April 24, 2015

 Exemption No. 11422

 Regulatory Docket No. FAA–2015–0154

Mr. Michael J. Murphy

CEO

Soar Environmental Consulting, Inc.

1802 North Magnolia Avenue

Clovis, CA 93619

Dear Mr. Murphy:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter dated January 21, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Soar Environmental Consulting, Inc. (hereinafter petitioner or operator) for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct inspections of hydroelectric system assets, specifically remote penstocks, 

flow lines, dams, and reservoirs; remote or impassable section of natural gas and/or oil 

pipelines; and bridges supporting gas and oil pipelines.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.
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Airworthiness Certification

The UAS proposed by the petitioner is a Rotomotion SR–15.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Soar Environmental Consulting, Inc. is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed below.
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Conditions and Limitations

In this grant of exemption, Soar Environmental Consulting, Inc. is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Rotomotion SR–15

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

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

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

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

5. The UA must be operated within visual line of sight (VLOS) of the 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.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. 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.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

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

Administrator upon request. If a discrepancy exists between the conditions and 
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limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its 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. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator 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.

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, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

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.

9. The operator 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 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.

11. The operator must 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 must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a 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. 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 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may 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 under this exemption, 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 operated 

under this exemption are permitted under the terms of this exemption. 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 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

16. The UA 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 exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA 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.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption 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.

23. 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 Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. 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 UA 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 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 under this exemption.

27. 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.

28. 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.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

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

as documented in this grant of exemption.

30. 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.

31. 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.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
January 21, 2015

Petition for Exemption under §333 of the FAA Modernization and Reform Act of 2012

Soar Environmental Consulting, Inc. 

The Honorable Mr. Anthony Foxx

United States Secretary of Transportation

1200 New Jersey Ave, SE

Washington DC, 20590

Re: Exemption Request under §333 of the FAA Modernization and Reform Act of 2012 

(Public Law 112-95) from 14 CFR 21; 14 CFR 36, 45.23; 45.27, 45.29; 61.113; 91.9(b) 

(2); 91.103(b); 119(c); 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2);

91.417(a)&(b)

Dear Mr. Secretary,

In accordance with §333(c) of the Federal Aviation Administration Modernization and Reform 

Act of 2012, Soar Environmental Consulting, Inc. is requesting permission to use its Rotomotion 

SR-15 Unmanned Aircraft System (UAS) to perform inspections of hydroelectric system assets, 

specifically remote penstocks, flow lines, dams, and reservoirs; remote or impassable sections 

of natural gas and/or oil pipelines; and bridges supporting gas and/oil pipelines. This letter 

contains an explanation of how these exemptions are in the public interest and maintain at least 

an equal level of safety to existing regulations, as well as documentation pertaining to the 

waiver requests as per 14 CFR Part 11. Additionally, this letter includes an attachment with the 

UAS Operations Guide delineating the operations, procedures, and operating system of the SR15 UAS.

Soar Environmental Consulting, Inc. is focused on public safety while supporting companies in 

meeting extant and forthcoming regulatory compliance measures associated with the operation 

and maintenance of hydroelectric and natural gas pipeline projects. Soar Environmental 

Consulting personnel have over 20 years of direct field and management experience with 

penstock and pipeline inspections, regulatory requirements, and compliance management. Not 

only does our company provide solutions through the use of environmental consulting, auditing 

and management services, but we also have the distinct advantage of having a working 

knowledge within the utility industries, understand endemic inspection requirements, and know 

the requirements for conducting work in remote locations.

Soar Environmental Consulting would like incorporate UAS technology coupled with qualified 

pilots into our commercial portfolio. Our proposal to meet inspection requirements of the 

hydroelectric and natural gas pipeline industry through UAS operation is directly correlated to 

the remote locale, the complex regulatory structure, and the safety risks associated with the 

current practice of operating and maintaining these assets. Our UAS inspection operations will 

be in the best interest of the public, providing a safer alternative to the extant potentially 

dangerous task of inspecting in remote or inaccessible areas. Soar will be responsible for 

Soar Environmental Consulting, Inc. 

1802 N Magnolia Ave, Clovis, CA 93619

Tel 559.547.8884

soar@soarhere.com

www.soarhere.com

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ensuring compliance with applicable Federal Aviation Administration (FAA) and International 

Civil Aviation Organization (ICAO) regulations in relation to this operation and Best

Management Practices will be implemented for regulations that are not applicable to this 

operation. 

Performing aerial inspections utilizing an unmanned system is a benefit to the public interest in 

multiple ways:

1. Personnel Safety

a. Capital assets, such as penstocks, dams, pipelines, and bridges often times span 

over areas where terrain is unstable, vertical, or simply too dangerous for foot 

travel. Field inspections leave employees vulnerable to environmental hazards 

such as snow and ice accumulation, stream crossing, seasonal water runoff, 

felled trees and blocked paths; biological hazards, such as poison ivy, snakes, 

and natural predators; and extreme temperature changes which may cause

altitude sickness, heat stroke or frost bite. The utilization of our UAV will ensure 

access to these areas while minimizing risk of serious injury or issue to personnel 

assigned to conduct these inspections. 

