October 22, 2015 

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue, SE 

Room W12-140, West Building Ground Floor 

Washington, D.C. 20590-0001 

Subject: Petition to the FAA for Section 333 Exemption

Dear Sir or Madam, 

SITECH Mid-Atlantic, L.L.C. hereby submits to the Federal Aviation Administration, pursuant to the FAA

Modernization and Reform Act of 2012, an exemption petition, in accordance with Section 333 of the 

Act. 

This letter provides requested information as listed in the FAA’s “Public Guidance for Petitions for 

Exemptions Filed under Section 333” as described as of this date at the FAA website at 

https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/

SITECH Mid-Atlantic, L.L.C. (referred to as SITECH, SITECH M.A. or SITECH Mid-Atlantic) Background:

SITECH operates in the Heavy Civil Construction, Agriculture and Survey for Construction industries. 

It provides precision GPS machine control, robotics, laser guidance instruments for the 

aforementioned industries. SITECH also provides software for contour modeling, estimating and 

volume metrics. SITECH M.A. also engages in mining and marine utilizing the products above. We 

represent Trimble Navigation for the products described. 

SITECH Mid-Atlantic provides a single vendor solution in heavy industrial construction, 

maintenance, estimating and heavy hauling, and consulting services for over 15 years. Consultancy 

is provided to assist Growers and Construction clients to optimize yields, protect the environment 

and efficiently manage construction projects for building sites and road\interstate construction. 

The company is privately owned and headquartered in Charlotte, North Carolina. SITECH M.A. has 

facilities in Charlotte and Raleigh, North Carolina; Richmond, Virginia; and Charleston, South Carolina. 

The major trade areas are the states of North Carolina, South Carolina, Virginia and West Virginia. 

Vendor and client recognition of our performance has consistently ranked us among the top heavy civil,

agriculture, mining and marine. We are Trimble Navigation’s largest heavy civil precision GPS dealer in 

North America. We are a data company at our core utilizing instruments, software and consulting serve 

our clients. More company information can be viewed at the company website at 

http://www.sitechma.com/ . 

SITECH Mid-Atlantic, LLC

Phone: (800) 443-7561; (704) 525-7099 

Fax: (704) 523-8558 

Web: www.sitechma.com

Email: info@sitechma.com
Purpose for the Exemption

SITECH Mid-Atlantic, L.L.C. desires to utilize an unmanned aircraft system (UAS), herein described, to

accomplish aerial photography, surveys and assessments of construction sites, agriculture and mining. 

Contact Information:

Edward Upchurch 

President 

SITECH Mid-Atlantic, LLC 

8100 Arrowridge Blvd., Ste G 

Charlotte, NC 28273 

Mobile: 704-309-6613 

Office: 704-525-7099 

Email: 

eupchurch@sitechma.com

List of Specific Sections of 14 CFR for which exemption is sought:

This listing matches the list on page 7 of the FAA’s “Public Guidance for Petitions Filed under Section 

333”, Rev. 9/25/2014. 

14 CFR 21, Subpart H –Airworthiness Certificates 

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 

14 CFR 91.7 (a), Airworthiness required for operation 

14 CFR 91.103 (b) (2), Preflight action 

14 CFR 91.105, Flight crewmembers at stations 

14 CFR 91.109, Flight instruction 

14 CFR 91.119 (c), Minimum safe altitudes 

14 CFR 91.121, Altimeter settings 

14 CFR 91.151, Fuel requirements for flights in VFR conditions 

14 CFR 91.405 (a), Maintenance required 

14 CFR 91.407 (a) (1), Operation after maintenance 

14 CFR 91.409 (a) (2), Inspections 

14 CFR 91.417 (a) and (b), Maintenance records 

(See pages 8 through 10 for further details) 
In accordance with the outline given in the FAA’s “Public Guidance for Petitions Filed under Section 

333”, the following information is provided for each numbered item listed in that guidance: 

1. Aircraft Description

Design and Operational Characteristics: 

SITECH Mid-Atlantic plans to operate a 3DRobotics (also referred to as ‘3DR’), Model X4 (X4) 

aircraft, each comprised of an unmanned aircraft and a transportable ground station. This aircraft 

is a quad-copter design with gross weight (battery and propellers included) of X4 - 2.2 kg (5.3 

lbs.). This aircraft can also be configured as an eight propeller aircraft, known as X8. The quad 

version is what will be utilized by SITECH. 

The 3DRobotics X4 will utilize GoPro 3+ Black lightweight camera (or equivalent) mounted to a 

three-way gimbal for capturing aerial still photographs and videos. 

It is equipped with four rotors that are driven by battery-powered electric motors. Maximum 

airspeed is X4 - 30 knots (34.5 mph). Operational speed for SITECH Mid-Atlantic purposes will 

be lower as outlined in this document. 

