High Level Images – Petition for Exemption 1

September 8, 2015

U.S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave. SE Washington, DC 20590

RE: HIGH LEVEL IMAGES, LLC

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF YUNEEQ 

TYPHOON SMALL UNMANNED AIRCRAFT SYSTEM PURSUANT TO

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC 

LAW 112-95)

Thomas A. Li Calzi

Owner

High Level Images, LLC

1833 Waverly Dr.

Florence, KY 41042

(513) 314-4847

tom@highlevelimages.com

 
High Level Images – Petition for Exemption 2

Table of Contents

1. List of Relevant Abbreviations.................................................................................................................3

2. Summary...................................................................................................................................................3

3. Introduction to the Petitioner ....................................................................................................................4

4. Sections of 14 CFR from which the Petitioner Seeks Exemption ............................................................4

5. Extent of Relief Petitioner seeks to Sections of 14 CFR and Reasons for Request..................................7

6. Public Benefit for Granting High Level Images Request for Procedural Relief.......................................9

7. Granting the Exemption Would Not Adversely Affect Public Safety ....................................................10

8. Summary for Publishing in the Federal Register....................................................................................11

9. Additional Information to Support High Level Images Request ............................................................11

10. Conclusion ............................................................................................................................................11

11. Appendix...............................................................................................................................................12

YUNEEC TYPHOON AND GROUND CONTROL STATION SPECIFICATIONS ..........................12

HIGH LEVEL IMAGES PREFLIGHT CHECKLIST ...........................................................................15

Section 1 – Equipment Transportation...................................................................................................15

Section 2 - Flight Plan..............................................................................................................................15

Section 3 - Preflight Checklist .................................................................................................................16

Section 4 – Flight Procedures..................................................................................................................17

Section 5 – Post Flight.............................................................................................................................17

High Level Images – Flight Log.............................................................................................................18
High Level Images – Petition for Exemption 3

1. List of Relevant Abbreviations 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

NM Nautical Mile

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

sUA Small Unmanned Aircraft

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VO Visual Observer

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

2. Summary

A. High Level Images, LLC. seeks exemptions from Title 14, Code of Federal 

Regulations § 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 

91.407 (a)(1), 91.409 (a)(1) and (2), 91.417 (a) and (b) to operate a Yuneec Typhoon 

sUA. This exemption will allow High Level Images, LLC. to operate a sUA 

commercially to provide aerial photography and videography on private property. 

Utilizing the enclosed safety procedures we will safely provide unique perspectives to 

assist in marketing properties and better inform the general public.
High Level Images – Petition for Exemption 4

3. Introduction to the Petitioner

.

A. Name and address 

(a) Thomas A. Li Calzi (Owner)

High Level Images, LLC

1833 Waverly Dr.

Florence, KY 41042

(513) 314-4847

tom@highlevelimages.com

B. About the petitioner 

(a) High Level Images, LLC provides custom digital media products for 

advertising. Our services include photography, cinematography, and 3D 

modeling. We primarily work in the real estate market providing high quality 

images, video tours and 3D "doll house views" of real estate for use on the 

MLS listings and marketing material. We are seeking relief to use the Yuneec 

Typhoon to capture elevated images and videos of private and commercial

real estate. We would like to propose the following safety and standard 

operating procedures to ensure the highest level of safety. 

4. Sections of 14 CFR from which the Petitioner Seeks Exemption

A. § 61.113 Private pilot privileges and limitations: Pilot in command: 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who 

holds private pilot certificate may act as 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.

B. § 91.7 Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

C. § 91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating—
High Level Images – Petition for Exemption 5

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure.

D. § 91.151 Fuel requirements for flight in VFR conditions.

(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.

(b) No person may begin a flight in a rotorcraft 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, to fly 

after that for at least 20 minutes.

E. § 91.405 Maintenance required. Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter;

F. § 91.407 Operation after maintenance, preventive maintenance, rebuilding, or 

alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter; and

(2) The maintenance record entry required by § 43.9 or § 43.11, as applicable, of 

this chapter has been made.

G. § 91.409 Inspections.
High Level Images – Petition for Exemption 6

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; 

or

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter.

H. § 91.417 Maintenance records.

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 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

(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.
High Level Images – Petition for Exemption 7

(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.

5. Extent of Relief Petitioner Seeks to Sections of 14 CFR and 

Reasons for Request.