2. Access to remote or impassable areas

a. Segments of penstocks, dams, pipelines, and bridges may currently be or 

become unreachable, partially obscured, or impracticable for inspection by 

conventional means, such as physically walking the line, or utilizing airplane or 

helicopters for inspections. Access to assets can also be partially or completely 

blocked by environmental singularities, such as storm events, snow loading, 

felled trees, or vegetation growth, or blocked by mechanical means such as 

vehicle accidents, new construction, or road maintenance. The use of our UAV 

will ensure access to remote or impassable areas on an as-needed basis as well 

as during or after uncontrolled singular events. 

3. Ensure regulatory requirements are actualized

a. Regulatory requirements, including but not limited to those enforced by the 

Federal Energy Regulatory Commission, Department of Transportation’s Office 

of Pipeline Safety, the California Public Utilities Commission and/or other federal, 

state and county agencies in general mandate that public entities and private 

corporations maintain and inspect the aforementioned assets on a periodic basis 

to ensure public safety and proper operation. As discussed, some of these 

assets are currently unreachable, partially obscured, or impracticable for 

inspection by conventional means, such as physically walking the line, or utilizing

airplane or helicopters for inspections. The use of a UAV to conduct these 

inspections will supplement extensive, comprehensive maintenance programs

where needed and will ensure regulatory compliance measures are fully 

actualized, which in turn reinforces public safety standards and adherence to 

extant and forthcoming regulatory requirements. 

4. Cost Effectiveness

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Petition for Exemption under §333 of the FAA Modernization and Reform Act of 2012

Soar Environmental Consulting, Inc.

Soar Environmental Consulting, Inc. requests an exemption under Section 333 of the FAA 

Modernization and Reform Act of 2012 for commercial flight of its Rotomotion SR-15 UAS. Soar 

Environmental Consulting, Inc. is a Disabled Veteran Business Enterprise (DVBE) small 

business located in Clovis, California. Soar Environmental Consulting provides environmental 

consulting, regulatory compliance management solutions, and inspection services to 

commercial and government operations. With approval of this petition, Soar Environmental 

Consulting will utilize our UAS to perform inspections of hydroelectric system assets, specifically 

remote penstocks, flow lines, dams, and reservoirs; remote or impassable sections of natural 

gas and/or oil pipelines; and bridges supporting gas and/oil pipelines. Proposed operations will 

be performed in full compliance with aviation safety regulations, maintained at or below 400 feet 

AGL and in Line-of-sight with the Pilot-in-Command (PIC). As per 14 CFR §11.81, this petition 

for exemption is prepared and filed in accordance with regulation to request exemptions from 

the Federal Aviation Regulations pertaining to operation of a UAS so that operations can be 

commercially completed in accordance to all applicable FARs that would pertain to a small UAS. 

Specifically, 14 CFR §11.81 states:

“You must include the following information in your petition for an exemption and submit 

it to FAA as soon as you know you need an exemption. 

(a) Your name and mailing address and, if you wish, other contact information 

such as a fax number, telephone number, or e-mail address; 

(b) The specific section or sections of 14 CFR from which you seek an 

exemption; 

(c) The extent of relief you seek, and the reason you seek the relief; 

(d) The reasons why granting your request would be in the public interest; that is, 

how it would benefit the public as a whole; 

(e) The reasons why granting the exemption would not adversely affect safety, or 

how the exemption would provide a level of safety at least equal to that provided 

by the rule from which you seek the exemption; 

(f) A summary we can publish in the FEDERAL REGISTER, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

(g) Any additional information, views or arguments available to support your 

request; and 

(h) If you want to exercise the privileges of your exemption outside the United 

States, the reason why you need to do so.”

IAW 14 CFR §11.81, Soar Environmental Consulting, Inc. submits the following information: 

(a) Name and mailing address

I. Michael J. Murphy

1802 N Magnolia Ave

Clovis, Ca 93619

559.547.8884

mjmurphy@soarhere.com

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(b) The specific section or sections of 14 CFR from which exemption is sought

I. 14 CFR 21

II. 14 CFR 36 

III. 14 CFR 45.23, 45.27

IV. 14 CFR 45.29

V. 14 CFR 61.113

VI. 14 CFR 91.9

VII. 14 CFR 91.103

VIII. 14 CFR 91.119

IX. 14 CFR 91.151

X. 14 CFR 91.203

XI. 14 CFR 91.405, 91.407, 91.409, 91.417

(c) The extent of relief sought is for the duration of the Grant of Exemption, unless otherwise 

specified. The reason to seek the relief is as follows:

I. 14 CFR 21

i. Soar Environmental Consulting, Inc. requests relief from 14 CFR part 21. The 

UAV is a small rotorcraft weighing less than 25 pounds during operation. The 

UAV maximum speed is 25mph and the operating area will be limited to 

remote or impassable locations where vehicular traffic is non-existent or 

controlled. The PIC will maintain VFR Rules and operate the UAV during the 

day, at or below 400 feet AGL and in line-of-sight so as not to create a hazard 

to users of the National Airspace System or the Public or pose a threat to 

national security. 