The 3DRobotics X4 is equipped with a built-in Flight Control System which includes an integral 

inertial sensor and a barometric altimeter that measure both attitude and altitude. Included is a 

shielded, anti-static compass which reads geomagnetic information and assists in accurately 

calculating position and altitude. 

The Flight Control System includes a Failsafe Function. Multiple ways are provided for handling 

failsafe conditions. GPS failsafe’s are enabled if the aircraft has lost GPS lock or GPS communications 

are lost for 5 seconds or more when operating in flight mode that requiring GPS. The aircraft will 

enter one of two preset conditions, 1) controlled landing or 2) return manual control to the PIC. The 

PIC will not be able to switch to GPS until the aircraft has landed and flight controls are checked and 

reset. If GPS mode is not active, Failsafe will execute a controlled descend and automatic landing. 

Through the designated Flight Assistant software (Agisoft, Datumate or Ardupilot), each flight 

operation will be programmed with a maximum radius distance and maximum altitude from the 

Home Point such that the flight control system will limit operations to within the confines of the 

property to be surveyed for SITECH M.A. or SITECH’s Clients. The software will be selected for the 

specific mission. All flights will be line-of-sight. These performance limitation requirements are 

included in the UAS Operating Procedure contained in Appendix A herein.

 
Manufacturer’s Documentation: 

Detailed manufacturer’s design information (current to this date) is contained the in the following 

manuals in the appendices at the end of this document: 

• Appendix A – 3DRobotics X4 Specifications 

• Appendix B – 3DRobotics X4 Operating Procedure 

• Appendix C – 3D Robotics Instruction Manual (Provided as Separate Attachment) 

• Appendix D – Pilot In Charge Information 

For ease of reference, the 3DRobotics is included in FAA Section 333 Exemption No. 11335 

granted on April 16, 2015 to Voler. Inc. and FAA Section 333 Exemption No. 11824 granted on 

June 16, 2015 to Axis Surveying, LLC. 
2. Procedures for Ensuring UAS Is In a Condition Safe for Flight

Preflight Checks: As a minimum, the following items will be checked prior to initiating any 

operation (See Appendix A in this document for detailed procedures):

o Operations must be in daylight hours and under visual meteorological conditions (VMC). 

o Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for 

each leg of the flight clearly marked. 

o Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and 

structures unless protective barriers or structures are present, or permission is granted, or 

such operations present no hazard to the Pilot in Command, the Visual Observer, trainees, 

and other essential persons. 

o Flight plan and schedule has been reviewed with site leadership and communicated to all 

SITECH Mid-Atlantic and Client personnel in the area. 

o Remote control, smart battery, range extender, and smart phone are fully charged. 

o Propellers are mounted correctly. 

o Gimbal clamp has been removed. 

o Damping absorbers are in good condition, not broken or worn. 

o Camera lens checked and clear of obstruction. 

o Micro-SD card has been inserted. 

o Gimbal is functioning as normal. 

o Controller app connected and camera lens is visual to ground control (tablet or computer). 

o Compass has been calibrated. 

o Flight radius and altitude limits have been set with the 3DRobotics Assistant software, not 

to exceed 400 ft. AGL altitude, and radius limited to the property boundaries of SITECH 

M.A. or Client site. 

o The Visual Observer (VO) is stationed at the required initial observation point according to 

the flight plan and in view of the Pilot in Command (PIC) and has means for continual verbal 

communication. 

o All site required safety permits are approved and in possession of the PIC. 

o A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and 

not less than 48 hours prior to the operation. 

o Motors can start and function as normal. 

o Flight Indicator Lights on the aircraft verify that the Home Point is set to current location. 

o Record the Preflight Check, date and sign, and file it in the Equipment Inspection and 

Maintenance Record Book. 
3. Control Radio Frequency (RF) Spectrum 

The Remote Control ground station operating frequency is 5.278 – 5.85 GHz and is FCC compliant 

with communication distance in an open area of 800 m (875 yds.) 

Operating Frequency 915 MHz or 433 MHz 

Communication Distance (open area) FCC Compliance: 800m 

Receiver Sensitivity (1%PER) -117 dBm 

Transmitter Power FCC Compliance: 100mW 

Working Voltage 100 mA @ 3.7 – 6 VDC 

Built-in Lithium Polymer Battery 3 cell, 11.1 VDC, 3.5 Ah 

4. Qualifications for the Pilot in Command (PIC)

Certifications: Operations will be conducted by a Pilot in Command (PIC) possessing at least a 

private pilot certificate and at least a current third-class medical certificate. 

Logged Hours: Prior to operations the PIC will have accumulated and logged a minimum of 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS. Training, proficiency, and experience-building flights in dedicated training sessions will

be included in the accumulated and logged hours. 

Currency: Prior to operations, the PIC will have accumulated and logged a minimum of 5 hours as 

UAS pilot specifically operating the 3DRobotics X4. The PIC will have accomplished, during 

dedicated training sessions, 3 take-offs and landings in the preceding 90 days (for currency 

purposes). 

