### 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 Re quest 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 grow ing 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 sh are 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 sp ent 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 th e 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 f irst 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 establi shments, 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 fl ying 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 L egal V ideo S ervices, I nc. , I request the exempti ons 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 O lio Road

Noblesville IN 46060

Private Pilot

– Single Engine Land (Certificate # available on request )

Current 3 rd 

### 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, I N 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 1 5 , 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 Cons truction and Performance Manual

3) Appendix C

– LVSI sUAS Flight Operations Manual

References:

1) FAA Exemption No. 11405, Regulator y 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

petiti on 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 airsp ace system as compared to a manned aircraft.

Op erations 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 he rein 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) : T he petitioner requests relief in order to allow pilots who hold a PR IVATE 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 s imilar fashion to the previously granted exemptions.

91.119 (b) & (c) : A s discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer
than 500 feet to the ground may require that the s UA S be operated closer tha n 500 feet to essential

person s 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 structure s 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 re quest 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 s UAS does not

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

information (AGL an d 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 s UAS specific relief has been granted in Exemption Nos.
8811, 10808, and 10673 for daytime, VFR conditions. The s UAS provides battery power remaining as a
percentage to the PIC on the ground stati on 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 petitio ner, 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 m aximum 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 in ches (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 onboar d 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 t he 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 limite d 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 befor e 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 ha s 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 simil ar 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 withou t 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 reduc e 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/photo graphy. 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 increase d 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 availabl e to FAA for use in collecting data regarding the use of

s UAS 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,
pho togrammetry, 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 sU A S . The petitioner’s market r esearch 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
compl iance. 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 3 rd 

### 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 sec tions 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 5kt s 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 flight s will be less than 15 minutes in duration, and since the p ilot 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 extensiv e experience in complex electronic systems, the pe titioner 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, t he 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 contr ollers (situated under the propellers ) to facilitate enhanced airflow and cooling , and to distance high frequency electrical switching “noise” from the compute rized 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 co nfiguration for easy transportation.



### Figure 1

- LVSI Tarot 680Pro System

### Petition for Exemption Page 7 

## LVSI Tarot 680Pro S pecifications:

Frame:

Frame d iameter (motor center to center): 26.75 inches (680mm) Total diameter (with propellers): 38.75 inch es (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 motor s ( 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 f light 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 modu le Minim OSD 2.4
Video transmission/t elemetry 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 stat ion 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

w hose video output is fed to radio

- frequency video downlink . The video image is sent via radio frequency transmission to a ground stat ion 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 image s 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 r emaining > (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 mu lti

- 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 2 C 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 t o 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 avail able:

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 t his 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 (UA S )

.

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 limitation s 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, a ny pilot in command (PIC) of commercial UA S missions must adhere to the following conditions and limitations:

1. T he UA S will be operated with a flying weight not to exceed 55 pounds including payload.

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

.

3. The UA S must be operated at an altitude of no more than 400 feet above gr ound level (AGL).

4. The UA S 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 FA A

- issued airman medical certificate or U.S. driver’s

license.

5. All commercial operations must utilize a visual observer (VO). The UA S 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

comm unicate 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 V O 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 UA S and conduct its operations in accordance with the

conditions and limitations are hereinaf ter referred to as the operating documents. The operating documents must be accessible during commercial UA S operations and made available to the

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

documents , unless those procedures are superseded by FAA exemption documents

.

7. Any UA S that has undergone maintenance or alterations that affect the UA S operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight p rior 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 UA S 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

con dition 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 f rom 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, r ecreational, 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 whi ch 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 pers ons, 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 UA S with appropriate distance from nonparticipants in accordance with 14 C FR 91.119.

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

m ust be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

15. The UA S may not opera te 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 cha rt, 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 r equest.

16. The UA S 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 UA S must return to a p re

determined 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

conditi ons) there is enough available power for the UA S 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 o perated in accordance with these oper ating 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 ope rator 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

availabl e to the FAA or any law enforcement official upon request.

22. The UA S 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 operatio ns 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

UA S 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 ensuri ng 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 object s 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

th e 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 pu rpose 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 manu al (MPTOM) as

documented in the grant of exemption.

28. A t 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 notificati on 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 a nd 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 producti on 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, a s specified in the exemption holder’s

MPTO M.

### Petition for Exemption Page 14 

## 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 thei r 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 scr ews.

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 requ ired for the subsequent flight session.

b) If the subsequent flight session is to include autonomous flight operations, create the flight plan using MissionPlann er software on the PC

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

II. Powering up the sUAS:

### Petition for Exemption Page 15 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 l ocked.

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, c heck 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 t hrottle 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.

### Petition for Exemption Page 16 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

hov er without significant flight control input or trim.

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

5. Conduct the flight mission.