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 Exemp tion

Dear Sir or Madam,

SITECH Mid-Atlantic, L.L.C. hereby submits to the F ederal 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 liste d 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/sectio n_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, Ag riculture and Survey for Construction industries. It provides precision GPS machine control, robotics , laser guidance instruments for the aforementioned industries. SITECH also provides sof tware 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 descr ibed.
SITECH Mid-Atlantic provides a single vendor soluti on in heavy industrial construction, maintenance, estimating and heavy hauling, and cons ulting services for over 15 years. Consultancy is provided to assist Growers and Construction clie nts to optimize yields, protect the environment and efficiently manage construction projects for bu ilding 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 Carolin a. The major trade areas are the states of North Carol ina, South Carolina, Virginia and West Virginia.

Vendor and client recognition of our performance ha s consistently ranked us among the top heavy civil, agriculture, mining and marine. We are Trimble Navi gation’s largest heavy civil precision GPS dealer i n North America. We are a data company at our core ut ilizing 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.comPurpose for the Exemption

SITECH Mid-Atlantic, L.L.C. desires to utilize an u nmanned aircraft system (UAS), herein described, to accomplish aerial photography, surveys and assessme nts 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 exemp tion is sought: This listing matches the list on page 7 of the FAA’ s “Public Guidance for Petitions Filed under Sectio n 333”, Rev. 9/25/2014.

14 CFR 21, Subpart H –Airworthiness Certificates

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

14 CFR 91.7 (a), Airworthiness required for operati on

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 eac h 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 an d 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 e ight propeller aircraft, known as X8. The quad version is what will be utilized by SITECH.

The 3DRobotics X4 will utilize GoPro 3+ Black light weight camera (or equivalent) mounted to a three-way gimbal for capturing aerial still photogr aphs 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 s peed for SITECH Mid-Atlantic purposes will
be lower as outlined in this document.

The 3DRobotics X4 is equipped with a built-in Fligh t Control System which includes an integral
inertial sensor and a barometric altimeter that mea sure both attitude and altitude. Included is a shielded, anti-static compass which reads geomagnet ic information and assists in accurately calculating position and altitude.

The Flight Control System includes a Failsafe Funct ion. Multiple ways are provided for handling
failsafe conditions. GPS failsafe’s are enabled if the aircraft has lost GPS lock or GPS communication s are lost for 5 seconds or more when operating in fl ight mode that requiring GPS. The aircraft will enter one of two preset conditions, 1) controlled l anding or 2) return manual control to the PIC. The
PIC will not be able to switch to GPS until the air craft has landed and flight controls are checked an d reset. If GPS mode is not active, Failsafe will ex ecute a controlled descend and automatic landing.

Through the designated Flight Assistant software (A gisoft, 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 i n 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 docume nt:

• Appendix A – 3DRobotics X4 Specifications

• Appendix B – 3DRobotics X4 Operating Procedure

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

• Appendix D – Pilot In Charge Information

For ease of reference, the 3DRobotics is included i n FAA Section 333 Exemption No. 11335 granted on April 16, 2015 to Voler. Inc. and FAA Se ction 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 deta iled procedures):

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

o Area to be surveyed is defined on a plot plan drawi ng 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-partic ipating 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 C ommand, the Visual Observer, trainees, and other essential persons.

o Flight plan and schedule has been reviewed with sit e leadership and communicated to all SITECH Mid-Atlantic and Client personnel in the are a.

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 wit h 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 requir ed 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 i n possession of the PIC.

o A Notice to Airmen (NOTAM) has been requested not m ore 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 frequen cy 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 P ilot in Command (PIC) possessing at least a private pilot certificate and at least a current th ird-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 a t least 10 hours logged as a UAS pilot with a multi rotor UAS. Training, proficiency, and experience-b uilding flights in dedicated training sessions will be included in the accumulated and logged hours.

Currency: Prior to operations, the PIC will have ac cumulated 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 landin gs 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 emergenc y maneuvers and maintaining appropriate distances from people, vessels, vehicles and struct ures. All hours will be logged and recorded.