Emergency and Evasive Maneuvers: The PIC will have demonstrated the ability to safely operate the 

3DRobotics in a manner consistent with how it will be operated in SITECH applications and\or 

SITECH Client sites, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. All hours will be logged and recorded. 

5. Pilot in Control (PIC) - Medical

As described above, in “4. Qualifications for the Pilot in Command (PIC)”, the PIC will possess at least 

a current third-class medical certificate. 

6. Description of Intended UAS Operations

Operations will be restricted to Class G airspace. 

No operations will occur within 5 miles of a non-towered airport reference point as denoted on a 

current FAA-published aeronautical chart, unless a letter agreement with the airport’s management 
is obtained, and the operation is conducted in accordance with a Notice to Airman (NOTAM) as 

required by the Certificate of Waiver or Operation (COA). 

The 3DRobotics X4 and will be utilized to demonstration, photo, video, survey construction sites 

and agriculture sites in accordance with customer requirements. The use of small unmanned 

aircraft systems provides more immediate and thorough information than is presently available by 

other means. In some circumstances man lifts and structures have had to be erected for 

observation, measurement and acquisition of data. Expenses for scaffolding, rental of manned 

aircraft, rental of equipment, and lost time is saved. Safety is improved by reducing fall risk for 

workers and reducing potential for manned aircraft accidents. 

As described in “2. Procedures for Ensuring UAS Is in a Condition Safe for Flight”, altitude and 

distance limits will be entered into the Flight Control System prior to commencement of flight. This 

will restrict the operation to the SITECH Mid-Atlantic or SITECH M.A. Client property. The Failsafe 

Function integral with the 3DRobotics will assure the aircraft stays within the area deemed safe for 

operation. 

7. Proposed Speed, Altitude, Visibility and Distances

Speed: The 3DRobotics X4 is capable of a maximum speed of 30 knots. In order to conserve power, 

and thereby maximize flight time, and to assure good quality still photographs and video, 

both\either aircraft will be operated at a slow speed along the flight path, typically 4 knots or 

below. Higher speeds may be used from time to time when traversing a section of the flight area 

and not included in a given study. 

Altitude: Altitudes below 400 ft. AGL are adequate for the complete range of facilities and 

structures to be surveyed. The integral Flight Control System will be set to limit the altitude to 

always be below that level. 

Distances: The integral Flight Control System will be set to limit the radial distance from the Home 

Point (point of flight commencement) such that the 3DRobotics aircraft will stay within the 

boundary of the property lines. The PIC will operate the equipment to assure those limits are not 

reached and will maneuver the 3DRobotics to follow the preplanned flight path within the property 

boundaries. 

The 3DRobitics aircraft will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud when visibility is less than 3 statute miles from the PIC. 

Operations will be aborted immediately if the PIC encounters unpredicted obstacles or emergencies. 

Safe descent and landing procedures will be followed in accordance with operating documents. 
8. Description of the Area of Intended Operations

As described in “6. Description of Intended UAS Operations”, the 3DRobotics copter craft operation 

will be restricted to SITECH Mid-Atlantic or SITECH Mid-Atlantic Client property and not taken into 

public areas. SITECH M.A. and Client personnel on the site will be made fully aware of the operation 

prior to commencement of operations. 

9. Proximity of Airports

Operations will be restricted to Class G airspace. 

No operations will occur within 5 miles of a non-towered airport reference point as denoted on a 

current FAA-published aeronautical chart, unless a letter agreement with the airport’s management 

is obtained, and the operation is conducted in accordance with a Notice to Airman (NOTAM) as 

required by the Certificate of Waiver or Operation (COA). 

10. Operation as Visual Line-of-Sight (VLOS)

In addition to the Pilot in Command (PIC), all operations will include a Visual Observer (VO). The VO 

will assure that the Phantom 2 Vision+ is always within their visual line-of-sight (VLOS), as well as the 

PIC’s, at all times. The VO and the PIC will be able to communicate verbally at all times utilizing twoway radios available at SITECH M.A. and SITECH Client sites. 

11. Procedures for Preflight Safety Assessment

Prior to each flight, the PIC will inspect the 3DRobotics including the ground control station, in 

accordance with the Preflight Checklist (see “2. Procedures for Ensuring UAS Is In a Condition Safe 

for Flight”). If the Preflight Check indicates any unsafe conditions or a non-functioning safety-critical 

part, the flight will not commence until the needed maintenance is performed and a satisfactory 

Preflight Check can be completed. All maintenance and alterations performed will be documented 

and filed in the Equipment Inspection and Maintenance Record Book. 

12. Notifications

In accordance with the COA, a Notice to Airmen (NOTAM) will be requested not more than 72 hours 

in advance and not less than 48 hours prior to an operation. 

