February 3, 2015 

U.S. Department of Transportation 

Docket Operations M-30 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Madam, Sir, 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") 

and 14 C.F.R. Part 11, Vertical Sciences, Inc. ("VSI"), an operator ofthe DJI S-1000+ Unmanned 

Aircraft System ("S-1 000+") and a DJI Phantom 2 Vision+ ("Vision"), seeks an exemption from 

the Federal Aviation Regulations ("F ARs") listed below: 

• 14 C.F.R. 21 

• 14 C.F.R. 45.23 

• 14 C.F.R 45.29 

• 14 C.F.R. 61.133(a) 

• 14 C.F.R. 91.7(b) 

• 14 C.F.R. 91.9(b)(2) 

• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203(a) & (b) 

• 14 CFR Subpart E (91.401- 91.417) 

VSI is comprised of licensed professional engineers, professional geologists, certified engineering 

geologists, private and commercial pilots, and software specialists trained in working in the civil 

and geotechnical engineering, surveying, environmental, and construction fields. Most of our 

professionals have over 30 years of experience and our pilots, over 5 years of experience that 

includes flying unmanned aircraft. The requested exemption would authorize commercial 

operations using the S-1 000+ and Vision for mapping, geotechnical, and survey applications. 

These operations will be subject to strict operating requirements defined in the S-1000+ Pilot 

Operating Handbook and Vision Pilot Operating Handbook and conditions defined by the Safety 

Code of the Academy of Model Aeronautics (see Annex B), in order to ensure at least an 

equivalent level of safety to currently authorized operations using manned aircrafts. 

The S-1000+ and Vision will be operated by an individual who fulfill the following requirements: 

• Has successfully passed a manufacturer's training program for the S-1 000+ and Vision; 

• Has a Private Pilot license; 
1. CHARACTERISTICS OF THE AIRCRAFT 

The S-1000+ is a small (41 inches between rotors) and ultra-light (maximum take-off weight of 

24 pounds) platform made of composite materials. The Vision is also a small (13.8 inches 

between rotors) and ultra-light (maximum take-off weight of 3.1 pounds) made of composite 

materials. Those aircraft perform pre-programmed precision aerial mapping missions thanks to 

on-board GPS and the related flight management software that allows the operator to plan safely 

and efficiently a mission in 3D, and then monitor it in real-time. With an attached camera, the S1 000+ takes a collection of high-definition still images that are used later to generate maps and 

contour lines of the surveyed area. The Vision takes high-definition video that is used later to 

generate maps, photographs, and contour lines of the surveyed area 

The four main characteristics of the S-1 000+ and Vision are: 

a. Very light weight 

The S-1 000+ and Vision are so light that the operator can launch them by hand and let them land 

on almost any surface without requiring a parachute or landing net. Its low impact energy in case 

of a controlled emergency landing, also significantly reduces the risk of hazardous situations. 

Finally, the rotor arms of the S-1 000+ are detachable and made of rounded composite materials 

with no sharp edges. The rotor arms of the Vision are rounded and made of plastic with no sharp 

edges. 

b. Electric-powered 

The S-1 000+ and Vision are electric powered. The four and eight motors, respectively, are very 

quiet and reliable. 

c. Semi-automatic flight 

The artificial intelligence incorporated within the S-1 000+ and Vision autopilot system 

continuously analyzes data from the Inertial Measurement Unit and from the onboard GPS and 

takes care of all the aspects of the flight under the supervision of the operator. 

d. Option for Manual control 

Additionally, the S-1 000+ and Vision provide an override capability that allows the operator to 

take manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and 

also suspend automated operations and take manual control of the aircraft should it become 

necessary to respond emergent circumstances, thanks to the remote controller provided with the 

system. 