II. 14 CFR 36 

i. Soar Environmental Consulting requests relief from any associated noise 

certification and testing requirements of part 36. As a note, according to the 

manufacturer’s specifications, the UAV operates below 40db within 50 

meters. 

III. 14 CFR 45.23, 45.27

i. The UAV does not currently display marks consisting of the Roman capital 

letter “N” followed by the registration number of the aircraft in compliance with 

14 CFR 45.23 and 14 CFR 45.27. Soar Environmental Consulting will

register the UAV with the FAA and ensure UAV is marked as appropriate 

before using the UAV in the NAS for commercial purposes.

IV. 14 CFR 45.29

i. Soar Environmental Consulting request relief from the size requirements 

under this section due to the size limitations of the UAV. We propose to use 

marks as large as possible on the UAV as well as keep registration 

information with the PIC during operation. 

V. 14 CFR 61.113

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i. Soar Environmental Consulting, Inc. currently does not have commercial pilot 

licenses and requests relief from 14 CFR part 61.113 for a period not to 

extend one year from Grant of Exemption to acquire the appropriate 

commercial pilot licenses for any and all PICs operating the UAV. Soar 

Environmental Consulting, Inc. will require that all PICs hold a minimum of a 

Private Pilot License with a third class airman medical certificate for the one 

year exemption period. This one-year exemption will give pilots enough time 

to acquire the necessary hours and skills to become commercial pilots. We 

hope the FAA considers this exemption noting that these operations will be in 

remote areas with controlled or no access, that private pilots have parallel 

aeronautical knowledge requirements to those of commercial requirements,

and the additional manned airmanship experience of a commercially 

certificated pilot may not correlate to the airmanship skills necessary for 

operating a UAS.

VI. 14 CFR 91.9

i. Relevant materials shall be kept in a location accessible to the PIC in 

compliance with the regulations. 

VII. 14 CFR 91.103

i. In regards to 91.103(b), the UAV will not be operated within any Class B, C, 

or D airspace; but, the PIC will follow all other applicable pre-flight actions 

including reviewing weather, flight battery requirements, landings, and takeoff 

distances and aircraft performance data before initiation of flight. 

VIII. 14 CFR 91.119(c)

i. Soar Environmental Consulting requests relief from this section because the 

UAV will be operated below 400 feet AGL. The PIC will ensure the UAV is 

operated in controlled environments outside of populated areas away from 

public and traffic; avoiding of areas which are depicted in “yellow” on VFR 

charts, as well as obtaining and assessing information regarding congested 

areas from the local Flight Standards District Office (FSDO) and avoiding 

areas of congestion. The UAV will not be operated within 500 feet of vehicles 

or objects in open areas. Soar Environmental Consulting requests that if 

barriers or structures are present that can sufficiently protect nonparticipating 

persons from the UAV or debris in the event of an accident, the PIC may 

operate closer than 500 feet to persons afforded such protection. The 

operator will ensure that nonparticipating persons remain under such 

protection.

IX. 14 CFR 91.151

i. Soar Environmental Consulting requests exemption from this section due to 

the maximum flight time available from this UAV. The UAV total flight time is 

limited to 35 minutes and therefore the PIC would not be able to meet the 

minimum standards and still conduct the inspections. The UAS is equipped 

with a visual battery indicator that displays the battery levels at all time. 

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Additionally, the UAS has a visual alarm that indicates when the battery 

reaches a state of 20% battery life, or approximately 7 minutes of flight time. 

These indicators, coupled with pilot awareness and the emergency return-tostation setting will supply ample time to land the UAV safely in the event of 

low battery. 

X. 14 CFR 91.203

i. Soar Environmental Consulting requests relief from 14 CFR 91.203 as the 

appropriate airworthiness certificate does not exist for this UAS. Additionally, 

the certificate cannot be displayed in the aircraft due to the size and physical 

structure of the UAV. 

XI. 14 CFR 91.405, 407, 409, 417

i. Soar Environmental Consulting, Inc. requests relief from 14 CFR 91.405, 407, 

409, and 417 The above-cited regulations require, in general, aircraft owners 

and operators to inspect the aircraft “...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.” These regulations apply to aircraft with an Airworthiness Certificate. 

Therefore, these sections are not applicable to this UAS. Operators will 

adhere to requirements located within the operations manual. 

(d) The reasons why granting this request would be in the public interest; that is, how it would 

benefit the public as a whole

I. Personnel Safety

i. Capital assets, such as penstocks, dams, pipelines, and bridges often times 

span over areas where terrain is unstable, vertical, or simply too dangerous 

for foot travel. Field inspections leave employees vulnerable to 

environmental hazards such as snow and ice accumulation, stream crossing, 

seasonal water runoff, felled trees and blocked paths; biological hazards, 

such as poison ivy, snakes, and natural predators; and extreme temperature 

changes which may cause altitude sickness, heat stroke or frost bite. The 

utilization of our UAV will ensure access to these areas while minimizing risk 

of serious injury or issue to personnel assigned to conduct these inspections. 