In addition, any notifications required by the FAA Flight Standards District Office will be made. 
Specific Regulations for Which Exemption is Sought:

1. 14 CFR 21, Subpart H –Airworthiness Certificates

Part 21 covers certification procedures for products and parts. Subpart H specifies requirements for 

Airworthiness Certificates for various aircraft types. Small unmanned aircraft systems are not 

specifically called out and addressed in these rules. 

SITECH M.A. will, in lieu of airworthiness certification by aforementioned rule, if exemption is 

granted, ensure that the 3DRobotics 4X system is in compliance with its operating documents as 

described herein. The PIC will assure that all Preflight Checks are completed and documented and 

there is full compliance with all manufacturer’s operation and maintenance documents. 

Due to consideration of the size, weight, speed, and limited operating area associated with SITECH’s 

proposed 3DRobotics 4X we believe it will not create a hazard to users of the National Airspace 

System (NAS) or the public. Therefore, a request is made for exemption from 14 CFR part 21, and 

any associated noise certification and testing requirements of part 36. 

2. 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

14 CFR 61.113 (a) and (b) prohibit private pilots from fulfilling the role of PIC if the aircraft is carrying 

property for compensation, unless the flight is only incidental to that business or employment. 

SITECH M.A. believes that due to the size, weight, speed, and limited operating area associated 

with SITECH’s proposed 3DRobotics 4X operation, a PIC possessing a private pilot certificate and 

a current third-class medical certificate, and also having the aforementioned training and logged 

hours, would ensure safety and prevent creating any hazard to users of the National Airspace 

System (NAS) or the public. We therefore request an exemption from these parts of 14 CFR. 

3. 14 CFR 91.7 (a), Airworthiness required for operation

If the exemption from 14 CFR 21, Subpart H (item 1 above) is granted, no airworthiness certificate 

will be required. On this basis, exemption from 14 CFR 91.7 (a) is requested, presuming that 

airworthy condition by definition in the rule means having an airworthiness certificate. SITECH M.A. 

will, in lieu of airworthiness certification by 14 CFR 21, ensure that the 3DRobotics 4X system is in 

compliance with its operating documents as described herein. The PIC will assure that all Preflight 

Checks are completed and documented and execute full compliance with all manufacturer’s 

operation and maintenance documents. 

4. 14 CFR 91.103 (b) (2), Preflight action

14 CFR 91.103 (b) (2) specifies that the PIC be familiar with aircraft performance under expected 

values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. 
Since the 3DRobotics 4X will not be operating out of airports this rule is not applicable. On this 

basis, and on the basis that the operating documents cover requirements for operation safety, an 

exemption from this rule is requested. 

5. 14 CFR 91.105, Flight crewmembers at stations

This part requires certain actions by onboard crewmembers. Since the 3DRobotics 4X is 

unmanned, an exemption from this rule is requested.

6. 14 CFR 91.109, Flight instruction

14 CFR 91.109 describes requirements for flight instruction and requires that the aircraft used for 

flight instruction have fully functioning dual controls. The details pertain to manned airplanes and 

are not applicable to a small unmanned aircraft system such as the 3DRobotics Flight training will 

be required for the 3DR 4X pilot as detailed on page 5 herein, “4. Qualifications for the Pilot in 

Command (PIC).” Compliance with these training requirements with logged hours, in combination 

with a private pilot’s license and current third-class medical certificate, assure that the required 

competency for safely operating the 3DRobotics 4X will be maintained. On this basis an exemption 

from this rule is requested. 

7. 14 CFR 91.119 (c), Minimum safe altitudes

14 CFR 91.119 (c) requires that no operation is permitted below 500 feet above the surface, except 

over open water and sparsely populated areas. The proposed use of the 3DR 4X is specifically for 

altitudes that range from the surface to maximum 400 feet AGL. On the basis of the 

aforementioned safety procedures, we believe there will be no increased hazard to users of the 

National Airspace System (NAS) or the public will be created by the 3DR 4X as detailed here. 

8. 14 CFR 91.121, Altimeter settings

14 CFR 91.121 provides specific rules for altimeter settings for cruising altitude and flight level of

aircraft and speaks of altimeter stations along the route and the elevation of the departure airport. 

In lieu of these specific requirements, most suitable for manned airplanes, the 3DR 4X has 

barometric altimeter and GPS derived altitude capabilities. All altitudes reported to Air Traffic 

Control (ATC) will be in feet above ground level (AGL). On this basis, an exemption from this rule is 

requested. 
of 30

9. 14 CFR 91.151, Fuel requirements for flights in VFR conditions

14 CFR 91.151(a) requires that no person may begin a flight under Visual Flight Rule (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. 

The 3DRobotics Model 4X has a built-in Low Battery Level Warning Function: 

(1) If the smart battery is depleted to the point that may affect the safe return of the 

aircraft, the low battery level warning notifies the PIC to take action. 

(2) The thresholds for these warnings are automatically determined based on the 

current aircraft altitude and its distance from the Home Point. 

(3) A color coded battery level indicator shows battery level, and an estimated 

remaining flight time in minutes is displayed to the ground controller. 