5. Pilot in Control (PIC) - Medical

As described above, in “4. Qualifications for the P ilot in Command (PIC)”, the PIC will possess at lea st 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-to wered airport reference point as denoted on a current FAA-published aeronautical chart, unless a letter agreement with the airport’s managementis obtained, and the operation is conducted in acco rdance with a Notice to Airman (NOTAM) as

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

The 3DRobotics X4 and will be utilized to demonstra tion, photo, video, survey construction sites and agriculture sites in accordance with customer r equirements. The use of small unmanned aircraft systems provides more immediate and thorou gh information than is presently available by
other means. In some circumstances man lifts and st ructures have had to be erected for observation, measurement and acquisition of data. E xpenses for scaffolding, rental of manned aircraft, rental of equipment, and lost time is sav ed. 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 Con trol System prior to commencement of flight. This will restrict the operation to the SITECH Mid-Atlan tic or SITECH M.A. Client property. The Failsafe Function integral with the 3DRobotics will assure t he 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 sp eed of 30 knots. In order to conserve power, and thereby maximize flight time, and to assure goo d quality still photographs and video, both\either aircraft will be operated at a slow spe ed 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 Cont rol 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 operat e 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 t han 500 feet below or less than 2,000 feet horizontally from a cloud when visibility is less t han 3 statute miles from the PIC.

Operations will be aborted immediately if the PIC e ncounters unpredicted obstacles or emergencies. Safe descent and landing procedures will be followe d in accordance with operating documents.8. Description of the Area of Intended Operations

As described in “6. Description of Intended UAS Ope rations”, 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 t he 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-to wered 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 acco rdance 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 oper ations will include a Visual Observer (VO). The VO will assure that the Phantom 2 Vision+ is always wi thin their visual line-of-sight (VLOS), as well as the PIC’s, at all times. The VO and the PIC will be abl e to communicate verbally at all times utilizing tw oway radios available at SITECH M.A. and SITECH Clie nt sites.

11. Procedures for Preflight Safety Assessment

Prior to each flight, the PIC will inspect the 3DRo botics including the ground control station, in accordance with the Preflight Checklist (see “2. Pr ocedures for Ensuring UAS Is In a Condition Safe for Flight”). If the Preflight Check indicates any unsafe conditions or a non-functioning safety-criti cal part, the flight will not commence until the needed maintenance is performed and a satisfactory Preflight Check can be completed. All maintenance a nd alterations performed will be documented and filed in the Equipment Inspection and Maintenan ce Record Book.

12. Notifications

In accordance with the COA, a Notice to Airmen (NOT AM) will be requested not more than 72 hours in advance and not less than 48 hours prior to an o peration.

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 product s and parts. Subpart H specifies requirements for Airworthiness Certificates for various aircraft typ es. Small unmanned aircraft systems are not specifically called out and addressed in these rule s.

SITECH M.A. will, in lieu of airworthiness certific ation 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 Pref light Checks are completed and documented and there is full compliance with all manufacturer’s op eration and maintenance documents.

Due to consideration of the size, weight, speed, an d limited operating area associated with SITECH’s proposed 3DRobotics 4X we believe it will not creat e 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 requ irements of part 36.

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

14 CFR 61.113 (a) and (b) prohibit private pilots f rom fulfilling the role of PIC if the aircraft is c arrying property for compensation, unless the flight is onl y 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 P IC 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 a n exemption from these parts of 14 CFR.

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

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 describe d herein. The PIC will assure that all Preflight Checks are completed and documented and execute ful l 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 fam iliar with aircraft performance under expected values of airport elevation and runway slope, aircr aft gross weight, and wind and temperature.Since the 3DRobotics 4X will not be operating out o f airports this rule is not applicable. On this

