UAS's. Our 

equipment utilizes still photography, scanning and full videography in support of our mission.

We currently have full liability insurance, fly only VLOS, with a two man crew including a 

visual observer and a pilot. Both the visual observer and the pilot have been trained to man 

the vehicle's controls in the event of an emergency. Additionally all the flights are logged, 

remain under an altitude of 200 feet and with clearance of the local ATC.

Crew members are fully trained to fly in such a way that it will minimize the risk to public 

safety, as well as the natural environment within our area. Their flight time, at this time, is in 

excess of 40 hours, without incident or an accident.

All our equipment goes through a thorough maintenance & load checklist prior to take off, as 

well as utilizing an official preflight checklist.

Our equipment includes a 4 rotor quad copter, currently we utilize the DJI Phantom and 

Inspire 1 series, which carries a gimbal and a camera is not equipped to carry any individuals 

and remains under 25 pounds at takeoff. Flight times of the aircraft are 20-25 minutes 

depending on the winds and weather. Landing always happens before we reach a 25% 

threshold within the battery's cells. The aircraft does not exceed a ground speed of 40 mph 

and is equipped to return to the GPS position of takeoff in the event of a failure.

BENCH SET UP & TESTS

 All screws/bolts are tight

 Timer alarm for flight time to not exceed 80% battery capacity set properly

 Batteries are secure

 Antennas are secure

 Props balanced

 Props aligned

 Props not chipped

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

 Wiring Tight

 No excessive flexing of motors or booms

 Booms/motors will not twist

 Center of gravity is correct

 Warning lights set for low battery if used

 Batteries charged. Replace any battery which cycles below 80% of rated capacity

QUICK PREFLIGHT CHECKLIST

 Landing zone clear
 Level copter with correct heading

 Battery 4.1+ full, 3.8 depleted (do not use)

 Camera on. SD card in.

 Both TX – all switches down

 Copter on

 Check GPS and Course lock checks

 Video check

 Photo check

 Timers ready

 Takeoff

 Raise Landing Gear

 Unplug 6 batteries upon landing

TAKEOFF CHECKLIST

 Declare intentions for takeoff with ATC if required.

 Engage GPS mode – Double purple flash

 Engage Course 

 Announce loudly: “CLEAR PROP”

 Position the sticks in the lower left hand corners, then immediately raise the throttle 2 

clicks and center the right stick.

 Advance throttle to 1⁄4 power for 5 seconds. Assure all motors are operating.

 Verify that left/right and forward/back stick movement engages the proper motors.

 Verify data and video links are still operational

 Announce loudly: “TAKING OFF”

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

 Ascend to 3 meters. Center throttle stick. Should be single green flash. Verify 

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

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

 Verify copter stability. If unstable, land and reset gains, recalibrate, or retest as 

necessary.

 Raise landing gear

 Proceed with manual mission

 For autopilot operation Ascend to 10 meters manually

then engage autopilot

 Manual pilot/observer must monitor the informational LED and be ready to take over 

in manual mode when necessary.

 Manual pilot to request copter flight battery voltage readout from camera operator

periodically.

LANDING CHECKLIST

 Landing area clear

 Lower landing gear

 Note obstacles along flight path

 Announce clearly and loudly: “LANDING”

 First cut power to the aircraft

 Note elapsed time of flight

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

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

 Touch motors to verify temperatures are similar
 Complete flight log

o Date and time of flight

o Location

o Document Any issues

o Batteries used

o Time of Flight

 Contact ATC if required