(4) When the critical battery level warning activates, the aircraft will gradually 

descend and land automatically. 

As standard operating procedure, the PIC will immediately return the 3DRobotics 4X to the 

Home Point for a battery swap when the battery level reaches 25%. 

On the basis of these specific safety features of battery power level monitoring, and operating 

procedures, an exemption from this rule is requested. 

10. 14 CFR 91.405 (a), Maintenance required

Please see exemption request explanation in item 15 below (14 CFR 91.417). 

11. 14 CFR 91.407 (a) (1), Operation after maintenance

Please see exemption request explanation in item 15 below (14 CFR 91.417). 

12. 14 CFR 91.409 (a) (2), Inspections

Please see exemption request explanation in item 15 below (14 CFR 91.417). 

13. 14 CFR 91.417 (a) and (b), Maintenance records

Parts 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), and 91.417 (a) and (b), contain requirements for 

maintenance of larger aircraft. In lieu of adapting these rules for the 3DR Model 4X, SITECH M.A. is 

requesting an exemption on the basis that it will inspect the 3DR Model 4X and ensure that it is in a 

condition for safe flight prior to beginning any operation. We propose that adherence to the 

operating documents describing the requirements for maintenance, inspection, and recordkeeping, 

are sufficient to ensure that safety is not adversely affected. 
PUBLIC BENEFIT

Granting this Section 333 Exemption would benefit the public in the following ways: 

• Public Safety: Common practice for industrial facility construction projects and periodic site- wide 

industrial facility visual assessment involves utilization of manned aircraft. The potential risk to life and 

property is order of magnitudes less for use of a small unmanned aircraft system as compared to 

conventional aerial photography by manned fixed wing aircraft. 

• Work Place Safety: In order to accomplish inspections of difficult to access areas at high elevations

requires either erection of scaffolding or lifting personnel by crane in protective enclosures to view the 

subject of interest. Fall protection gear and compliance with OSHA rules governing such work is crucial for 

life safety. The ultimate protection, however, would be to not involve personnel in such activity and 

instead complete this work with an unmanned aircraft system. 

• Energy Savings and Environmental Protection: Reduction of frequency of manned aircraft used to do 

aerial photography and surveys for construction and agriculture sites results in burning less fuel thereby 

saving energy and reducing emissions of combustion gases. 

REASONS SAFETY NOT ADVERSELY AFFECTED AND IS AT LEAST EQUIVALENT TO EXISTING RULE

The key features of the proposed 3DRobotics Model 4X unmanned aircraft system that assure that safety to the 

public and safety of the National Airspace System (NAS) is not adversely affected are the following: 

• Credentials and training for the Pilot in Command (PIC), along with detailed operating 

procedures, assure that the level of competency required for successful and safe flight 

operations is achieved. 

• The built-in Flight Control System, which includes a Failsafe Function, assures proper flight control data 

feedback to the Pilot in Command (PIC), and immediate return to the Home Point and safe landing under 

failure scenarios, thereby preventing injury or damage. 

• Visual Line-of-Sight (VLOS) operation provided by the PIC and the Visual Observer (VO), and their 

ability to communicate verbally at all times, assures full operational control. 

Detailed operations and maintenance procedures, including a Preflight Checklist, provide assurance of 

mechanical integrity and full functioning of 3DR Model 4X unmanned aircraft system prior to 

commencement of any operation. 

 
SUMMARY FOR PUBLICATION IN FEDERAL REGISTER 

Petition for Exemption 

Docket No.: FAA-2015-xxxx 

Petitioner: SITECH Mid-Atlantic, L.L.C. 

Section of 14 CFR 14 CFR 21 Subpart H, 61.113(a) and (b), 91.7 (a), 91.103 (b) (2), 91.105, 

91.109, 91.119 (c), 91.121, 91.151, 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) and (b). 

Description of Relief Sought: The petitioner is seeking an exemption to utilize an unmanned 

aircraft system (UAS) to accomplish aerial photography, surveys and assessments of industrial 

facilities and construction sites. 

Respectfully Submitted, 

Edward Upchurch 

President 

SITECH Mid-Atlantic, LLC 
Appendix A 

X4 Platform Specification 

• Battery: 4S 14.8V 8,000 mAh 10C 

• Battery Dimensions: 5.6 in x 1.93 in x 1.69 in (14.2 cm x 4.9 cm x 4.3 cm) 

• Battery Weight: 643 g 

• Autopilot hardware: Pixhawk v2.4.5 or greater 

• Autopilot firmware: ArduCopter 3.2 or greater 

• GPS: 3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update) 

• Ground Station Radio: 3DR Radio v2 (915 MHz or 433 MHz) 

• Motors: SunnySky V2216-12 KV800 II (The images above show conical nuts; 

X8+ ships with hex nuts.) 

