Russell T. Rohan Jr. – Petition for Exemption 1

March 8, 2015

U.S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave. SE Washington, DC 20590 

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

OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF YUNEEQ TYPHOON SMALL UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Russell T. Rohan Jr. 

130 Burr Road

East Northport NY, 11731

(516) 642-8280

russell.t.rohan@gmail.com
Russell T. Rohan Jr. – Petition for Exemption 2

Table of Contents

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

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

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

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

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

6. Public Benefit for Granting Russell T. Rohan Jr. Request for Procedural Relief ..................................... 

9 

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

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

9. Additional Information to Support Russell T. Rohan Jr. Request.......................................................... 11 

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

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

 YUNEEC TYPHOON AND GROUND CONTROL STATIONSPECIFICATIONS.......................... 12 

 RUSSELL T. ROHAN JR. PREFLIGHT CHECKLIST ..................................................................... 15 

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

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

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

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

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

 Russell T. Rohan Jr. – Flight Log............................................................................................................ 18
Russell T. Rohan Jr. – Petition for Exemption 3

1. List of Relevant Abbreviations 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

NM Nautical Mile 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

sUA Small Unmanned Aircraft 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VO Visual Observer 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

2. Summary 

A. Russell T. Rohan Jr. seeks exemptions from Title 14, Code of Federal Regulations 

§ 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 

(a)(1), 91.409 (a)(1) and (2), 91.417 (a) and (b) to operate a YUNEEC 

TYPHOON sUA. This exemption will allow Russell T. Rohan Jr. to operate a 

sUA commercially to provide aerial photography and videography on private 

property. Utilizing the enclosed safety procedures he will safely provide unique 

perspectives to assist in Real Estate, Marketing, Land Management/Surveying, 

and Special Events.
Russell T. Rohan Jr. – Petition for Exemption 4

3. Introduction to the Petitioner 

. 

A. Name and address

(a) Russell T. Rohan Jr. 

130 Burr Road

East Northport NY, 11731

(516) 642-8280 

russell.t.rohan@gmail.com

B. About the petitioner 

(a) Russell T. Rohan Jr. provides professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract 

with the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the local 

authorities or government has requested it by contract or donation. 

I am seeking relief to use the YUNEEC TYPHOON to capture elevated images and 

videos of private and commercial real estate, as well as public events, 

cinematography and newsgathering. I would like to propose the following safety and 

standard operating procedures to ensure the highest level of safety. 

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

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

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

who holds private pilot certificate may act as pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or 

hire. 

B. § 91.7 Civil aircraft airworthiness. 
Russell T. Rohan Jr. – Petition for Exemption 5

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

C. § 91.121 Altimeter settings. 

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

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

when operating—

(1) Below 18,000 feet MSL, to—

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

and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or 

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

the departure airport or an appropriate altimeter setting available 

before departure. 

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

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 20 minutes. 

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

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

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

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

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

alteration. 

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

preventive maintenance, rebuilding, or alteration unless—
Russell T. Rohan Jr. – Petition for Exemption 6

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

of this chapter; and

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

this chapter has been made. 

G. § 91.409 Inspections. 

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

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

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

has been approved for return to service by a person authorized by § 43.7 

of this chapter; or 

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

accordance with part 21 of this chapter. 

H. § 91.417 Maintenance records. 

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

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration 

and records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 
Russell T. Rohan Jr. – Petition for Exemption 7

(iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified time 

basis. 

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. 

If the AD or safety directive involves recurring action, the time and 

date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 

43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

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

Reasons for Request. 

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

(a) The YUNEEC TYPHOON sUA has a take-off weight of 3.75 lbs. and 

as configured by the manufacturer and operated by Russell T. Rohan Jr. is 

incapable of carrying pilot(s), passengers, or cargo. In addition The 

YUNEEC TYPHOON is electronically limited to an operational envelope 

of 400’ AGL, a flight radius of 300’ from the GCS, is always operated 

VLOS, VMC, and during daylight hours only. 
Russell T. Rohan Jr. – Petition for Exemption 8

(b) Given the above operational limitations of the YUNEEC TYPHOON

Russell T. Rohan Jr. submits that operation by a PIC with a private pilot 

certification would provide an appropriate level of safety and 

understanding of operation in the NAS and requests an exemption to § 

61.113 (a) & (b). 

B. § 91.7 Civil aircraft airworthiness. 

(a) It is not clear if the YUNEEC TYPHOON is an aircraft for which the 

FAA has established or intends to issue an airworthiness certificate. To 

meet the intent of this regulation Russell T. Rohan Jr. requires the PIC, as 

part of the pre-flight checklist, to verify the airworthiness of the UAS prior 

to applying control power. This includes visual inspection of rotor blades, 

fuselage, rotor arms, landing gear, and camera gimbal for any damaged or 

loose parts. Please refer to Russell T. Rohan Jr. Preflight Checklist in 

Appendix section 2. 

(b) Russell T. Rohan Jr. submits that his preflight SOP and after flight 

maintenance meets the requirements of this regulation and requests 

exemption from § 91.7. 