A. § 61.113 Private pilot privileges and limitations: Pilot in command:

(a) The Yuneec Typhoon sUA has a take-off weight of 3.75 lbs. and as configured by 

the manufacturer and operated by High Level Images is incapable of carrying 

pilot(s), passengers, or cargo. In addition The Yuneec Typhoon is electronically 

limited to an operational envelope of 400’ AGL, a flight radius of 300’ from the 

GCS, is always operated VLOS, VMC, and during daylight hours only.

(b) Given the above operational limitations of the Yuneec Typhoon High Level 

Images submits that operation by a PIC with a private pilot certification would 

provide an appropriate level of safety and understanding of operation in the NAS 

and requests an exemption to § 61.113 (a) & (b).

B. § 91.7 Civil aircraft airworthiness.

(a) It is not clear if the Yuneec Typhoon is an aircraft for which the FAA has 

established or intends to issue an airworthiness certificate. To meet the intent of 

this regulation High Level Images requires the PIC, as part of the pre-flight 

checklist, to verify the airworthiness of the UAS prior to applying control power. 
High Level Images – Petition for Exemption 8

This includes visual inspection of rotor blades, fuselage, rotor arms, landing gear, 

and camera gimbal for any damaged or loose parts. Please refer to High Level 

Images Preflight Checklist in Appendix section 2. 

(b) High Level Images submits that their preflight SOP and after flight maintenance 

meets the requirements of this regulation and requests exemption from § 91.7.

C. § 91.121 Altimeter settings.

(a) The Yuneec Typhoon utilizes a combination of GPS and barometric pressure 

sensor to establish both position and altitude and transmits this data to the GCS 

operator display via a radio communications telemetry data link. Zero feet AGL 

is automatically established from the take off point of the sUA and may not reflect 

local field attitude.

(b) The Yuneec Typhoon is electronically limited to factory default of maximum 

400’ AGL, and High Level Images further utilizes an SOP that requires the PIC to 

operate the sUA at an altitude less than 300’ AGL. 

(c) High Level Images submits that its componentry and operation provide an 

equivalent level of safety and requests an exemption to § 91.121.

D. § 91.151 Fuel requirements for flight in VFR conditions.

(a) The Yuneec Typhoon is powered by one (1) 5400mAh Lithium Polymer (LiPo) 

battery and is limited to a flight duration of between 20 and 25 minutes total. 

High Level Images will restrict flight time to 15 minutes to leave a minimum of 

five (5) minutes of power reserve. 

(b) The PIC shall preplan a flight path for each AOI and take into consideration 

energy requirements based on air speed, wind conditions, planned and emergency 

VTOL locations. 

(c) All flights will be conducted during daylight hours beginning no sooner than one

(1) hour after sunrise and terminate one (1) hour before sunset. 

E. § 91.405 Maintenance required. Each owner or operator of an aircraft—

§ 91.407 Operation after maintenance, preventive maintenance, rebuilding, or 

alteration.

§ 91.409 Inspections.

§ 91.417 Maintenance records.

(a) High level Images seeks relief on § 91.405, § 91.407, § 91.409, and § 91.417 for 

the following reasons:
High Level Images – Petition for Exemption 9

(b) It is not clear if the Yuneec Typhoon is an aircraft for which the FAA has 

established or intends to issue an airworthiness certificate. These rules appear to 

apply to aircraft with an airworthiness certificate.

(c) High Level Images will maintain a detailed flight log recording all flight durations 

to keep record of motor hours, battery charge cycles, and wear on sUA. 

(d) Notwithstanding High Level Images will maintain and document the Yuneec

Typhoon in accordance with recommendations by the manufacturer’s 

communiques and Instruction Manual.

(e) High Level Images will document repairs and modifications to the sUA using 

only manufacturer recommended spare and replacement parts.

(f) High Level Images will maintain a monthly maintenance log and repair manual.

See Appendix 11 – High Level Images Flight Log.

6. Public Benefit for Granting High Level Images Request for 

Procedural Relief

A. Aerial photography and videography helps illustrate the scale and layout of real estate 

that is unobtainable using conventional ground photography. Aerial images’ unique 

perspectives make them instant attention grabbers and are very useful in marketing. 

Current manned aircraft aerial photography can be cost prohibitive and out of the 

budget of smaller business and real estate agents. 