basis, and on the basis that the operating document s 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 crewm embers. 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 ins truction and requires that the aircraft used for flight instruction have fully functioning dual cont rols. The details pertain to manned airplanes and are not applicable to a small unmanned aircraft sys tem such as the 3DRobotics Flight training will be required for the 3DR 4X pilot as detailed on pag e 5 herein, “4. Qualifications for the Pilot in Command (PIC).” Compliance with these training requ irements with logged hours, in combination with a private pilot’s license and current third-cl ass medical certificate, assure that the required competency for safely operating the 3DRobotics 4X w ill 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 per mitted below 500 feet above the surface, except over open water and sparsely populated areas. The p roposed use of the 3DR 4X is specifically for altitudes that range from the surface to maximum 40 0 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 b e 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 suitab le for manned airplanes, the 3DR 4X has barometric altimeter and GPS derived altitude capab ilities. All altitudes reported to Air Traffic Control (ATC) will be in feet above ground level (A GL). 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 condi tions) there is enough fuel to fly to the first point of intended landing and, assuming normal crui sing speed, (1) during the day, to fly after that for at least 30 minutes, or (2) at night, to fly af ter 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 th e 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 th e 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 immed iately return the 3DRobotics 4X to the Home Point for a battery swap when the battery leve l reaches 25%.

On the basis of these specific safety features of b attery power level monitoring, and operating procedures, an exemption from this rule is requeste d.

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), a nd 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 i nspect the 3DR Model 4X and ensure that it is in a condition for safe flight prior to beginning any op eration. We propose that adherence to the operating documents describing the requirements for maintenance, inspection, and recordkeeping, are sufficient to ensure that safety is not adverse ly affected.PUBLIC BENEFIT

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

• Public Safety: Common practice for industrial facil ity construction projects and periodic site- wide industrial facility visual assessment involves util ization of manned aircraft. The potential risk to l ife and property is order of magnitudes less for use of a s mall unmanned aircraft system as compared to conventional aerial photography by manned fixed win g aircraft.

• Work Place Safety: In order to accomplish inspecti ons 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 compl iance with OSHA rules governing such work is crucia l for life safety. The ultimate protection, however, woul d be to not involve personnel in such activity and instead complete this work with an unmanned aircraf t system.

• Energy Savings and Environmental Protection: Reduct ion of frequency of manned aircraft used to do aerial photography and surveys for construction and agriculture sites results in burning less fuel the reby saving energy and reducing emissions of combustion gases.

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

The key features of the proposed 3DRobotics Model 4 X 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 req uired 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 immedia te return to the Home Point and safe landing under failure scenarios, thereby preventing injury or dam age.

• Visual Line-of-Sight (VLOS) operation provided by t he PIC and the Visual Observer (VO), and their ability to communicate verbally at all times, assur es full operational control.

Detailed operations and maintenance procedures, inc luding a Preflight Checklist, provide assurance of mechanical integrity and full functioning of 3DR Mo del 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) an d (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 see king an exemption to utilize an unmanned aircraft system (UAS) to accomplish aerial photogra phy, 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 abov e show conical nuts; X8+ ships with hex nuts.)

• 

## Controller: Taranis X9D

• 

## Frame Type: X

• 

## Propellers: APC Propeller 11x4.7 SF (4), APC Propel ler 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 paylo ad 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 respon sibilities and tasks required to safely and success fully operate a 3DRobotics Model 4X unmanned aircraft sys tem to accomplish a mission to survey SITECH or SITECH Client construction sites or agriculture fac ilities.

This is a Critical Procedure that requires sign off of the Preflight Checklist f or safety and full compliance with all steps as required.
To properly use this procedure, personnel must be a ware of safety related information contained in the Health, Safety and Environmental Precautions sectio n of this document.

RESPONSIBILITIES

1. PILOT IN COMMAND (PIC):

a. The Pilot in Command of the aircraft is directly re sponsible for, and is the final authority for the operation and safety of the flight.

b. In an in-flight emergency requiring immediate actio n, the PIC may deviate from any rule or procedure to the extent required to meet that emerg ency in order to protect life and property.

c. The PIC will assure that all Preflight Checks are c ompleted and documented and execute full compliance with all manufacturer’s operation and ma intenance 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) wi th the aircraft at all times during operation.

c. The VO will travel to required locations on the sit e, as specified in the flight plan, and be able to communicate verbally with the PIC at all ti mes 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 typ ically consists of ANSI approved hard hats and safety glasses, but in many locations may also incl ude reflective vests and safety shoes.

4. Hazard Communication: The UAS operation does not in volve use of any hazardous materials. The site being surveyed may contain and process such ma terials in which case the site owner or contractor is responsible. During the preflight pla nning 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 ai d in any awareness needed for specific substances.