C. § 91.121 Altimeter settings. 

(a) The YUNEEC TYPHOON utilizes a combination of GPS and 

barometric pressure sensor to establish both position and altitude and 

transmits this data to the GCS operator display via a radio 

communications telemetry data link. Zero feet AGL is automatically 

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

field attitude. 

(b) The YUNEEC TYPHOON is electronically limited to factory default 

of maximum 400’ AGL, and Russell T. Rohan Jr. further utilizes an SOP 

that requires the PIC to operate the sUA at an altitude less than 300’ AGL. 

(c) Russell T. Rohan Jr. submits that its componentry and operation 

provide an equivalent level of safety and requests an exemption to § 

91.121. 

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

(a) The YUNEEC TYPHOON is powered by one (1) 5400mAh Lithium 

Polymer (LiPo) battery and is limited to flight duration of between 20 and 

25 minutes total. Russell T. Rohan Jr. will restrict flight time to 15 

minutes to leave a minimum of five (5) minutes of power reserve. 
Russell T. Rohan Jr. – Petition for Exemption 9

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

consideration energy requirements based on air speed, wind conditions, 

planned and emergency VTOL locations. 

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

sooner than one(1) hour after sunrise and terminate one (1) hour before 

sunset. 

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

§ 91.407 Operation after maintenance, preventive maintenance, rebuilding, 

or alteration. 

§ 91.409 Inspections. 

§ 91.417 Maintenance records. 

(a) Russell T. Rohan Jr. seeks relief on § 91.405, § 91.407, § 91.409, and 

§ 91.417 for the following reasons: 

(b) It is not clear if the YUNEEC TYPHOON is an aircraft for which the 

FAA has established or intends to issue an airworthiness certificate. These 

rules appear to apply to aircraft with an airworthiness certificate. 

(c) Russell T. Rohan Jr. will maintain a detailed flight log recording all 

flight durations to keep record of motor hours, battery charge cycles, and 

wear on sUA. 

(d) Notwithstanding Russell T. Rohan Jr. will maintain and document the 

YUNEEC TYPHOON in accordance with recommendations by the 

manufacturer’s communiques and Instruction Manual. 

(e) Russell T. Rohan Jr. will document repairs and modifications to the 

sUA using only manufacturer recommended spare and replacement parts. 

(f) Russell T. Rohan Jr. will maintain a monthly maintenance log and 

repair manual. See Appendix 11 – Russell T. Rohan Jr. Flight Log. 

6. Public Benefit for Granting Russell T. Rohan Jr. Request for 

Procedural Relief 

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

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

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

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

of smaller business and real estate agents. 

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

for marketing private real estate. This new demand for bird’s eye views will create an 
Russell T. Rohan Jr. – Petition for Exemption 10

entirely new business market which in return will create countless job as well as a large 

local and national economic benefits. 

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

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

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

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

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

off and land within the boundaries of the private property that they are working on. This 

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

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

than those risks posed by manned aircraft flying at low altitudes to capture images. 

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

conventional hydrocarbon fueled aircraft, exhibiting vastly lower noise pollution and a 

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

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

interest. 

7. Granting the Exemption Would Not Adversely Affect Public 

Safety 

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

YUNEEC TYPHOON operation and have undergone training and testing specific to the 

sUA. 

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

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

always be maintained. 

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

visibility. 

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

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

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

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

(PIC) and Visual Observer (VO). 
Russell T. Rohan Jr. – Petition for Exemption 11

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

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

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

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

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

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart. Should operation be requested within 5 nautical miles, a 

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

COA issued to Russell T. Rohan Jr. The letter of agreement with the airport management 

will be made available to the Administrator or any law enforcement official upon request. 

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

NoTAM and any relevant TFR in projected flight area. 

J. Russell T. Rohan Jr. will continually be self-monitoring safety procedures and 

adopting new SOP to ensure the highest level of safety. 

K. Russell T. Rohan Jr. will continually monitor Federal guidelines and FAA rules as 

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

8. Summary for Publishing in the Federal Register 

A. Russell T. Rohan Jr. requests exemption from TITLE 14 OF THE CODE OF 

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

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

Russell T. Rohan Jr. requests relief from these sections from the FAA Administrator per 

the intentions of the FAA Moderation and Reform Act of 2012 so that Russell T. Rohan 

Jr. can produce photography and video for clients in the private sector. 

9. Additional Information to Support Russell T. Rohan Jr. Request 

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

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

certain UAS may operate safely in the NAS. Russell T. Rohan Jr. has an unmatched 

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

photography and videography. He understands and respects that any UAS used 

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

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

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

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

as well as aeronautical and technological advances will help to consistently update our 

safety protocols and SOP. We strive to be an industry leader in safe and responsible use 

of sUA. Russell T. Rohan Jr., will obtain an ATO issued COA prior to conducting any 

operations under the grant of this exemption. All aircraft operated by Russell T. Rohan Jr.
Russell T. Rohan Jr. – Petition for Exemption 12

that comply with this exemption will be registered in accordance with 14 CFR part 47 

and aircraft will be marked with November markings as large as reasonably practical in 

accordance with 14 CFR part 45, Subpart C. 