• Controller: Taranis X9D 

• Frame Type: X 

• Propellers: APC Propeller 11x4.7 SF (4), APC Propeller 11x4.7 SFP (4) 

• Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm) 

• Payload Capacity: 600 g (1.4 lbs). Additional payload possible up to over 1kg 

with reduced flight time. 

• Vehicle Weight with Battery: 2.2 kg (5.3 lbs) 

• Maximum Estimated Flight Time: 8~12 min 
Appendix B 

UAS Operating Procedure 

Document: SMA-UAS-001
Procedure for Unmanned Aircraft System Operations SITECH Mid-Atlantic, LLC 

Procedure Doc Number SMA-UAS-001 Type Operation

Authored By Ed Upchurch Revision Number 10/6/2015

Reviewed By Steve Denty Next Review Date 10/15/2015

Approved By Steve Denty Approved Date 10/15/2015 

OVERVIEW

The purpose of this procedure is to describe responsibilities and tasks required to safely and successfully 

operate a 3DRobotics Model 4X unmanned aircraft system to accomplish a mission to survey SITECH or 

SITECH Client construction sites or agriculture facilities. 

This is a Critical Procedure that requires sign off of the Preflight Checklist for safety and full compliance 

with all steps as required. 

To properly use this procedure, personnel must be aware of safety related information contained in the

Health, Safety and Environmental Precautions section of this document. 

RESPONSIBILITIES

1. PILOT IN COMMAND (PIC): 

a. The Pilot in Command of the aircraft is directly responsible for, and is the final authority for 

the operation and safety of the flight. 

b. In an in-flight emergency requiring immediate action, the PIC may deviate from any rule or 

procedure to the extent required to meet that emergency in order to protect life and 

property. 

c. The PIC will assure that all Preflight Checks are completed and documented and execute full 

compliance with all manufacturer’s operation and maintenance documents. 

d. The PIC will carry out the flight plan as agreed to and approved by site leadership. 

e. The PIC is responsible for maintaining Visual Line-of-Sight (VLOS) with the aircraft during 

operations by direct view with human eyesight. 

2. VISUAL OBSERVER (VO): 

a. The Visual Observer is a trained person who assists the PIC with the duties associated with 

collision avoidance, including avoidance of traffic, clouds, obstructions and terrain. 
Procedure Doc: SMA-UAS-001 

b. The VO will maintain Visual Line-of-Sight (VLOS) with the aircraft at all times during 

operation. 

c. The VO will travel to required locations on the site, as specified in the flight plan, and be 

able to communicate verbally with the PIC at all times during the operation. 

HEALTH, SAFETY AND ENVIRONMENTAL PROCEDURES

3. Personnel Protective Equipment: The PIC and VO will at all times abide by local site safety rules 

regarding wearing of protective equipment. This typically consists of ANSI approved hard hats and 

safety glasses, but in many locations may also include reflective vests and safety shoes. 

4. Hazard Communication: The UAS operation does not involve use of any hazardous materials. The 

site being surveyed may contain and process such materials in which case the site owner or 

contractor is responsible. During the preflight planning meeting the PIC and VO should ask if there 

are any precautions required of them for personnel protection and comply with these. Material 

Safety Data Sheets (MSDS) should be available to aid in any awareness needed for specific 

substances. 

5. Permits: In compliance with local site safety procedures all required permits must be obtained and 

approved. All safety and environmental requirements by those permits and referenced site 

procedures must be followed at all times. 

6. Equipment Safety Inspection: Prior to each flight, the PIC will inspect the 3DR Model 4X, including 

the ground control station, in accordance with the Preflight Checklist to assure that the system is 

airworthy as determined by the PIC on the basis of these checks and manufacturer’s 

documentation. If the Preflight Check indicates any unsafe conditions or a non-functioning safetycritical part, the flight will not commence until the needed maintenance is performed and a 

satisfactory Preflight Check can be completed. 

7. Site Approval: No operations will start without review and approval of site leadership and 

communication of the site plan and schedule with site personnel. 

8. Conditions: All operations must be in daylight hours as defined in 14 CFR Section 1.1, and under 

visual meteorological conditions (VMC). No operations will be conducted less than 500 feet 

below or less than 2,000 feet horizontally from a cloud when visibility is less than 3 statute 

miles from the PIC. 

9. Safe Power Levels: As standard operating procedure, the PIC will immediately return the Model 4X 

to the Home Point for a battery swap when the battery level reaches 25%. 

10. Collision Avoidance: Altitude and distance limits will be entered into the Flight Control System prior

to commencement of flight. This will restrict the operation to the SITECH Mid-Atlantic or SITECH 

Client property. The Failsafe Function integral with the Flight Control System will assure the aircraft 

stays within the area deemed safe for operation, as well as assure altitudes do not exceed 300 feet 

AGL. By the Visual Line-of-Sight (VLOS) method the PIC with assistance of the VO will assure the 

aircraft avoids any other possible traffic, with clouds, obstructions and terrain. 
Procedure Doc: SMA-UAS-001 

11. Proximity of Airports: Operations will be restricted to Class G airspace. No operations will occur 

within 5 miles of an airport reference point as denoted on a current FAA-published aeronautical 

chart, unless a letter agreement with the airport’s management is obtained, and the operation is 

conducted in accordance with a Notice to Airman (NOTAM) as required by the Certificate of 

Waiver or Operation (COA). 

