Cover Letter

Page 1

Legal Video Services, Inc.

James P. David

9465 Counselors Row

Suite 200

Indianapolis, IN 46240

(317) 845-4440

office@legalvideoservicesinc.com

Mr. James H. Williams

Manager, Flight Standards Service

Unmanned Aircraft Systems Integration Office

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

September 15, 2015

Re: Exemption Request Section 333 of the FAA Reform Act of 2012.

Mr. Williams,

My name is James David. My father earned his private pilot’s license in 1965 when I 

was 2 years old, and he owned and operated several different general aviation 

airplanes while I was growing up. I spent many, many hours in the right seat next to 

him as we travelled all over the USA during my teen and pre-teen years. I earned my 

private pilot’s license in 1988 at age 23, and have adopted my dad’s deep affection for 

general aviation. I share this information to convey to you that I completely understand 

the importance of a safe NAS.

In 1987 I entered into the hobby of model aviation. I’ve been a member in good 

standing in the Academy of Model Aeronautics (AMA) since that time and have spent 

literally thousands of hours building and flying all sorts of radio-controlled (RC) model 

aircraft (fixed wing, rotorcraft and multi-rotorcraft). I take the AMA safety code very 

seriously, and I am proud to share that I’ve never been at fault for any accident or 

incident that caused harm or damage to anyone or any property (other than my own 

aircraft) throughout that 25+ year experience. I credit a strict adherence to the AMA 
Cover Letter

Page 2

safety code for that stellar safety record. I have been the president of the Northeast 

Side Taildraggers R/C Aviation Club in Noblesville Indiana since its inception in 2011, 

and as such, I am obliged to not only abide by the AMA safety code, but also to teach 

and enforce it.

I spent the first 25 years of my adult career as an electrical engineer. Most of that time 

was spent designing advanced electronic control systems for use in heavy factory 

automation. These systems were high-reliability, industrially hardened and designed to 

operate long-term in harsh environments. These were microprocessor-based systems 

for which I provided hardware, software and mechanical engineering disciplines.

In 2008, I purchased Legal Video Services, Inc., an S-Corporation located in 

Indianapolis Indiana. I work with many, many clients in the legal field, providing all sorts 

of imaging services. Occasionally I am asked to collect images for use in litigation of 

worksites, accident sites, business establishments, or other real estate locations that 

are either impossible, unsafe or cost-prohibitive for clients to use manned aircraft or 

ground-borne equipment.

I believe that my knowledge of the NAS as a private pilot, my extensive experience 

building and flying small unmanned aerial systems, and my experience in design and 

development of complex electronic systems all combine to make me an ideal candidate 

for the requested exemptions. Therefore, on behalf of Legal Video Services, Inc., I 

request the exemptions from part 14 of the CFR as detailed on the following pages.

Thank you for your time and consideration of this request.

Sincerely,

James P. David

President

Legal Video Services, Inc.

President

Northeast Side Taildraggers R/C Aviation Club

15251 Olio Road

Noblesville IN 46060

Private Pilot – Single Engine Land (Certificate # available on request)

Current 3rd Class Medical (Applicant ID #1996344976)

AMA Membership #954569
Petition for Exemption

Page 1

Legal Video Services, Inc.

James P. David

9465 Counselors Row

Suite 200

Indianapolis, IN 46240

(317) 845-4440

office@legalvideoservicesinc.com

U.S. Department of Transportation, Docket Management System

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington DC 20590 

September 15, 2015

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments: 

1) Appendix A – Exemption Request Summary

2) Appendix B – LVSI Tarot 680Pro sUAS Construction and Performance Manual

3) Appendix C – LVSI sUAS Flight Operations Manual 

References:

1) FAA Exemption No. 11405, Regulatory Docket No. FAA-2015-0118 in the matter of Bryan 

