Electronic Submission

March 3, 2016 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE

Washington, DC 20590 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein 

referred to as FMRA) and 14 CFR Part 11, Mr. Russell Burdge hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial 

operation of UAS for the acquisition of aerial data, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by 

the FAA. 

As detailed in this document and the attached Appendix of UAS, the requested exemption 

would permit the operation of UAS platforms previously approved by the FAA for 

commercial operations in the United States. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s responsibilities to “...establish 

requirements for the safe operation of such aircraft systems in the national airspace

system.” Section 333(c) Reform Act. 

The name and address of the applicant is: 

Mr. Russell Burdge 

1568 Meadowbrook Court 

Niceville, Florida 32578 

Tel: 850-585-1431 

Email: russburdge@gmail.com 
Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23(b) 

14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 

14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) & (b) 

AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes exempting civil aircraft, as the term is defined under §40101 

of the Act, including UAS, from the requirement that all civil aircraft must have a current

airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections §44702-44716 of this title if the

Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 

USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1). 

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may 

operate in the national airspace system without creating a hazard to the user, the public, 

or a threat to national security. In making this determination, the Secretary must consider: 

 The UAS’ size, weight, speed and operational capability; 

 Whether the UAS operates within the visual line of sight of the operator; 

 Whether the UAS operates outside of highly populated areas and away from close

proximity to airports. 

Reform Act 333(a). If the Secretary determines that a UAS “may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system.” Id. 333(c). 
BACKGROUND ON RUSSELL BURDGE

Russell Burdge provides high quality imagery and data that can be used independently or 

in the case of surveying and modelling, can be combined to produce precision digital 

point clouds, triangle models, and contour maps of the surveyed area. Applications for 

the UAS include, but are not limited to: 

 Environmental monitoring 

 Real Estate and Construction Inspection 

 Inspection, remote sensing and aerial survey of civil infrastructure 

 Transportation planning studies 

 Forestry and agriculture 

Mr. Burdge’s use of the UAS for these inspection and surveying applications reduces the 

need to operate conventional aircraft, providing data more safely, quickly, accurately, 

economically, and with reduced impacts to public health and the environment. 

Mr. Burdge believes in a risk-based and technology agnostic approach to operations in 

the national airspace. Approval for any operation should be based on an analysis of 

the specific risks associated with the fully integrated solution, rather than the 

individual components. 

UAS AND OPERATIONAL DESCRIPTION

Mr. Burdge seeks to commercially operate a UAS weighing less than 55 pounds 

including payload in the United States for the purpose of acquiring aerial data. The

Appendix attached to this exemption petition lists the aircraft that Mr. Burdge 

contemplates operating. In prior, similar exemptions the Secretary has approved every 

UAS platform included in the Appendix. 

As the operator of these aircraft, Mr. Burdge is committed to the following conditions 

and limitations on its operations. Mr. Burdge understands that failure to comply will be 

grounds for the immediate suspension or rescission any exemption granted. 

1. Operations are limited to the UAS listed in the Appendix when weighing less than 

55 pounds including payload. 

2. Operations for the purpose of closed-set motion picture and television filming are

not contemplated. 

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per 

hour). In no case will the aircraft be operated at airspeeds greater than the

maximum aircraft operating airspeed recommended by the aircraft manufacturer. 
4. The aircraft will be operated at an altitude of no more than 400 feet above ground 

level (AGL). Altitude must be reported in feet AGL. 

5. The aircraft will 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 U.S. 

driver’s license. 

6. All operations will utilize a visual observer (VO). The aircraft will be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. 

7. All operating documents needed to operate the UAS and will be accessible during 

UAS operations and made available to the Administrator upon request. The

operator will also present updated and revised documents if it petitions for 

extension or amendment. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

will undergo a functional test flight prior to conducting further operations. 

9. Mr. Burdge is responsible for maintaining and inspecting the UAS to ensure that 

it is in a condition for safe operation. 

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the

UAS is in a condition for safe flight. 

11. Mr. Burdge will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption will comply with all manufacturer 

safety bulletins. 

13. The PIC will hold a UAS flight training certificate, in some cases training directly 

from the aircraft manufacturer, and a valid U.S. driver’s license issued by a state, 

the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

government. 

14. Measure will not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will

be operated to acquire aerial data, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). Measure will operate flights for the purposes 
of training Measure PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC’s ability to safely operate the UAS. 