12. Emergencies: Operations will be aborted immediately if the PIC encounters unpredicted obstacles 

or emergencies. Safe descent and landing procedures will be followed in accordance with operating 

documents. 

13. Incident Reporting: Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA will be reported to the 

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Site leadership will be notified immediately as specified by local procedures. 

14. Qualifications and Training: The PIC will have logged hours and certifications as described in the 

Qualifications for the PIC section of this procedure. The VO will be trained by the PIC regarding duty

stations for the VLOS method as required by the flight plan and the procedures for verbal 

communication. 

PREREQUISITES

15. Operation of the UAS cannot proceed without full compliance with 

a. Health, Safety and Environmental Precautions 

b. Qualifications for the Pilot in Command (PIC) 

c. Preflight Planning 

d. Preflight Checklist 

These are covered in the so-named sections of this document. 

QUALIFICATIONS FOR THE PILOT IN COMMAND (PIC)

16. Certifications: Operations will be conducted by a Pilot in Command (PIC) possessing at least a 

private pilot certificate and at least a current third-class medical certificate. 
Procedure Doc: SMA-UAS-001 

17. Logged Hours: Prior to operations the PIC will have supply previously logged flight time with a multirotor UAS. Training, proficiency, and experience-building flights in dedicated training sessions will

be included in the accumulated and logged hours. 

18. Currency: Prior to operations, the PIC will have accumulated and logged time as a UAS pilot 

specifically operating the 3DRobotics 4X. The PIC will have accomplished, during dedicated 

training sessions, 3 take-offs and landings in the preceding 90 days as required by 14 CFR Section 

61.56. 

19. Emergency and Evasive Maneuvers: The PIC will have demonstrated the ability to safely operate the 

3DR 4X in a manner consistent with how it will be operated in SITECH M.A. and SITECH Client 

properties, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. The logged hour’s reference above will document this. 

PREFLIGHT PLANNING

20. Plan: A meeting with site leadership will be conducted to establish the purpose and objectives of 

the operation. Following that meeting, a path of flight over the SITECH Mid-Atlantic or SITECH M.A. 

Client property to achieve the operation’s objectives will be displayed on a site plot plan drawing 

showing 

a. Starting and ending points 

b. Required intermediate waypoints for hovering or change of direction 

c. Approximate altitudes along the flight path 

d. Areas of special interest to be surveyed 

e. Clearly marked obstructions or areas to avoid 

f. Station points for the PIC and VO at various stages of the operation 

g. Camera on and off points, angle of view, as well as still and video requirements along the 

flight path. 

21. Walk Around: The PIC, the VO, and site leadership will walk (or drive if practical) the site in 

accordance with the above plan with the aim to observe any additional details that should be 

taken into account in the flight plan. The flight plan will then be adjusted accordingly. 

22. Approval: This flight plan will be thoroughly reviewed with site leadership and signed off by both 

the PIC and site leadership. 
Procedure Doc: SMA-UAS-001 

PREFLIGHT CHECKLIST

23. Preflight Checks: As a minimum, the following items will be checked prior to initiating any 

operation. (A form to check off and document completion of these checks is included at the end of 

this procedure document.) 

a. Operations must be in daylight hours and under visual meteorological conditions (VMC). 

b. Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for 

each leg of the flight clearly marked. 

c. Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and 

structures unless protective barriers or structures are present, or permission is granted, or 

such operations present no hazard to the Pilot in Command, the Visual Observer, trainees, 

and other essential persons. 

d. Flight plan and schedule has been reviewed with site leadership and communicated to all 

SITECH M.A. and Client personnel in the area. 

e. Remote control, smart battery, range extender, and smart phone are fully charged. 

f. Propellers are mounted correctly. 

g. Gimbal clamp has been removed. 

h. Damping absorbers are in good condition, not broken or worn. 

i. Anti-drop kits have been mounted correctly. 

j. Camera lens cap has been removed. 

k. Micro-SD card has been inserted. 

l. Gimbal is functioning as normal. 

m. Control Software app can connect to the camera. 

n. Compass has been calibrated. 

o. Flight radius and altitude limits have been set with the Agisoft© software, not to exceed 

400 ft. AGL altitude, and radius limited to the property boundaries of SITECH or SITECH 

Client site. 

p. The Visual Observer (VO) is stationed at the required initial observation point according to 

the flight plan and in view of the Pilot in Command (PIC) and has means for continual verbal 

communication. 
Procedure Doc: SMA -UAS-001 

q. There are no inoperable components. 

r. All site required safety permits are approved in in possession of the PIC. 

s. A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and 

not less than 48 hours prior to the operation. 

t. Flight Indicator Lights on the aircraft verify that the Home Point is set to current location. 