Cherry

2) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter of the 

petition of DOUGLAS TRUDEAU 

3) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter of the 

petition of ADVANCED AVIATION SOLUTIONS LLC 4) FAA Exemption No. 11080 

Regulatory Docket No. FAA-2014-0355 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam, 

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 

333 of the FAA Modernization and Reform Act of 2012, I, James P. David, petitioner, on behalf 

of Legal Video Services, Inc., request exemption from the following sections of Title 14, Code of 

Federal Regulations

61.113(a); 61.113(b); 91.119(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(1); 91.409(a)(2); 91.417(a) & (b); 

In order to operate small unmanned aircraft systems (sUAS) commercially in airspace regulated 

by the Federal Aviation Administration (FAA) for the purposes of aerial photography, 
Petition for Exemption

Page 2

cinematography, property surveying, inspections, closed-set motion picture filming and other 

flight operations that could be performed safely and more cost effectively with the use of sUAS 

at low altitude within the U.S. national airspace system as compared to a manned aircraft. 

Operations will be performed over property controlled by Legal Video Services, Inc. and/or their 

clients or authorized agents. All such operations are to be conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following reasons; 

61.113(a) & (b): The petitioner requests relief in order to allow pilots who hold a PRIVATE PILOT (or 

greater) certificate as well as a current third class (or higher) medical certificate to act as PIC of for-hire 

sUAS missions. Any pilots operating under this exemption would be required to comply with any 

conditions as set forth and in a similar fashion to the previously granted exemptions.

91.119(b) & (c): As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer 

than 500 feet to the ground may require that the sUAS be operated closer than 500 feet to essential 

persons or objects that would not be possible without additional relief. The petitioner requests 

modification, waiver or exemption and clarification concerning the terms “congested areas” and 

“densely populated”. The petitioner requests waiver for this condition to allow reasonable and 

responsible operations in areas of subdivisions and neighborhoods if required. Such operations would 

be carefully flight-planned to eliminate all non-essential personnel from the flight path, and to limit 

operations over structures and/or vehicles to those owned by Legal Video Services, Inc., its clients or 

their authorized agents. Since the vast majority of missions involve very low horizontal speeds (less than 

5 kts) and very low maximum altitudes (less than 100 feet AGL), we request that the sUAS horizontal 

radius distance from non-essential personnel be lowered to two times the AGL altitude of the sUAS, 

down to a minimum horizontal distance of 50 feet (when the sUAS is lower than 25 feet AGL), for 

missions that will not exceed 5 kts in horizontal ground speed.

91.121: As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the sUAS does not 

have a mechanical altimeter and instead utilizes electronic GPS with a barometric sensor with altitude 

information (AGL and MSL) available to the PIC on the ground station through telemetry. 

91.151(a): As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has 

been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption 

Nos. 2689, 5745, and 10650. In addition, similar sUAS specific relief has been granted in Exemption Nos. 

8811, 10808, and 10673 for daytime, VFR conditions. The sUAS provides battery power remaining as a 

percentage to the PIC on the ground station through telemetry. Information provided in the operating 

documents discusses procedures regarding remaining battery power management. Those documents 

contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a

specified remaining level. Given the limitations on proposed operations and the location of those 

proposed operations, the FAA found that a reduced minimum power reserve for flight in daytime VFR 

conditions was reasonable. 

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b): As discussed in Exemption 11138 

(DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure that the UAS is in a condition for 

safe flight in accordance with the operating documents. The FAA found that adherence to the

petitioner’s operating documents and the conditions and limitations specified, describing the 
Petition for Exemption

Page 3

requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety 

would not be adversely affected. 