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

16. The aircraft 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, unless a letter of agreement with 

that airport’s management is obtained or otherwise permitted by a COA. 

17. The aircraft will 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. 

18. If the UAS loses communications or loses its GPS signal, the aircraft will return 

to a pre-determined location. 

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power or fuel for the

aircraft to conduct the intended operation and to operate after that for at least five

minutes or with the reserve power or fuel recommended by the manufacturer if 

greater. 

21. All operations shall be conducted in accordance with an ATO-issued COA if the

blanket COA does not cover the intended operation. 

22. All aircraft operated will 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 will be as large as 

practicable. 

23. Documents used by Mr. Burdge to ensure the safe operation and flight of the 

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating. 

24. The aircraft will remain clear and give way to all manned aviation operations and 

activities at all times. 
25. The UAS may be operated by the PIC from a moving device or vehicle; however, 

specific requests will be made via subsequent COA. 

26. All flight operations will 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 aircraft or debris in the event of an accident; or 

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

permission for operating closer to those objects and the PIC has made an

assessment of the risk of operating closer to those objects and determined that it

does not present an undue hazard. 

27. The PIC, VO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption. 

28. All operations conducted over private or controlled-access property will be

conducted with the 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. 

29. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will 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. 
DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates 

Subpart H, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR §91.203(a)(1). Given the size and limited operating area

associated with the aircraft to be utilized by Mr. Burdge, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 USC §44701(f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed, will be at least as safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

14 CFR 45.23(b): Marking of the aircraft 

This regulation requires that certain experimental, provisionally certified aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high 

“limited”, “restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance

to a cabin, cockpit or pilot station. Even though the UAS will have no airworthiness 

certificate, an exemption may be needed as the UAS will have no entrance to the cabin, 

cockpit or pilot station on which the word “Experimental” can be placed. Given the size

of the UAS, 2 inch lettering may be impossible. Measure will mark the UAS as 

practicable. 

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the

UAS will not carry a pilot or passengers, the proposed operations can achieve the

equivalent level of safety of current operations by requiring the pilot operating the

aircraft to have completed a UAS flight-training course. Unlike a conventional aircraft

that carries the pilot and passengers, the UAS is remotely controlled. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in 

advance. The risks associated with the operation of the UAS are so diminished from the

level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the UAS as requested exceeds the present level of 

safety achieved by 14 CFR 61.113(a) and (b). 
14 CFR 91.7(a): Civil aircraft airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft Mr. 

Burdge contemplates operating, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the aircraft and the 

operational restrictions put on the aircraft, an equivalent level of safety will be provided. 

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 

The UAS, given its size and configuration has no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no 

room or capacity to carry such an item on the aircraft. The equivalent level of safety will

be maintained by keeping the Operating Manuals at the ground control point where the

pilot flying the UAS will have immediate access to it. 

14 CFR 91.103: Preflight action 

This regulation requires each pilot in command take certain actions before flight to 

ensure the safety of flight. An exemption is needed from this requirement, as the pilot

will take separate preflight actions, including checking for weather conditions, checking 

flight battery or fuel requirements, checking takeoff and landing distances, and all other 

actions in the Operating Manual and safety checklists. These actions will provide an 

equivalent level of safety. 

14 CFR 91.109: Flight instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. By design, UAS do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via

radio communications. The equivalent level of safety is provided by the fact that neither a

pilot nor passengers will be carried in the aircraft, the ability to control the UAS via radio 

signals from the controller and by the size and speed of the aircraft. 

14 CFR 91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will

never operate at altitude higher than 400 AGL and all operations will occur during 

daylight hours under Visual Meteorological Conditions (VMC) only. 
The equivalent level of safety will be achieved given the size, weight and speed of the

UAS as well as the location where it is operated. No flight will be taken without the

permission of the property owner. Because advance notice to the property owner and any 

onsite personnel, as well as the precautions outlined below, all affected individuals will

be aware of the planned flight operations. 

Flight operations will be conducted at least 500 feet from all non-participating persons 

(persons other than the pilot in command (PIC) or visual observer (VO)), vessels, 

vehicles and structures, unless operations do not present an undue hazard. 

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will

be conducted at least 5 miles from an airport. The PIC or VO will provide notification to 

the local Flight Standards District Office and airport controller of all operations within 5 

miles of an airport. The FAA will have advance notice of all operations through the filing 

of notices-to-airmen. 

Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS 

proposed herein, any risk associated with our operations is far less than those presently 

presented with helicopters and other conventional aircraft operating at or below 500 feet

AGL. In addition, the low-altitude operations of the UAS will ensure separation between 

these UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 CFR 91.121: Altimeter Settings 

This regulation requires each person operating the aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the UAS may not have a

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the PIC confirming the altitude of the

launch site shown on the GPS altitude indicator before flight. 

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions 

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. 

Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of 

the UAS during daylight hours in visual flight rules (VFR) conditions to continue until 

90 percent of remaining battery power or fuel reserves remain. Mr. Burdge seeks the

requested relief because without an exemption from Section 91.151(a)(1), the flight time

duration of the selected aircraft will be reduced and severely constrain the practicality of 

any aerial acquisition of data that Mr. Burdge proposes to conduct pursuant to this 

Petition. 
10

The technical specifications of the proposed UAS, their Operations Manuals, and Mr. 

Burdge’s proposed operating limitations, ensure that Mr. Burdge will safely operate 

the selected aircraft during daylight hours in VFR conditions until 90 percent of 

remaining battery power or fuel reserves remain. 

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration 

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. 

Therefore, there is no ability or place to carry certification and registration documents or 

to display them on the UAS. An equivalent level of safety will be achieved by keeping 

these documents at the ground control point where the pilot flying the UAS will have

immediate access to them, to the extent they are applicable to the UAS. 

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections 

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Mr. Burdge. Maintenance will be 

accomplished pursuant to the User Guide or Operating Manual. An equivalent level of 

safety will be achieved because the UAS i s limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise, the UAS can land immediately and will be operating from no higher than 

400 feet AGL. The PIC will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance and keep a log of any maintenance 

performed. Moreover, the PIC is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. 

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition 

of data enhances safety while reducing risk. Manned aircraft in certain application such 

as pipeline monitoring create a greater risk because the aircraft are much larger and carry 

an onboard human pilot. In contrast, a UAS weighing 55 pounds or less will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights. In addition, additional streams of aerial data will allow large

commercial entities to make decisions about how to best deploy ground resources and 

ensure the safety and cost-effectiveness of their operations. 
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EQUIVALENT LEVEL OF SAFETY

Mr. Burdge proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate within the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current and proposed regulatory structure. 

PRIVACY

All flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge. Images or video taken of individuals will have consented to 

being filmed or otherwise they will be made anonymous. 

NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which 

they will operate, our petition presents no national security issue. 

FEDERAL REGISTER SUMMARY

Docket No.: No. FAA-2016- ___________ 

Petitioner: Mr. Burdge 

Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of 

Title 14, Code of the Federal Regulations (14 CFR). 

Description of Relief Sought: Mr. Burdge is seeking an exemption to conduct 

commercial acquisition of aerial data using unmanned aircraft systems. 

Based upon the foregoing, Mr. Burdge requests that the FAA grant it the necessary 

exemptions under Section 333 of the FAA Reform Act as requested herein to allow for 

commercial operations of UAS within the United States. 

Sincerely, 

Russell Burdge 

1568 Meadowbrook Court 

Niceville, Florida 32578 

850-585-1431 
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APPENDIX A 

UAS DESCRIPTION 

The following UAS to be used is as follows but not limited to providing they are within 

the scope of the exemption granted by the FAA. Mr. Burdge may update or revise the 

operating documents. It is the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator or any law enforcement 

official upon request. Mr. Burdge must also present updated and revised documents if it 

petitions for extension or amendment to this grant of exemption. If Mr. Burdge 

determines that any update or revision would affect the basis upon which the FAA 

granted this exemption, then Mr. Burdge must petition for an amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operating documents. 

Parrot Bebop 2 

Width: 382 mm 

Length: 328 mm 

Height: 89 mm 

Cruise Speed: 10 m/s 

Approx. Max Air Speed: 18 m/s 

Minimum Airspeed: 0 m/s 

Maximum Range: 1.2 miles / 0.8 km 

Multi-Rotor Weight w/ battery: 500 g 

Payload Capacity: Not designed for payload, total weight is 500 g 

Maximum Take-off Weight: 500 g 

Autonomous capabilities: Auto-Return to Home if lost communications or lost data link; 

Auto-Loiter, Auto-Landing, Emergency Auto-Landing if Low Power Emergency 

Maximum Wind Speed: 38 mph 

Normal Flight Time: 25 minutes 
13

Power Source: 

Lithium polymer or Lithium ion batteries. Charging of batteries can be completed via: 

standard wall outlet, direct connection to vehicle battery, or via the vehicle’s cigarette 

lighter. 