II. Access to remote or impassable areas 

i. Segments of penstocks, dams, pipelines, and bridges may currently be or 

become unreachable, partially obscured, or impracticable for inspection by 

conventional means, such as physically walking the line, or utilizing airplane 

or helicopters for inspections. Access to assets can also be partially or 

completely blocked by environmental singularities, such as storm events, 

snow loading, felled trees, or vegetation growth, or blocked by mechanical 

means such as vehicle accidents, new construction, or road maintenance. 

The use of our UAV will ensure access to remote or impassable areas on an 

as-needed basis as well as during or after uncontrolled singular events. 

Additionally, many of the areas with hydroelectric or natural gas pipelines 

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transect regions that contain environmental sensitive flora and fauna. The 

use of our UAV for inspecting in these remote areas will limit potential 

environmental damage to sensitive, protected, threatened or endangered 

flora and fauna from foot traffic and could reduce the current necessary 

vegetation maintenance required to access sensitive areas that are dispersed 

throughout the projects. 

III. Ensure regulatory and public safety requirements are actualized

i. Regulatory requirements, including but not limited to those enforced by the 

Federal Energy Regulatory Commission, Department of Transportation’s 

Office of Pipeline Safety, the California Public Utilities Commission and/or 

other federal, state and county agencies, mandate that public entities and 

private corporations maintain and inspect the aforementioned assets on a 

periodic basis to ensure public safety and proper operation. Some of these 

assets are currently unreachable, partially obscured, or impracticable for 

inspection by conventional means, such as physically walking the line, or 

utilizing airplane or helicopters for inspections. This UAV carries a Sony 

FCB-EX980 High Resolution video camera with 26x zoom which will allow 

viewing and recording of assets for critical infrastructure evaluation, such as 

rust accumulation, cracks, leaks, concrete damage, spalling, paint condition, 

etc. The recording can then be reviewed by technical experts at any time and 

archived for future condition comparison and filed to meet regulatory 

requirements. The use of a UAV to conduct these inspections will 

supplement extensive, comprehensive maintenance programs where needed 

and will ensure regulatory compliance measures are fully actualized, which in 

turn reinforces public safety standards, confirms structures are up to code, 

and ensures adherence to extant and forthcoming regulatory requirements. 

IV. Cost Effectiveness

i. Currently, multiple personnel consisting of agency officials, employees and/or 

contractors are often required to conduct field inspections on large projects 

over vast amounts of terrain in order to ensure public safety and meet 

regulatory requirements. Inspections can require a substantial amount of 

person-hours and persist for days or weeks at a time due to terrain and 

accessibility issues. Factoring in engineering, planning & scheduling, safety 

meetings, mileage, recovered man-hours, potential down time due to injury, 

potential worker’s compensation savings, and the intangible consideration of 

keeping employees injury-free, the current system of inspecting these assets 

becomes cost-prohibitive. UAV inspections in select areas are timelier, safer 

and more efficient than the conventional methods for conducting these 

inspections. Our UAV inspections will free up otherwise occupied 

employees, and provide a more economic approach to the traditional 

inspection, thus lowering operational costs. Lower overhead for corporations 

could lead to end-user savings such as decreased utility bills.

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which the exemption is sought

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FAA 333 Exemption Petition
9

I. The UAV consists of a lightweight, battery powered rotocraft, a personal computerbased ground control station, and associated communications equipment. The 

rotocraft length is 47”, width of 16.5” and a height of 20.5” which can operate at a 

maximum speed of about 22 knots. The UAS is equipped with a visual battery 

indicator that displays the battery levels at all time. Pilots are trained to monitor the 

battery indication lights during flights. Additionally, the UAS has a visual alarm that 

indicates when the battery reaches a state of 20% battery life, or approximately 7

minutes of flight time. The UAS consists of an autonomous flight mode with pointand-click waypoints overlaid on a GPS map as well as a hand-held Spektrum DX-8 

controller. The PIC will primarily utilize the autonomous mode for flights; but, the 

Spektrum DX-8 controller will be at hand and available for emergency use. Also, the 

PIC can modify the flight plan of the UAV at any time using the flight management 

interface or by manual take-over via the Spektrum DX-8 controller. In autonomous 

mode, the PIC can instruct the UAV to hold position with the click of a button, or

return to the Home waypoint, The UAV has an emergency return to Home waypoint 

in the event of signal loss. 

II. The aircraft will be operated with both a PIC and a ground-based Visual Observer 

(VO) in accordance with FAA Policy N 8900.227 Section 14, Operational 

Requirements for UAS. All flights will occur at no more than 400 feet above ground 

level (AGL); operations will be conducted in remote or inaccessible regions with the 

permission of the land owner; and all required permits will be obtained from state and 

local government before operation. The UAV will not be operated within 500 feet of 

vehicles or objects in open areas, unless barriers or structures are present that can 

sufficiently protect nonparticipating persons from the UAV or debris in the event of an 

accident. The PIC will file a Notice to Airmen (NOTAM) providing location and a 

date/time for each operation and a VFR Flight Following, if necessary. 

III. The aircraft will not be operated over urban or populated areas; at air shows or over 

an open-air assembly of people; over heavily trafficked roads; or within 5 nautical 

miles of an airport or heliport. Flight operations will be limited to day, visual 

meteorological conditions and the aircraft will remain within visual line of sight of the 

PIC at all times. 