Our sUAS System:

The petitioner, having extensive experience in both sUAS design and construction (25+ years) and in 

microelectronics design and implementation (25+ years) has constructed a hexcopter multi-rotorcraft 

from proven and successful commercially-available components based on the Tarot 680Pro hexcopter 

frame. See Appendix B for detailed documents that describe the design details of the sUAS. Our sUAS 

hexcopter configuration, with high-definition camera payload and flight battery has an maximum weight

not to exceed 10 lbs., will not exceed a horizontal ground speed of more than 30 knots (35 mph, 16 m/s) 

and has a maximum climb rate of less than 1000 fpm (5 m/s). It is powered by six electric motors with a 

diameter distance between motors (center to center) of less than 28 inches (700mm). It utilizes an 

internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global 

positioning system (GPS) and electronic magnetic compass (EMC) to maintain its geospatial orientation 

and position. While the onboard computerized flight controller (CFC) maintains basic flight coordination, 

the sUAS is piloted primarily through an FCC certified radio control (RC) unit. Real time video and 

telemetry information is transmitted back to a ground control station allowing the operator and/or PIC 

to monitor battery level, GPS signal strength, altitude (AGL and MSL), distance from PIC, camera 

imagery, and to control the camera angle. It has failsafe modes of operation for either loss of RC or GPS 

signal. Altitude can be limited by the onboard flight controller and maximum altitude can be 

preprogrammed by the PIC. Battery life limits flight times to approximately 20 minutes. The onboard 

flight controller will warn the pilot via telemetry, audible and external lighting cues before reaching a 

low battery state. An automatic termination of flight and landing will be initiated when the battery 

reaches a predetermined low state. It is anticipated that flights will usually last less than 15 minutes. 

Risk mitigation:

The petitioner has reviewed FAA exemptions reference’s 13 Conditions and Limitations section and 

believes that the procedures specified therein are reasonable and will be utilized in order to manage 

and mitigate risk and ensure public safety. A preflight checklist will be utilized to ensure that the sUAS 

airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs. The petitioner request that in a 

manner similar to reference 4, he be allowed to operate within 5 miles of an airport provided that; 

“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 non-towered airport as 

denoted on a current FAA published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. The letter of agreement with the airport management must 

be made available to the Administrator upon request.” 

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting 

a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the 

need arise. Operations within class B airspace are not requested due to the lack of mode C transponder. 
Petition for Exemption

Page 4

Public interest:

Use of the sUAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact 

as compared to similar operations conducted with manned aircraft of greater proportions, carrying a 

crew and flammable fuel. Additionally, use of the sUAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will enable service for property owners or their designees 

seeking an enhanced perspective for characteristics, amenities, and benefits of their desired 

photographic subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and enhance personal 

photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and 

conservation of water as well as increased crop yields and decreased costs. Aerial surveying and 

inspections can increase work site efficiency and safety, improve volumetric estimations and reduce 

risks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis 

acting as an independent contractor. A visual observer will be utilized. Liability insurance will be 

maintained. Flight data including UAS flight time, incident, accident, and details concerning any 

deviations from normal operations will be available to FAA for use in collecting data regarding the use of 

sUAS as part of this application. This data may be submitted to FAA if requested. 

Conclusion:

The petitioner is requesting this exemption for the purposes of aerial photography, cinematography, 

photogrammetry, structure surveying, inspections and other flight operations. The petitioner's business 

model is based on the idea of offering information processing and management solutions which are 

enhanced by utilization of sUAS. The petitioner’s market research shows pent up demand for these 

services currently exists in several markets with many others emerging. The primary purpose of seeking 

this exemption is to expand the business capability to offer the above services while remaining in 

compliance. The petitioner has over 70 hours of experience in the UAV model listed herein, over 25

years experience in sUAS design, construction and operation, and holds a Private Pilot airman certificate. 

Respectfully submitted, 

James P. David

President

Legal Video Services, Inc.

President

Northeast Side Taildraggers R/C Aviation Club

15251 Olio Road

Noblesville IN 46060

Private Pilot – Single Engine Land (Certificate #437370869)

Current 3rd Class Medical (Applicant ID #1996344976)

Academy of Model Aeronautics (AMA) Membership #954569
Petition for Exemption

Page 5

Legal Video Services, Inc.