CAUTION

Flight of the UAS must not proceed unless the Home Point is set in the Flight Control System 

utilizing the manufacturer’s procedures prior to flight. This will assure that the Fail Safe 

Function returns the aircraft to the PIC in case any of the failure scenarios are encountered. 

u. Motors can start and function as normal. 

v. Record the Preflight Check, date and sign, and file it in the Equipment Inspection and 

Maintenance Record Book. 

MANUFACTURERS GUIDELINES

24. All operations will be conducted in accordance with the manufacturer’s required procedures for safe 

flight. These requirements are specified in the following documents which will have been used to 

guide flight instruction for the PIC. 

a. 3DRobotics Quad 4X Operators Manual 

b. 3DRobotics Safety Instructions 

c. 3DRobotics Mission Planner 

EQUIPMENT INSPECTION AND MAINTENANCE

25. Preflight Inspection: In accordance with the Preflight Check procedure above, the PIC will complete 

a visual inspection and assessment of the aircraft and determine airworthiness. The Preflight 

Checklist Form will record each item listed to verify that it has been checked. 

26. Record Keeping: Preflight Checklists will be signed and dated by the PIC and filed in an Equipment 

Inspection and Maintenance Record Book. 

27. Acceptance: If the Preflight Check indicates any unsafe conditions or a non-functioning safetycritical part, the flight will not commence until the needed maintenance is performed and a 

satisfactory Preflight Check can be completed and the aircraft is accepted as airworthy by the PIC. 
Procedure Doc: SMA-UAS-001 

28. Repairs and Alterations: 

a. All maintenance, repairs, and alterations performed will be documented in detail with 

description of work, parts, names of repair persons, date, and will be filed in the Equipment 

Inspection and Maintenance Record Book. 

b. All repairs and alterations will be done in accordance with the manufacturer’s published 

recommendations. 

REFERENCES

• 3DRobotics Model X4 Specifications 

• 3DRobotics User’s Manual 

• 3DRobotics Electrical and Communications Instructions Manuals 

• 3DRobotics Safety and Mission Planning Instructions
Procedure Doc: SMA-UAS-001 

Preflight Checklist Form SITECH Mid-Atlantic, LLC 

Checklist Number UAS-001-01 Type Operation

Authored By Ed Upchurch Revision Number 10/6/2015

Reviewed By Steve Denty Next Review Date 10/15/2015

Approved By Ed Upchurch Approved Date 10/20/2015

Check each item as verified complete: 

o Operations must be in daylight hours and under visual meteorological conditions (VMC). 

o Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for each leg of 

the flight clearly marked. 

o Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and structures 

unless protective barriers or structures are present, or permission is granted, or such operations 

present no hazard to the PIC, the VO, trainees, and other essential persons. 

o Flight plan and schedule has been reviewed with site leadership and communicated to all 

SITECH and Client personnel in the area. 

o Remote control, smart battery, range extender, and smart phone are fully charged. 

o Propellers are mounted correctly. 

o Gimbal clamp has been removed. 

o Damping absorbers are in good condition, not broken or worn. 

o Camera lens cap has been removed. 

o Micro-SD card has been inserted. 

o Gimbal is functioning as normal. 

o Controller Software app can connect to the camera. 

o Compass has been calibrated. 

o Flight radius and altitude limits have been set with the 3DRobotics Assistant software, not to exceed 

400 ft. AGL altitude, and radius limited to the property boundaries of SITECH or SITECH Client site. 

o The Visual Observer (VO) is stationed at the required initial observation point according to the flight 

plan and in view of the Pilot in Command (PIC) and has means for continual verbal communication. 

o There are no inoperable components. 

o All site required safety permits are approved in in possession of the PIC. 

o A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and not less 

than 48 hours prior to the operation. 

o Motors can start and function as normal. 

o Flight Indicator Lights on the aircraft verify that the Home Point is set to current location. 

o Record the Preflight Check, date, sign, file it in Equipment Inspection and Maintenance Record Book. 

PIC Printed Name PIC Signature Date
Appendix C 

3DRobotics X4 Instruction Manual 

Attached as Separate Document 
Appendix D 

Pilot In Charge (PIC) 

Stephen C. Denty 

Commercial Pilot 

 Airplane Single Engine Land 

 Rotorcraft-Helicopter 

 Glider 

 Instrument - Airplane and Glider 

Private 

 Airplane Multiengine Land 

 

Flight Instructor 

 Airplane Single Engine 

 Rotorcraft-Helicopter 

 Instrument Airplane and Helicopter 

 

Approximately 15,000 flight hours PIC 

Steve has been granted a 333 Exemption DJI Inspire, DJI Phantom 2, and DJI Phantom 3 

Exemption #13077, FAA Docket No. FAA-2015-1507