B. Aerial photography and videography is quickly becoming common place and 

expected for marketing private real estate. This new demand for bird’s eye views will 

create an entirely new business market which in return will create countless job as 

well as a large local and national economic benefits. 

C. The magic of flight and intrigue of aerial images will help interest a new generation 

in the field of aviation. This could raise interest in science, technology, engineering

and math studies and could be a stepping stone for new commercial airline pilots. 

D. Traditional aerial photography is impracticable in densely populated residential areas. 

sUA are less intrusive to adjacent private property with reduced noise and are able to 

take off and land within the boundaries of the private property that they are working 

on. This eliminates the need to fly over and disturb the airspace of adjacent private 

property. 

E. The risk of property damage and injury with a 3.75 pound sUA is substantially less 

than those risks posed by manned aircraft flying at low altitudes to capture images.
High Level Images – Petition for Exemption 10

F. Operation of an electrically powered sUA is an environmentally sound alternative to 

conventional hydrocarbon fueled aircraft, exhibiting vastly lower noise pollution and

a carbon footprint which is a negligible fraction of traditional air operations.

G. Responsible regulated and operated UAS operations are inherently in the public’s 

best interest. 

7. Granting the Exemption Would Not Adversely Affect Public 

Safety

A. All operators and VOs have a minimum 25 hours flight time specific to the Yuneec 

Typhoon operation and have undergone training and testing specific to the sUA.

B. All flights are conducted during daylight hours no earlier than one (1) hour after 

sunrise and no later than one (1) hour before sunset to insure the proper VLOS can

always be maintained. 

C. All flights are conducted under clear weather conditions with minimum of 3 NM

visibility.

D. All Flights are electronically limited to a maximum of 400’ AGL and 300’ from the 

GCS which will eliminate exposure of sUA to entering airspace with other aircraft. 

E. All flights are conducted with electronic Return to Home (RTH) feature enabled.

F. All flight operations are conducted with a two person team consisting of an operator 

(PIC) and Visual Observer (VO).

G. All Flights require immediate landing upon detection of an intrusion by aerial 

vehicles, manned or unmanned, within 5000’ of operation. Intrusion by ground 

vehicles or unsheltered personnel within 500’ of operation require immediate landing.

H. The sUA will not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart. Should operation be requested within 5 nautical 

miles, a letter of agreement with the airport’s management is obtained or otherwise 

permitted by a COA issued to High Level Images, LLC. The letter of agreement with 

the airport management will be made available to the Administrator or any law 

enforcement official upon request.

I. PIC and VO will check tfr.faa.gov one (1) hour prior to every flight to receive

updated NoTAM and any relevant TFR in projected flight area. 
High Level Images – Petition for Exemption 11

J. High Level Images will continually be self-monitoring safety procedures and 

adopting new SOP to ensure the highest level of safety. 

K. High Level Images will continually monitor Federal guidelines and FAA rules as they 

are developed and adopted to stay abreast to the current rules and practices. 

8. Summary for Publishing in the Federal Register 

A. High Level Images, LLC. requests exemption from TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 

91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and 

(b). High Level Images, LLC. requests relief from these sections from the FAA 

Administrator per the intentions of the FAA Moderation and Reform Act of 2012 so 

that High Level Images, LLC. can produce photography and video for clients in the 

private sector. 

9. Additional Information to Support High Level Images Request

A. This petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. High Level Images, LLC. has an 

unmatched commitment to being a leader in the safe and responsible use of sUA in 

private photography and videography. We understand and respect that any UAS used 

improperly by inexperience operators can pose serious risks to the NAS, privacy and 

public safety. Our PIC and VO work together as a team to take every precaution 

necessary to ensure we do not enter the NAS in a manner that will interfere with 

manned aircraft or violate a NoTAM / TFR. Our continual intensive research on 

FAA regulations as well as aeronautical and technology advances will help us 

consistently update our safety protocols and SOP. We strive to be an industry leader 

in safe and responsible use of sUA. High Level Images, LLC will obtain an ATO 

issued COA prior to conducting any operations under the grant of this exemption. All 

aircraft operated by High Level Images that comply with this exemption will be 

registered in accordance with 14 CFR part 47 and aircraft will be marked with 

November markings as large as reasonably practical in accordance with 14 CFR part 

45, Subpart C. 