James P. David

9465 Counselors Row

Suite 200

Indianapolis, IN 46240

(317) 845-4440

office@legalvideoservicesinc.com

Appendix A – Summary Request

The petitioner requests exemption from the following sections of Title 14, Code of 

Federal Regulations

61.113(a) & (b): To allow pilots who hold a PRIVATE PILOT (or greater) certificate as well as a 

current third class (or higher) medical certificate to act as PIC of for-hire sUAS missions.

91.119(b) & (c): To allow low-altitude sUAS operations at horizontal distances of no less than 

twice the sUAS altitude AGL from non-essential personnel, down to a minimum of 50 feet

horizontally from non-essential personnel (during missions where the sUAS will not exceed 5kts 

ground speed). 

91.121: To allow operation with real-time AGL altitude telemetry instead of an on-board 

altimeter. 

91.151(a): To relax the 30-minute reserve fuel regulations, since most flights will be less than 

15 minutes in duration, and since the pilot will have real-time battery status available through 

telemetry. 

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b): Since the petitioner is the sUAS 

builder with extensive experience in sUAS design and construction, and also with extensive 

experience in complex electronic systems, the petitioner proposes to inspect and ensure that 

the UAS is in a condition for safe flight in accordance with the operating documents. 
Petition for Exemption

Page 6

Appendix B – LVSI Tarot 680Pro Construction and Performance 

Manual

After extensive research and trials, the Tarot 680Pro hexcopter frame was chosen due to its:

1. Ability to carry a shock and vibration dampened 2-axis camera gimbal.

2. Size, propulsion capacity and flying weight capable of safe and stable flight in 

moderate winds.

3. Low frame weight with high strength and rigidity.

4. Outboard position of the electronic speed controllers (situated under the propellers) 

to facilitate enhanced airflow and cooling, and to distance high frequency electrical 

switching “noise” from the computerized flight controller and RC receiver.

5. Integrated power distribution circuit board built into top frame plate.

6. Strong and lightweight carbon fiber sandwich frame design.

7. Battery and payload mounting rails provide payload flexibility and easily adjustable

center of gravity.

8. Ample ground clearance for gimbal/camera payload.

9. Constructed from readily available carbon fiber tubes for easy component 

replacement.

10. Large frame platform allows ample separation of radio frequency transmission 

components.

11. Foldable configuration for easy transportation.

Figure 1- LVSI Tarot 680Pro System
Petition for Exemption

Page 7

LVSI Tarot 680Pro Specifications:

Frame:

Frame diameter (motor center to center): 26.75 inches (680mm)

Total diameter (with propellers): 38.75 inches (985mm)

Height (including GPS mast): 16.5 inches (419mm)

Frame weight: 27.5 oz. (780 grams)

Flying weight (max): 160 oz. (4536 grams)

Propulsion:

Electronic speed controllers (Tarot recommended): Afro SimonK 20A (x6)

Electric motors (Tarot recommended): Tarot 4006 620kV (x6)

Max current requirement (each): 14A @ 14.8V

Power output (max each): 207.2 Watts each

Propellers (recommended): 12” x 5.5” carbon fiber (x6)

Flight Control:

Computerized flight controller: 3D Robotics Pixhawk

Microprocessor: Advanced 32-bit ARM

Data logging: Onboard, extensive

GPS/magnetic compass: 3D Robotics uBlox

Radio control receiver (sUAS onboard): Spektrum SPM9545

Radio control transmitter (PIC): Spektrum DX9

Radio control frequency band: 2.4 GHz

Radio control frequency interoperation: DSMX frequency hopping

Onboard Imaging Equipment:

Camera: GoPro Hero 4 Black

2 axis camera gimbal: Tarot T-2D

Roll axis stabilization: +/-35 degrees

Pitch axis stabilization: +/-45 degrees

Pitch axis control (PIC override): 0 to 90 degrees

Video transmitter: Immersion RC

Video transmitter frequency band: 5.8 GHz

Video transmitter output power: 200mW

Telemetry data acquisition module Minim OSD 2.4

Video transmission/telemetry range: 1km (.6mi)

Telemetry Ground Station:

Telemetry/image ground station: RX-LCD5802

Ground station screen: 7” color LCD

Ground station video receiver: Integrated (RX-LCD5802)

Ground station video receiver topology: Dual diversity

Flight Battery:

Chemistry: Lithium Polymer

Capacity: 10000mAh, 14.8V (4S)

Max safe discharge rate: 100 Amps

Hover discharge rate: ~30 Amps

Flight duration (hover): >20 minutes
Petition for Exemption

Page 8

LVSI Tarot 680Pro Schematic Diagram
Petition for Exemption

Page 9

Ground Station Telemetry

The LVSI implementation of the Tarot 680Pro multi-rotorcraft is equipped with a video camera 

whose video output is fed to radio-frequency video downlink. The video image is sent via radio 

frequency transmission to a ground station consisting of a video receiver and a 7” color LCD 

screen for display of the video image. In line with the video signal on the sUAS (between the 

camera and the video transmitter) is a telemetry extraction device that continuously polls the 

computerized flight controller for real-time flight data and inserts that data as an “overlay” on the 

video image. The composite image is then sent through the video transmitter to the ground 

station where it is displayed for the PIC (and/or VO) to monitor. The images below depict the 

real-time mission-critical values available to the PIC through the ground station via telemetry.

< Altitude AGL

< Altitude MSL

< Vertical speed (fps)

< Ground speed (mph)

< Distance from “home”

< Travelled distance

< CFC flight mode

“Home” direction >

Heading >

Heading rose >

Battery time remaining > 

(at current discharge rate)

Locked GPS satellites >

Battery mAh used >

Battery voltage >

Current draw >

GPS Latitude >

GPS Longitude >
Petition for Exemption

Page 10

Computerized Flight Controller – 3D Robotics Pixhawk

While several proven, commercially available flight controllers exist for multi-rotorcraft in the market today, 

the Pixhawk flight controller from 3D Robotics was chosen for several reasons:

1. 32-bit ARM microprocessor for fast processing and future expandability

2. 32-bit failsafe co-processor

3. Connectivity:

a) 14 PWM/servo outputs

b) UART (x5)

c) I

2C

d) CAN (x2)

e) Spektrum DSMX satellite receiver port

f) MicroUSB port

4. Robust support of GPS/magnetic compass module

5. 3-level motor arming procedure.

6. Detailed flight logging (on microSD card)

7. Fail-safe modes

a) Return to launch and land on low battery

b) Return to launch and land on loss of RC signal

c) Land if GPS lock is lost (and RC signal is lost)

8. Integrates with MissionPlanner flight software which facilitates:

a) Flight controller configuration and calibration

b) Satellite map-based mission planning

c) Missions with up to 99 three dimensional waypoints

d) Hard ceiling maximum altitude configuration

e) Secondary telemetry

The operations manual for the Pixhawk flight controller is far too voluminous to include here. For those 

interested, the following online documents are available:

Quick Start Guide: http://3drobotics.com/wp-content/uploads/2014/03/pixhawk-manual-rev7.pdf

Hardware overview: https://pixhawk.org/modules/pixhawk

User manual: https://pixhawk.org/users/first_steps

sUAS Aircraft Registration

As per FAA regulations, all models of the LVSI Tarot 680 Pro sUAS for use under this exemption must be 

registered and display an N-number before commercial use. Registration was granted for the sUAS 

pictured above, serial number 1411001, now registered as N586AD. Of course, any sUAS aircraft built 

for use under this exemption in the future will be of similar design and construction, and will also be 

registered with the FAA. 
Petition for Exemption

Page 11

Appendix C – LVSI sUAS Flight Operations Manual

The following procedures and guidelines have been developed to ensure safe, reliable and 

consistent operation of the LVSI Unmanned Aerial System (UAS).