5. Permits: In compliance with local site safety proce dures 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 t he needed maintenance is performed and a satisfactory Preflight Check can be completed.

7. Site Approval: No operations will start without rev iew and approval of site leadership and communication of the site plan and schedule with si te personnel.

8. Conditions: All operations must be in daylight hour s as defined in 14 CFR Section 1.1, and under visual meteorological conditions (VMC). No operatio ns will be conducted less than 500 feet below or less than 2,000 feet horizontally from a c loud 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 batte ry level reaches 25%.

10. Collision Avoidance: Altitude and distance limits w ill be entered into the Flight Control System prior to commencement of flight. This will restrict the o peration to the SITECH Mid-Atlantic or SITECH Client property. The Failsafe Function integral wit h the Flight Control System will assure the aircraf t 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 cl ouds, obstructions and terrain.Procedure Doc: SMA-UAS-001

11. Proximity of Airports: Operations will be restricte d to Class G airspace. No operations will occur within 5 miles of an airport reference point as den oted 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 (NO TAM) as required by the Certificate of Waiver or Operation (COA).

12. Emergencies: Operations will be aborted immediatel y 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 flig ht operation that transgresses the lateral or vertical boundaries of the operational area as defi ned by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hou rs. 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 logg ed hours and certifications as described in the Qualifications for the PIC section of this procedur e. The VO will be trained by the PIC regarding duty stations for the VLOS method as required by the fli ght plan and the procedures for verbal
communication.

PREREQUISITES

15. Operation of the UAS cannot proceed without full co mpliance 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 P ilot in Command (PIC) possessing at least a private pilot certificate and at least a current th ird-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-b uilding flights in dedicated training sessions will be included in the accumulated and logged hours.

18

. Currency: Prior to operations, the PIC will have ac cumulated and logged time as a UAS pilot specifically operating the 3DRobotics 4X. The PIC w ill 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 o perated in SITECH M.A. and SITECH Client properties, including evasive and emergency maneuve rs 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 conduc ted to establish the purpose and objectives of the operation. Following that meeting, a path of fl ight over the SITECH Mid-Atlantic or SITECH M.A. Client property to achieve the operation’s objectiv es will be displayed on a site plot plan drawing showing

a. Starting and ending points

b. Required intermediate waypoints for hovering or cha nge 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 w ill walk (or drive if practical) the site in accordance with the above plan with the aim to obse rve 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 revie wed 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 comple tion of these checks is included at the end of this procedure document.)

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

b. Area to be surveyed is defined on a plot plan drawi ng 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-partic ipating 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 C ommand, the Visual Observer, trainees, and other essential persons.

d. Flight plan and schedule has been reviewed with sit e 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 wit h the Agisoft© software, not to exceed 400 ft. AGL altitude, and radius limited to the pro perty boundaries of SITECH or SITECH
Client site.

p. The Visual Observer (VO) is stationed at the requir ed 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 m ore 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 fl ight. This will assure that the Fail Safe Function returns the aircraft to the PIC in case an y 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 fol lowing 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 Prefli ght 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 veri fy 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 un safe conditions or a non-functioning safetycritical part, the flight will not commence until t he needed maintenance is performed and a satisfactory Preflight Check can be completed and t he 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 accorda nce with the manufacturer’s published recommendations.

REFERENCES

• 3DRobotics Model X4 Specifications

• 3DRobotics User’s Manual

• 3DRobotics Electrical and Communications Instructio ns Manuals

• 3DRobotics Safety and Mission Planning InstructionsProcedure 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 visu al meteorological conditions (VMC).

o Area to be surveyed is defined on a plot plan drawi ng with path of flight and altitudes for each leg o f the flight clearly marked.

o Flight path is at least 500 ft. from all non-partic ipating persons, vessels, vehicles and structures unless protective barriers or structures are presen t, 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 sit e 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 wit h the 3DRobotics Assistant software, not to exceed 400 ft. AGL altitude, and radius limited to the pro perty boundaries of SITECH or SITECH Client site.

o The Visual Observer (VO) is stationed at the requir ed initial observation point according to the fligh t 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 m ore 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