10. Conclusion 

A. As set forth herein, High Level Images, LLC. seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit the safe operation of a Yuneec Q500 TYPHOON UAS 

commercially to provide aerial and videography services. The Administrator will be 
High Level Images – Petition for Exemption 12

assisting small business by granting this petition. In accordance with the FAA 

Modernization and Reform Act of 2012, High Level Images, LLC. respectfully 

requests that the FAA Administrator grants this petition for exemption from TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 

91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and 

(2); 91.417 (a) and (b)

11. Appendix 

YUNEEC TYPHOON AND GROUND CONTROL STATION SPECIFICATIONS

Q500 TYPHOON SPECIFICTATIONS 

Height: 210mm (8.3 in)

Length (without rotor blades): 420mm (16.5 in)

Width (without rotor blades): 420mm (16.5 in)

Diameter (without rotor blades): 565mm (22.2 in)

Propeller/Rotor Blade Diameter: 330mm (13.0 in)

Weight (without battery and payload): 1130g (40.0 oz.)

Takeoff Weight (with battery and CGO2-GB): 1700g 

(60.0 oz.)

Battery: 5400mAh 3S 11.1V LiPo

Transmitter: ST10 10-channel 2.4GHz with 5.8GHz 

video link

Flight Time: 20-25 minutes
High Level Images – Petition for Exemption 13

CGO2-GB PAYLOAD (CAMERA AND GIMBAL)

Height: 115mm (4.5 in) Width: 75mm (2.9 in) Depth: 135mm (1.4 in)

Weight: 185g (6.5 oz)

Video Resolution: 1080p 60, 50 or 48 fps

Photo Resolution: 12 megapixels

Transmission Distance/Range: Up to 600m (1970 ft) depending on receiving device

Transmission Band: 5.8GHz
High Level Images – Petition for Exemption 14

ST10 GCS

Number of Channels: 10

RC Band: 2.4GHz

RC Modulation: Yuneec

Video Downlink Band: 5.8GHz

Telemetry/OSD: Yes

SD Card Compatible: Yes

LCD Screen Size: 4.5”

Touchscreen: Yes
High Level Images – Petition for Exemption 15

HIGH LEVEL IMAGES PREFLIGHT CHECKLIST

High Level Images, LLC

Safety Procedures and Checklist ©

Section 1 – Equipment Transportation 

1.1 Ensure rechargeable batteries in range extender and aircraft are fully charged. Check and/or replace 

non-rechargeable batteries in transmitter. Remember: Charging batteries can take 1-3 hours!

1.2 Inspect fuselage, motors and landing gear on the aircraft. Aircraft must not be flown if damage or 

deformity in any of these areas exists without first replacing or repairing the offending item(s) using only 

manufacturer approved parts and procedures. 

1.3 Inspect rotor blades for damage, chips or deformity of any kind. Immediately discard any damaged 

rotors and replace with original manufacture equipment. 

1.4 All joints, connections, wires, hinges, linkages, controls, mounting systems, rotor blades, and landing 

gear are tight fitting, within normal range of motion, lubricated, and free of debris, dirt, or other foreign 

material.

1.5 Inspect UAS identification number for any damage. Replace any characters to ensure proper 

identification at all times. 

1.6 All electrical connections are connected and plugged in and secured.

1.7 Photography equipment and mounting system is secure and within normal range of movement. 

Photography equipment is free of damage or deformity. Ensure lens cover and gimbal clamp are in place 

prior to transport.

1.8 Securely pack sUA and accessories in appropriate locations in travel case prior to transport.

Section 2 - Flight Plan 

2.1 Verify address of work site location and associated GPS coordinates. Ensure flight location is minimum 

five (5) miles from nearby airport(s).

2.2 Verify existing weather conditions and check NOTAMs on aviationweather.gov . Ensure no snow, hail, 

rain, lightning and/or thunder is occurring within 5 miles of the flight path. Wind conditions, steady or 

gusts, shall not exceed 15 mph at the field of flight. If unsure of the distance or amount of inclement 

weather, the operator SHALL NOT proceed with the flight, unless conditions improve.

2.3 Consult established flight plan and/or work order, including number of sites to be photographed, 

number of waypoints around each site, and a path between each waypoint. Verify the projected flight 

path will allow for visual line of sight operation of the aircraft at all times.