The operator (Legal Video Services, Inc.) has applied for a part 333 exemption from the FAA to 

allow for-hire commercial operation of the UAS. Should there be any discrepancy between 

these conditions and limitations and those set forth by the FAA part 333 exemption, the 

conditions and limitation set forth in the exemption will take precedence. In lieu of such 

discrepancy, any pilot in command (PIC) of commercial UAS missions must adhere to the 

following conditions and limitations:

1. The UAS will be operated with a flying weight not to exceed 55 pounds including payload.

2. The UAS may not be operated at a ground speed exceeding 100 miles per hour.

3. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL). 

4. The UAS must be operated within visual line of sight (VLOS) of the pilot in command (PIC) at all 

times. This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s 

license.

5. All commercial operations must utilize a visual observer (VO). The UAS must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO and PIC must be able to 

communicate verbally at all times; electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

6. This operations manual, the FAA exemption documents, flight and mission logs, and all 

documents needed to operate the UAS and conduct its operations in accordance with the 

conditions and limitations are hereinafter referred to as the operating documents. The operating 

documents must be accessible during commercial UAS operations and made available to the 

FAA upon request. The operator must follow the procedures as outlined in its operating 

documents, unless those procedures are superseded by FAA exemption documents. 

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g., replacement of a flight critical component, must undergo a functional test 

flight prior to conducting further commercial operations. Functional test flights may only be 

conducted by a PIC with a VO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property.

8. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

9. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g.,

inoperable components, items, or equipment. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight.

10. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

11. Each UAS must comply with all manufacturer safety bulletins.

12. The PIC must hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. 
Petition for Exemption

Page 12

driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, 

or the Federal government. The PIC must also meet the flight review requirements specified in 

CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

13. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and 

currency must be logged in a manner consistent with 14 CFR 61.51(b). Flights for the purposes of 

training the operator’s PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS 

will be commercially operated are subject to and eligible for flight logging. However, training 

operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UAS with appropriate distance from 

nonparticipants in accordance with 14 CFR 91.119.

14. 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.

15. The UAS may not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a 

letter of agreement with that airport’s management is obtained or otherwise permitted by a COA 

issued to the operator. The letter of agreement with the airport management must be made 

available to the FAA or any law enforcement official upon request.

16. The UAS 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.

17. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private or controlled-access property.

18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UAS to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.

20. All aircraft operated in accordance with these operating documents 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.

21. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR 91.9 and 91.203 must 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 FAA or any law enforcement official upon request.

22. The UAS must remain clear and give way to all manned aviation operations and activities at all 

times. 

23. The UAS may not be operated by the PIC from any moving device or vehicle. 

24. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UAS and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 
Petition for Exemption

Page 13

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons.

25. All operations shall be conducted over private or controlled-access property with permission from 

the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

26. 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.

If the exemption permits operations for the purpose of closed-set motion picture and television filming and 

production, the following additional conditions and limitations apply.

27. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in the grant of exemption.

28. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must 

submit a written Plan of Activities to the local Flight Standards District Office (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 aerial filming 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 aerial filming;

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. Flight operations may be conducted closer than 500 feet from participating persons consenting to 

be involved and necessary for the filming production, as specified in the exemption holder’s 

MPTOM.
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LVSI UAS Preflight Checklist

I. The following checklist is to be performed by the visual observer (VO) and pilot in 

command (PIC) prior to connecting the power source to the UAS. This is to be 

done prior to each flying session:

a. Place all motor arms into flight position (unfold). Ensure that all arms are securely 

locked into flight position.

b. Inspect the airframe for fatigue or transportation damage:

a) Inspect arms.

b) Inspect center plates:

1. Inspect center plate screws.

2. Inspect flight controller mount and connections.

3. Inspect GPS mast and mount and connections.

4. Inspect the telemetry module and video transmitter module and connections.

5. Inspect RC receiver and connections.

6. Inspect RC and video transmitter antennae and their connections.

c) Inspect motor pods:

1. Inspect plastic parts for cracks or fatigue.

2. Inspect motor and pod mounting screws.

3. Inspect exposed wiring and connections.

4. Inspect ESCs and mounting.

d) Inspect propellers for chips or cracks.

e) Inspect propeller mounting screws.

f) Inspect landing skids, ensure that they are both locked in “down” position.

g) Inspect battery/payload mounting rails:

1. Check mounting screws.

2. Check rigidity of battery and payload mounts.

h) Inspect cover mounting bosses.

i) Check center of gravity and adjust battery/payload as necessary to obtain 

balance.

c. Prepare flight controller:

a) Remove the SD memory card from the flight controller, use an external personal 

computer (PC) to ensure that there is enough storage space on the SD memory 

card for data logging required for the subsequent flight session.

b) If the subsequent flight session is to include autonomous flight operations, create 

the flight plan using MissionPlanner software on the PC

c) If PC telemetry will be used, ensure that the PC has adequent battery power.

II. Powering up the sUAS:
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1. Turn on the RC transmitter:

a) Ensure that it is configured for use with the sUAS to be flown.

b) Ensure that the RC transmitter has sufficient battery power to conduct the 

subsequent flight session with adequate reserve power (at least 7.0 volts)

c) Check RC transmitter configuration switches and controls:

1. Flight mode – Stabilize mode.

2. Control sensitivity – Low rates.

3. Throttle curve – Expo medium.

4. Telemetry display mode – Complex mode.

2. Turn on the ground station:

a) Ensure that it has sufficient battery power to conduct the subsequent flight 

session with adequate reserve power. The ground station can be charged while 

operating from a 12 volt DC power source.

3. Turn on the payload camera, check its battery.

4. Connect the sUAS onboard flight battery.

III. Check flight-ready status:

1. Check flight battery voltage (on-board voltmeter and telemetry):

a) Replace or charge flight battery if motor-off voltage is below 15.8 volts.

2. Check video downlink and telemetry signal quality:

a) Ensure GPS has at least 4 satellites locked.

b) Ensure displayed AGL altitude is <2 feet.

c) Ensure distance from “home” is <2 feet.

3. Check RC signal status by operating the camera gimbal pitch control.

4. Check for solid-green LED on flight controller (indicating ready to arm).

5. If using PC telemetry, check status on PC ground station.

6. Prior to the first flight of the day, perform a range-check of the RC system.

IV. Arming the UAS

1. Place the UAS on the ground at the “home” location (where it will return if a fail-safe 

mode is enacted). This location must be a level surface at least 20 feet from any 

obstacle.

2. Make sure that the throttle control on the RC transmitter is in the “off” position.

3. Press and hold the arm button on the UAS until the arm LED turns on solid and the 

UAS emits a “ramping” tone.

4. With the throttle control at minimum, move the rudder (yaw) control to its full right 

position and hold for 5 seconds. When the UAS emits another long tone, the aircraft 

will be armed and ready to fly. If the throttle channel is held at idle (off) for more than 

15 seconds, the UAS will automatically disarm.
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V. Commencing Flight

1. After arming, raise the throttle channel to about 10% to start the motors. Ensure that 

all motors are running.

2. Check telemetry voltage to make sure that the flight battery is holding its charge 

under the minimal load.

3. While still in Stabilize flight mode, increase the throttle channel to about 50%, 

enough to lift the UAS into the air. Ensure that the UAS is able to maintain a stable 

hover without significant flight control input or trim.

4. Exercise all flight controls and ensure that the UAS responds appropriately.

5. Conduct the flight mission.