Propulsion System: 

The UAS described herein is powered by electric direct drive brushless DC motors. 

Autonomous Flight: 

The key element of the UAS described herein is the system’s autopilot which 

automatically compensates for wind versus relying on the operator’s sense of feel for 

what the impact of the wind is at launch or at the altitude the system is flying. All flight 

operations are GPS and autopilot controlled making the system extremely easy to 

operate and navigate. The autopilot serves in a “cruise control” like manner limiting the 

operator from placing the UAS described herein in an unusual attitude while 

maintaining desired altitude. At any point if the signal between the Ground Control 

Station (GCS) and the aircraft is lost, the aircraft will return to the designated home 

station and loiter or land as preprogrammed. 

Landing styles/types – Aided or Autonomous: 

In “Aided” landing mode the autopilot continues to assist the pilot in maintaining 

altitude and stability as the pilot controls the UAS to the desired landing location. 

In “Autonomous” Landing mode without human intervention, the UAS autopilot can 

land the aircraft consistently within a narrow and limited landing area, even in 

crosswinds. The autopilot intelligently manages the landing pattern and glideslope to 

minimize overshoot or undershoot. If signal is lost and cannot be reestablished for some 

reason, the autopilot will initially return to home location and loiter. 

Onboard Flight Instruments: 

The UAS described herein are equipped with an Inertial Navigation System (3axis 

gyroscope, 3axis magnetometer, GPS receiver, and static pressure sensor and secure 

radio link to the operator). 

Onboard Computer Systems: 

The UAS described herein are equipped with onboard computer systems to monitor, 

control, and communicate the essential fight status to the PIC and VO. 

Frequency Allocations: 

2.4 GHz OR 5.8 GHz 
14

Navigation System: 

Specific maps can be downloaded to the display screen (such as air sectional and 

geographic maps) which are overlaid with GPS positional data. Waypoints can be 

created before and during flight operations, thus creating specific locations and flight 

sequences for the aircraft. During flight waypoints can be clicked and dragged to 

change their location and/or altitude. 

Command and Control Systems: 

All missions will be flown in using a handheld radio transmitter in conjunction with 

ground control station (GSC) computers providing PIC and VO all of the essential 

flight data via telemetry from the UAS at least once per second. 

GCS Data Displayed: 

 UAS Barometric Altitude 

 UAS Bearing 

 UAS Heading 

 UAS Ground Speed 

 UAS Climb Rate 

 UAS Flight Time 

 UAS Data Link Quality 

 UAS Position 

 GPS Number of Satellites 

 UAS Battery Level 

 Altitude 

 Local Time 

 Direction to Home 

 Active Flight Mode 

 UAS Status 

 Pitch/Roll/Yaw Horizon 

Emergency Procedures and System Failures: 

Sensor Failure- Failure of onboard flight instruments/sensors will degrade the UAS 

performance and will result in either a fatal critical response or a non-fatal critical 

response, depending on the nature and severity. If the UAS becomes unstable due to 

sensor failure, this may result in loss of performance or features but still allow for stable 

Pilot in Command flight, an automated landing or in extreme cases a fatal response. 

Motor Failure- This will cause a fatal response in the UAS flight performance if one or 
15

more motors fails. 

Airframe Failure- Depending on the nature and severity, this may result in decreased 

flight performance or a fatal response. 

Navigation System Failure- In a navigation system failure, degraded GPS will result 

in a response warning to the pilot where-by the system would be flown in manual mode. 

This will result in degraded GPS position performance, manual Pilot in Command flight 

will not be effected. 

Power Failure - A complete battery failure which results in power loss to the UAS will 

result in a fatal response. 

Low Battery Condition - Operator will be alerted of a low battery condition and will 

land the UAS as soon as able. 

Critical Battery Condition - Operator will be alerted of a Critical low battery 

condition and will land the UAS as soon as able, the UAS will begin to descend at a 

controlled rate. 

Line of Sight Loss - All flight operations will be conducted with the UAS within visual 

sight of the pilot. If the pilot's view becomes obstructed and line of sight is lost, the 

pilot may instruct the 

UAS to hover in place until line of sight is re-established, to return to the takeoff 

position, or to land at the current position. 

Security - The system and communication links are encrypted by the manufacturer's 

proprietary software.