2.4 Verify the projected flight path is clear of all obstacles. If there is an obstacle, an alternative flight path 
High Level Images – Petition for Exemption 16

must be established. Obstacles include people, vehicles, roads, and structures. Always maintain at least 

100 feet from obstacles due to potential hazards from unplanned landings. If, at any time during a flight, 

people or vehicles impinge on the 100 foot separation rule, the operator must direct the aircraft to an 

emergency safe landing area and land immediately until it is once again safe to operate.

2.5 Establish a primary safe landing/take off zone defined as a 10 foot radius firm level surface free from any 

object or person other than High Level Images personnel directly involved in the flight session.

2.6 Under no circumstances should a flight session exceed an altitude of 300 feet to avoid conflict with fullscale manned aircraft and maintain VLOS.

2.7 All flights should be performed during daylight hours beginning no earlier than 1 hour after dawn and no 

later than 1 hour prior to dusk.

 

Section 3 - Preflight Checklist 

3.1 Unpack aircraft and accessories from case at primary landing/take off zone

3.2 Perform an overall visual check of aircraft, paying strict attention to the soundness of the following items 

with battery removed from aircraft.

3.2.1 Rotor blades are free from damage and are adequately tightened

3.2.2 Rotor blades turn freely by hand with no binding

3.2.3 Fuselage is free from damage

3.2.4 Landing gear is undamaged and not entangled by foreign objects

3.2.5 Camera gimbal and camera are securely attached to aircraft

3.2.6 Camera gimbal dampeners are in good condition

3.2.7 Micro SD card is installed

If faulty equipment is found at any point during the pre-flight inspection, it shall be repaired before any 

flight. If it cannot be repaired at the flight scene, the operator must not proceed or continue with flight.

3.3 Remove camera lens protective cover and gimbal lock. Store them safely in transport case.

3.4 Remove items not directly related to flight operations to a minimum distance of 50 feet from zone and 

projected flight/operator path.

3.5 Power on GCS.

3.6 Place flight battery in aircraft and power on vehicle.

3.7 Ensure successful RF control connection and video feed.

3.8 Perform compass recalibration.

3.9 PIC and VO scan ground area and sky above for no intrusions and to announce “clear” or “hold”.
High Level Images – Petition for Exemption 17

Section 4 – Flight Procedures 

4.1 From a distance of 10’ from aircraft depress and hold motor control button until rotors begin low idle.

4.2 Observe aircraft at idle (throttle centered) for any undue vibration or behavior. If aircraft exhibits any 

unusual functionality, attempts to take off or move in any direction pull throttle to lowest level and 

depress motor control button until motors power down. If reparable in field then reattempt, otherwise 

cancel flight operations.

4.3 Announce “TAKE OFF” loudly so that anyone within 100 feet can hear.

4.4 Slowly advance throttle and establish a low hover above ground effect but no greater than 8’ AGL. Check 

aircraft for proper response to slight control inputs.

4.5 Fly mission maintaining 100 foot obstruction zone and less than 300 feet altitude flight parameters. 

4.6 Upon mission complete or less than 20% battery level, check for personnel or obstructions near safe 

zone and announce "Landing, All Clear!". Ensure safe landing zone is not obstructed.

4.7 Return to low hover (around 15 feet) over safe zone, check again for personnel or obstructions, and 

announce again "Landing, All Clear!" . Slowly pull throttle back until safely on ground.

4.8 Depress motor control button until rotors stop.

4.9 Power off battery and remove. If continuing mission, ensure replacement battery is powered off, 

replace battery and re-inspect aircraft for flight worthiness. Repeat checklist beginning at step 3.9.

 

Section 5 – Post Flight 

5.1 Power down flight battery and remove from aircraft.

5.2 Power down GCS.

5.3 Replace camera lens protective cover. 

5.4 Carefully remove and secure micro SD card.

5.5 Replace camera gimbal lock. 

5.6 Inspect aircraft, camera, and gimbal assembly for missing, damaged, or loose parts. Repair, replace, find, 

or make note of items that cannot be addressed in the field.

5.7 Carefully repack aircraft and accessories in transport case, ensuring all items are in their proper storage 

locations.
High Level Images – Petition for Exemption 18

5.8 Scan and police area for detritus left during mission.

5.9 Fill out flight log with information from flight.

High Level Images – Flight Log