IV. This exemption will provide a greater level of safety to that provided by the rule from 

which the exemption is sought due to the current nature of conducting inspections in 

remote regions. Because UAS flights are not currently authorized for commercial 

use, methods for inspecting remote assets are limited to pedestrian or helicopter 

operations. Where helicopter operations are not feasible due to environmental or

mechanical obstructions, deep canyons, steep montane regions or closeness of 

objects, utilizing the UAV will provide a safe alternative to the inherent dangers of 

walking through these regions to conduct the required inspections. The small size, 

extreme maneuverability and zoom capabilities on the camera allow for a safe, 

unimpeded inspection of critical infrastructure assets. A universal example of 

application would be monitoring the downstream face of a large concrete dam for 

cracking or block movement. As one may envision, walking up the face of a 

concrete dam is extremely dangerous, if at all possible, and dropping a helicopter 

into a steep canyon is also an extreme risk. However, utilizing our UAV in this 

instance would keep everyone safe, meet regulatory requirements and provide a 

necessary, desirable and more accurate depiction of the dam condition. Conducting 

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FAA 333 Exemption Petition
10

inspections such as these are in the public interest, provide a safer alternative, and 

produce more accurate data for engineering evaluation. 

(f) Summary to publish in the Federal Register 

I. The rule from which exemption is sought

i. Soar Environmental Consulting, Inc. seeks exemption under §333 of the FAA 

Modernization and Reform Act of 2012 (Public Law 112-95) from 14 CFR 21; 

14 CFR 36, 45.23; 45.27, 45.29; 61.113; 91.9(b) (2); 91.103(b); 119(c); 

91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b)

II. A brief description of the nature of the exemption sought

i. Soar Environmental Consulting, Inc. requests an exemption under Section 

333 of the FAA Modernization and Reform Act of 2012 for commercial flight 

of its Rotomotion SR-15 UAS. Soar Environmental Consulting, Inc. is a 

Disabled Veteran Business Enterprise (DVBE) small business located in 

Clovis, California. Soar Environmental Consulting provides environmental 

consulting, regulatory compliance management solutions, and inspection 

services to commercial and government operations. With approval of this 

petition, Soar Environmental Consulting will utilize our UAS to perform 

inspections of hydroelectric system assets, specifically remote penstocks, 

flow lines, dams, and reservoirs; remote or impassable sections of natural 

gas and/or oil pipelines; and bridges supporting gas and/oil pipelines. 

Proposed operations will be performed in full compliance with aviation safety 

regulations, maintained at or below 400 feet AGL and in Line-of-sight with the 

Pilot-in-Command (PIC). As per 14 CFR §11.81, this petition for exemption is 

prepared and filed in accordance with regulation to request exemptions from 

the Federal Aviation Regulations pertaining to operation of a UAS so that 

operations can be commercially completed in accordance to all applicable 

FARs that would pertain to a small UAS. 

(g) Any additional information, views or arguments available to support request

I. We here at Soar Environmental Consulting are requesting this exemption because 

we strongly believe in the continuous improvement of safety measures that offer to 

protect our field personnel from the inherent dangers of the work environment, while 

striving to exceed regulatory compliance standards set forth for the safe and practical 

operation and maintenance of our hydroelectric and natural gas pipelines. The use 

of Unmanned Aircraft Systems affords us a great opportunity to reach both of these 

goals. Through adopting and utilizing UAS technological advancements within these 

fields, we are unlocking the potential to create a safer workplace for our loved ones,

ensure regulatory requirements are exceeded, and build inspection data with which 

we can improve and protect the infrastructure of these crucial industries. We look 

forward to working with the FAA in meeting and exceeding these goals in the near 

future. 

(h) Request to exercise the privileges of this exemption outside the United States

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SOAR ENVIRONMENTAL CONSULTING DEPARTMENT ORDER SEC-04

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Revision 0

Soar Environmental Consulting

UAS Operations Manual

I. Purpose

a. This Department Order addresses the safe handling and operations of the 

Rotomotion SR-15 Unmanned Aircraft System (UAS) to perform flight operations 

during inspections of structures and other assets. This UAS Operations Manual 

contains instruction and explanation on correct and safe operating procedures 

within the National Airspace System as required by the Federal Aviation 

Administration.

II. Scope

a. The scope of this order applies to flight of the UAS utilized for the expressed 

purpose of inspecting specific hydroelectric system assets, specifically remote 

penstocks, flow lines, dams, and reservoirs; remote or impassable sections of 

natural gas and/or oil pipelines; and bridges supporting gas and/oil pipelines. 

Soar Environmental Consulting, Inc. will utilize the UAS to perform structure 

evaluations and asset compliance inspections on remote assets by qualified and

trained personnel that carry current required pilot license and applicable medical 

certificate. 