10. Conclusion 

A. As set forth herein, Russell T. Rohan Jr. seeks an exemption pursuant to 14 C.F.R. § 

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

which will permit the safe operation of a Yuneec TYPHOON UAS commercially to 

provide aerial and videography services. The Administrator will be assisting small 

business by granting this petition. In accordance with the FAA Modernization and 

Reform Act of 2012, Russell T. Rohan Jr. respectfully requests that the FAA 

Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF 

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

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

11. Appendix 

YUNEEC TYPHOON AND GROUND CONTROL SPECIFICATIONS

Q500+ TYPHOON SPECIFICATIONS

Height: 210mm (8.3 in) 

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

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

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

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

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

Takeoff Weight (with battery and CGO2-GB): 1700g (60.0 

oz.) 

Battery: 5400mAh 3S 11.1V LiPo 

Transmitter: ST10 10-channel 2.4GHz with 5.8GHz video 

link 
Russell T. Rohan Jr. – Petition for Exemption 13

Flight Time: 20-25 minutes

CGO2+ Camera System and Gimbal 

Height: 115mm (4.5 in)

Width: 75mm (2.9 in)

Depth: 135mm (1.4 in)

Weight: 185g (6.5 oz)

Video Resolution: 1080p 60, 50 or 48 fps

Photo Resolution: 16 megapixels

Transmission Distance/Range: Up to 600m (1970 ft)

depending on receiving device and environment

Transmission Band: 5.8GHz

Storage (memory): microSD Class 10 up to 128GB

ST10+ Transmitter and Ground Station

Number of Channels: 10

RC Band: 2.4GHz

RC Modulation: Yuneec

Video Downlink Band: 5.8GHz

Telemetry/OSD: Yes

SD Card Compatible: Yes

LCD Screen Size: 5.5”

Touchscreen: Yes

Appendices: Link to Yuneec Q500+ Manual 

http://static.bhphotovideo.com/lit_files/115006.pdf

Safety Procedures and Checklist 

Section 1 – Equipment Transportation

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

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

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

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

only manufacturer approved parts and procedures.

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

damaged rotors and replace with original manufacture equipment.
Russell T. Rohan Jr. – Petition for Exemption 14

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

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

other foreign material.

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

identification at all times.

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

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

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

place prior to transport.

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

Section 2 - Flight Plan

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

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

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

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

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

amount of inclement weather, the operator SHALL NOT proceed with the flight, unless conditions 

improve.

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

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

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

2.4 Verify the projected flight path is clear of all obstacles. If there is an obstacle, an alternative flight 

path High Level Images – Petition for Exemption 16 must be established. Obstacles include people, 

vehicles, roads, and structures. Always maintain at least 100 feet from obstacles due to potential 

hazards from unplanned landings. If, at any time during a flight, people or vehicles impinge on the 

100 foot separation rule, the operator must direct the aircraft to an emergency safe landing area and 

land immediately until it is once again safe to operate.

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

from any object or person other than High Level Images personnel directly involved in the flight 

session.

2.6 Under no circumstances should a flight session exceed an altitude of 300 feet to avoid conflict 

with full scale manned aircraft and maintain VLOS.

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

and no later than 1 hour prior to dusk.

Section 3 - Preflight Checklist

3.1 Unpack aircraft and accessories from case at primary landing/take off zone
Russell T. Rohan Jr. – Petition for Exemption 15

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

following items with battery removed from aircraft.

3.2.1 Rotor blades are free from damage and are adequately tightened

3.2.2 Rotor blades turn freely by hand with no binding

3.2.3 Fuselage is free from damage

3.2.4 Landing gear is undamaged and not entangled by foreign objects

3.2.5 Camera gimbal and camera are securely attached to aircraft

3.2.6 Camera gimbal dampeners are in good condition

3.2.7 Micro SD card is installed

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

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

continue with flight.

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

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

zone and projected flight/operator path.

3.5 Power on GCS.

3.6 Place flight battery in aircraft and power on vehicle.

3.7 Ensure successful RF control connection and video feed.

3.8 Perform compass recalibration.

3.9 PIC and VO scan ground area and sky above for no intrusions and to announce “clear” or “hold”.

Section 4 – Flight Procedures

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

idle.

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

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

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

otherwise cancel flight operations.

4.3 Announce “TAKE OFF” loudly so that anyone within 100 feet can hear.
Russell T. Rohan Jr. – Petition for Exemption 16

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

AGL. Check aircraft for proper response to slight control inputs.

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

parameters.

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

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

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

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

4.8 Depress motor control button until rotors stop.

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

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

Section 5 – Post Flight

5.1 Power down flight battery and remove from aircraft.

5.2 Power down GCS.

5.3 Replace camera lens protective cover.

5.4 Carefully remove and secure micro SD card.

5.5 Replace camera gimbal lock.

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

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

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

storage locations.

5.8 Scan and police area for detritus left during mission.

5.9 Fill out flight log with information from flight.

Flight log

All flights and any relevant issues will be documented in a flight log.

Appendices: Link to flight log book 

http://www.amazon.com/UAS-Pilot-Log-Unmanned-Operators/dp/1507643810