III. General Responsibility and Authority

a. Managers

i. Managers are responsible for purchase, maintenance, storage, security, 

and oversight related to the proper management and functional use of the 

UAS. 

ii. Managers are responsible for UAS registration, ensuring training is 

completed by manufacturer or qualified trainers, and ensuring

administrative records are maintaining for UAS operation in accordance 

with regulatory requirements. 

b. Pilot in Charge (PIC)

i. The PIC is responsible for determining whether the UAS is in condition for 

safe flight. The PIC shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur. The PIC is directly 

responsible for the operation of the UAS and the safety of the operation. 

ii. The PIC is responsible for following the flight preparation checklists and 

ensuring the operation complies with applicable regulations and ensures

application of Best Management Practices for other operations not 

covered by applicable regulations.

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iii. The PIC conducts a detailed inspection of the UAV after every 10 hours

of flight. The PIC can perform maintenance on the UAV limited to 

repairing small cracks and/ or replacing rotors. All other maintenance will 

be performed by the manufacturer or a designated qualified person.

c. Observer

i. The Observer is responsible for maintaining visual contact with the UAV

and scanning the flight area for air traffic, pedestrians, vehicles, or other 

obstacles that may have an impact on flight safety. 

ii. The Observer is responsible for relaying to the PIC information related to 

air traffic, pedestrians, vehicles or other objects that may have an impact 

on flight safety, in a timely manner. 

iii. The Observer coordinates any required communication between the PIC

and other individuals.

IV. Description of UAS

a. The UAS is an autonomous Unmanned Aircraft System complete with automatic 

takeoff and a computer guided landing system. The system consists of the SR15 rotocraft, a laptop-based ground control unit, and supporting telemetry. 

b. No manual piloting is required during a mission cycle. The modes can be 

switched between semi and fully and autonomous flight control during flight, if 

necessary. Several modes are available, including teleop (joystick, fly-by-wire) 

and waypoint. The autonomous flight control system utilizes an advanced, 

stable-hover control system auto-takeoff and landing, unlimited number of 

programmable waypoints, “point and click” waypoints on map underlay, and 

joystick control. Pre-planned flight paths are created in autonomous mode by 

clicking on the map underlay on the UAS Ground Control Station (GCS) to create 

a preplanned flight path. To clear the flight plan, simply click the “x” button on the 

controller. Adjustments to speed and altitude can be made for each waypoint 

during the flight by highlighting the waypoint and inputting the change in speed or 

altitude in the coordinating boxes. Return-to-Home waypoints, Minimum Safe 

Altitude, and velocity are entered during preflight ensuring the UAV operates only 

within specified parameters. 

V. Description of the GCS

a. The UAS GCS allows the operator simultaneous control over aircraft and camera 

functions. The touch screen control allows for quick navigation and data entry 

while the display screen provides all essential flight data to the PIC. Telemetry 

data is transmitted to the command station at least once per second.

b. The GCS displays the following information:

i. Video camera view

ii. GPS Map underlay with asset delineation as necessary

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iii. UAV Latitude and Longitude

iv. UAV position, altitude and heading

v. Return-to-Home location

vi. North seeking arrow

vii. Date/time

viii. Altitude AGL

ix. Relative horizontal position

x. UAV HZ, RSSI, AFCS Voltage, Servo Voltage, GPS Satellite availability, 

GPS VDOP, Battery Voltage and RSSI reading and conditions

VI. Description of the UAV

a. The UAV can fly with a maximum takeoff wind of up to 15 mph and maximum 

sustained wind of up to 19.88 mph. The UAV automatically compensates for 

wind during all phases of flight and will remain steady in the air even when winds 

are reaching the maximum threshold. 

b. The UAV has a maximum operational range of up to 20km (10.77nm).

c. All flight operations are controlled with GPS waypoints, making the system 

extremely easy to command and control. The UAV holds position and altitude if 

no commands are given by the PIC.

d. Camera positioning is manually controlled with left-hand buttons of the controller, 

but will automatically “lock” onto a target during slow turns or altitude 

adjustments. The camera will remain fixed on the target, which allows for better 

inspection capabilities, until the camera is manually moved from the target, or the 

target is no longer in the camera’s field of vision. 

e. The UAV contains several safety features to ensure a safe flight. Onboard

system error handling allows the UAV to detect system errors while in flight and 

return to the preset home waypoint automatically. System error handling 

includes loss of communication and low battery levels. 

f. The UAV can be operated entirely with the GCS map based interface. The PIC

only needs to click a location on the map, and the system will create a waypoint 

and command the UAV to fly to that waypoint on the map. All flights are 

recorded with map information and flight plans for archiving or future review.

g. Two high-duration, self-contained Lithium polymer batteries operate the UAV. 

The GCS laptop has its own battery and the telemetry require standard 110v

electricity for operation. Charging the batteries is completed with a battery 

charger in 45 minutes and can be accomplished via standard outlet or vehicle. 

h. The UAV is equipped with an Inertial Navigation System consisting of a 3-axis 

gyroscope, a 3-axis magnetometer, GPS receiver, and a static pressure sensor. 

i. The UAV is equipped with vertical lift autonomous takeoff and assisted recovery. 

A Return-to-Home waypoint is designated by the operators and identified in the 

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GCS software. During launch initiation, the rotocraft will takeoff and hover 3 

meters directly above the takeoff area and await further instruction.

VII. UAS Specification Sheet

Item Specification

Length 1,195 mm, 47”

Width 410 mm, 16.5”

Height 520 mm, 20.5”

Main Rotor (M/R) 

Diameter

1,390 mm, 54.7”

Tail Rotor (M/R) 

Diameter

260 mm, 10.2”

Transmission Direct Drive

Tail Rotor Shaft Drive

Dry Weight 8.2 Lbs, 3.72 Kg

Engine 2,200W Electric Motor (25V)

Energy Capacity 32V Battery 11,200 mAh (battery charge rate 45 minutes)

Climb Rate 122 mpm, 400 fpm (AFCS regulated)

Maximum Speed 11 mps, 36 fps [40 kph, 25 mph] (AFCS regulated)

Endurance ~ 30 Minutes

Maximum Range 20 Kilometers

Operating Ceiling 500 Meters

Payload With Battery and Pan & Tilt Sensor Platform Installed:

1.5 Lbs or .7 Kg, sufficient to carry Sony FCB-EX980 day video 

camera, FLIR TAU 2 Series I/R Camera, multi- spectral camera, or 

small SLR digital camera.

Operating 

Temperatures

-20C to 50C

Stealth Yes (40 db at 50 m)

Can Be Weatherized No

Maximum Takeoff 

Wind

24km/h

Maximum Sustained 

Winds

32km/h

Minimum 

Takeoff/Landing Area

5m x 5m

Time to Deployment 5 Minutes

Time to Refuel and 

Redeploy

3 Minutes

Telemetry 802.11-based, LOS Long-range option up to 5 Kilometer range

Flight Control 

Software

Fully autonomous flight with auto-takeoff and landing, unlimited 

number of programmable waypoints, “point and click” waypoints on 

map overlay, joystick control

Ground Control 

Software

Included with system and provides command and control and 

sensor data on screen with audible warning system

Safety Controller a) GHz DSM2, 800 yards, LOS range

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VIII. Flight Preparation Checklists – Flight Operations Area

a. Prior to starting operations, The PIC will ensure the UAS is operated in controlled 

environments, outside of populated areas, away from public and traffic; avoiding 

of areas which are depicted in “yellow” on VFR charts, as well as obtaining and 

assessing information regarding congested areas from the local Flight Standards 

District Office (FSDO) and avoiding areas of congestion.

b. The PIC will file a Notice to Airmen (NOTAM) providing location and a date/time 

for each operation and request a VFR Flight Following, if necessary. 

c. The PIC will check the current ATIS with the jurisdictional Air Traffic Control 

Center on the day of the flight prior to setting up the UAS.

d. The PIC will adhere to the following: 

i. Ensure launch and recovery zone is free and clear of debris.

ii. Ensure launch and recovery zone is clearly marked for safety.

iii. Conduct a safety and flight tailboard with all involved personnel on

hazards in the area, flight mission, and flight operations area.

iv. Ensure control of area, vehicular and pedestrian traffic is in place.

v. Check ATIS report within 30 minutes of flight to ensure weather 

minimums are met for operation.

1. VFR conditions; clear-of-clouds

2. IFR conditions are not authorized at any time

IX. Flight Preparation Checklists – Preflight Airframe Check

a. Remove cab and inspect main gears for wear or damage

b. Visually inspect airframe

c. Visually inspect landing gear

d. Visually inspect rotor integrity

i. Check tension on rotors and ensure rotors are straightened

ii. Check for debris on rotors

e. Check charge of all batteries (aerial vehicle, command station) including backup 

batteries and ensure all telemetry is connected to energy supply source and the 

energy source is in working condition

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f. Visibility >1 statute mile

g. Cloud Clearance >500 feet

h. Wind is no greater than 10kts with gusts no greater than 15kts

X. Flight Preparation Checklists – Preflight Systems Check

Turn on Computer and open GCS

Attach Telemetry Ethernet to Computer

Double click on black bar in the GCS Window

Turn on and plug Joystick in and open Tab and 

press Rescan twice

Confirm movements from Joystick in the GCS

Turn on Manual Transmitter and make sure the 

throttle stick is down, hold switch is on and all 

switches away from pilot

Battery Voltage > 4.7 on Transmitter

Plug both batteries in on UAV and let sit for at 

least 30 seconds without moving.

Confirm the V light on gyro is a solid red light If red V light is blinking unplug batteries and plug 

back in

Press on Network Tab and select UAV

Start Log File

Minimize Network Tab

Open Map Tab and load map

Select Fail Safe and set ALT, Timeout, Speed to 4 

m/s and highlight Rotate button

Minimize tab and click on map to set Fail Safe 

Point to desired location

Press the ROT and PSH button and make sure 

they are highlighted in yellow

UAV HZ > 5

RSSI > 100

AFCS Voltage (fully charged) > 11.5

Servo Voltage > 5

GPS Satellites > 7

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GPS VDOP < 100

Battery Voltage is >58

AHRS is stable and correct according to UAV

Move UAV to Takeoff position with transmitter

Once UAV is in position make sure all blades are 

straight

Recheck all UAV numbers

Make sure camera in forward position

Open Telemetry Tab and press the Reset Tangent 

button

Minimize Telemetry Tab

XI. Takeoff

a. Takeoff will take place at pre-determined location. The location will be clearly 

marked as such to ensure safety with ground personnel.

b. The system cannot be launched without approval from Observer. After the PIC 

has received clearance from the Observer, the PIC will have authority to proceed 

with takeoff. 

XII. Reliability

a. The UAS is designed for maximum reliability and to maintain performance; 

however, due to normal motor operations, certain components will experience 

wear and tear and shall be checked before and after each flight to ensure proper 

working order. Check rotors, batteries, motors, and landing gear before and after 

flight. 

b. Motor conditions and battery are monitored by the system with deviations 

reported on screen.

c. Contact with other objects during flight may cause other components, particularly 

rotors, servos and motor arms to become damaged. Land the rotocraft as soon 

as safely possible to do so, record any contact with objects, check airframe, 

rotors, batteries, motors, landing gear, motor arms and servos and report the 

contact to CEO before initiating additional preflight checklists or flights.

d. The UAS continuously detects and displays system functions on screen which 

may make flying unsafe. These conditions are UAV HZ, RSSI, AFCS Voltage, 

Servo Voltage, GPS Satellite availability, GPS VDOP, Battery Voltage and RSSI. 

If any of these systems are not functioning properly, the UAS will report the 

anomaly with visual and aural alarms. Land rotocraft as soon as safely possible 

to do so, and check conditions. Do not fly until the system is functioning within 

the normal parameters as listed on flight checklist.

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XIII. Emergency Procedures and System Failures

a. Sensor Failure – Failure of on-board flight instruments/sensors will degrade the 

UAS performance. 

i. If sensor failure occurs, utilize the Return-to-Home feature on the display. 

If this does not work, utilize the Spektrum DX-8 remote controller to return 

the UAV to the landing point or a safe area for landing.

b. Motor Failure – The UAV flight performance will degrade significantly if one or 

more motors fails.

i. If motor failure occurs, utilize the Return-to-Home feature on the display if 

able. If this does not work, utilize the Spektrum DX-8 remote controller to 

land the UAV in a safe area closest to the current position of the UAV.

c. Airframe Failure – If airframe becomes damaged to the point that it affects flight 

operation, the UAS will behave similarly to an on-board flight instrument failure.

i. Utilize the Return-to-Home feature on the display. If this does not work, 

utilize the Spektrum DX-8 remote controller to return the UAV to the 

landing point or a safe area for landing.

d. Navigation System Failure – In a navigation system failure, degraded GPS will 

result in unstable flight, depending on failures. 

i. Utilize the Spektrum DX-8 remote controller to return the UAV to the 

landing point or a safe area for landing. 

e. Power Failure – A complete battery failure will result in total power loss to the 

UAV and the UAV will land with the assistance of gravity. Check landing site, 

assist in any safety issues, clean up the area and report the incident to the CEO.

f. Low Battery Condition – Operator will be alerted of a low battery condition.

i. Utilize the Return-to-Home feature on the display. 

g. Visual Line-of-Sight (VLOS) Loss

i. PIC will conduct all flight operations with VLOS. If the pilot’s view 

becomes obstructed and VLOS is lost, the pilot may instruct the UAS to 

hover in place until VLOS is reestablished, or to return to the Return-toHome waypoint. If VLOS is not reestablished in a timely fashion, have 

the observer establish VLOS and relay information to the PIC. Based 

upon the information, the PIC may opt to land the rotocraft at the current

position or wait until VLOS is restored. 

XIV. Security

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a. The system and communication links are encrypted by manufacturer proprietary 

software.

XV. Crew Requirements

a. Soar Environmental Consulting, Inc. requires the PIC to hold the proper Pilot 

License as required by the FAA. 

b. The PIC will maintain flight currency as well hold a current Class II FAA Medical

Certificate.

XVI. Safety

a. Safety is priority for every flight. The PIC is responsible for adhering to 

applicable FAR & ICAO Regulations. 

b. Soar Environmental Consulting will utilize Best Management Practices during 

field operations and for any instances not covered by regulation. 

c. Personnel will abide by all company safety practices at all times.

d. Any personnel may stop work at any time if a safety concern is raised without 

retribution 

e. To assure safe operation within close proximity of structures, the PIC will operate 

the UAV in autonomous mode at all times, unless manual operation is 

necessitated, such as in the event of an emergency. 

f. PIC and Observer will make all efforts possible to ensure that an emergency 

UAV landing will not result in injury to persons or property.

g. Operation support must adhere to PIC instructions, unless that instruction would 

result in an unsafe situation. 

h. UAV flights will occur with VLOS.

i. The PIC will adhere as close as possible to the prescribed flight plan and will not 

deviate or fly in unnecessary areas. No joy-flying.

j. The UAS PIC will give way to any manned aircraft. 

k. Flight operations will occur under VFR Conditions only. No night flights.

l. A fire extinguisher will be brought onsite for use in emergency situations.

XVII. Landing and Retrieval

a. Landing area will be pre-determined prior to flight. A secondary landing area will 

also be determined prior to the flight. 

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