2. APPLICATIONS 

The aircraft will be utilized for gathering geologic, geotechnical, environmental, and survey data 

for mining, public works, and construction-related studies and projects. These areas are typically 

2 
rural and will not include congested areas. Those data will be used for creating highly accurate 

maps and geo-rectified orthophotographs. In addition, the aircraft will allow gathering of 

geologic and geotechnical data in areas where previously, a geologist, engineer, or others would 

be required to repel down slopes or be situated at the base of rock and unstable slopes, thus 

reducing the danger to and increasing the safety for those professionals. Additionally, the use of 

the S-1 000+ and Vision will negate the need for conventional manned helicopters to perform 

work where repelling and access is not possible, thus, reducing risk to pilot and passenger of the 

helicopter, and personnel on the ground. The use of UAV will also reduce the need for 

conventional aircraft in gathering photogrammetric data, thus improving public safety. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Operating requirements 

Grant of the exemption to VSI for the S-1000+ and Vision will be subject to the following 

operating conditions, based on the operating conditions set forth by the Academy of Model 

Aeronautics (see Appendix B). The main restrictions are summarized below: 

• Operations to be conducted over private or public controlled-access property where 

approved; 

• Permission from the land owner/authority required before commencing any flight; 

• Operations over congested areas shall be avoided; 

• Operations must not interfere with manned aircraft operations, must yield the right of way 

to manned aircraft, and operators must See & Avoid other aircraft and obstacles at all 

times. Use of an ADS-B receiver by the VO will assist in monitoring the presence of other 

proximal aircraft; 

• Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight 

hours; 

• Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually 

monitored at all times; 

• VLOS guaranteed with a GPS geo-fence around operator of0.5 miles; 

• Flight ceiling pre-programed at 400 feet; 

• All operations conducted within 5 miles from an airport shall only be initiated after verbal 

coordination with the airport authority, or air traffic control when a control tower is 

present at the airport; 

• All operations shall comply with required permissions and permits established by 

territorial, state, county or city jurisdictions; including local law enforcement, fire, or other 

appropriate governmental agencies; 

• The S-1 000+ and Vision operations will be compliant with existing safety procedures 

inherent to the activities of the related company. 

b. Operator Requirements 

The S-1 000+ and Vision Pilot in Charge (PIC) will have a Private Pilot license. The PIC and 

Visual Observer (VO) will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system 

and will complete a course of maintenance instruction as part of their initial training. Due to the 

3 
simplicity of the system, we do not anticipate the need for a supplemental pilot in the field. 

3. CONCLUSION 

We submit that the combination of the aircrafts' light weight, historically demonstrated flight 

performance, fully qualified flight crew and strict operation under the guidelines established 

in 8900.227, the FAA can have confidence that the operation will have an equivalent or 

greater level of safety of manned aircraft performing the same mission. 

The name and contact information of the applicant are: 

Vertical Sciences, Inc. 

Attn: James Bianchin 

2308 Lake Redding Drive 

Redding, CA 96003 

Phone: 530-949-6241 

Email: jim.bianchin@gmail.com 

Respectfully Submitted, 

VERTICAL SCIENCES, INC. 

James A. Bianchin, PG, CEG 

President 

Appendices 

A. Exemption Request and Equivalent Level of Safety 

B. Academy of Model Aeronautics Safety Requirements 

C. Privacy Issues 

D. Safety Case 

E. Maintenance Procedures 

F. User Manual 

G. Training Program 

H. Aviation Experience 

4 
APPENDIX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

VSI requests an exemption from the following regulations as well as any additional regulations 

that may technically apply to the operation of the S-1 000+ and Vision: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for UAS, we request an experimental 

certificate be issued for the S-1000+ and Vision under either or both of the following provisions: 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new 

aircraft equipment, new aircraft installations, new aircraft operating 

techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests 

and other operations to show compliance with the airworthiness 

regulations including flights to show compliance for issuance of 

type and supplemental type certificates, flights to substantiate major 

design changes, and flights to show compliance with the function 

and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market 

surveys, sales demonstrations, and customer crew training, we would expect that an 

experimental certificate would permit our commercial purpose as well. 

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the fact that the aircraft are lightweight, we propose 

that the S-1 000+ and Vision will be at least as safe, if not safer, than a conventionally 

certificated aircraft performing the same mission. 

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew." The S-1 000+ and Vision are too small to 

carry documentation, do not have an entrance, and are not capable of carrying passengers or 

crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for these aircraft by the FAA will be co-located with the crew at 
the ground control station and available for inspection upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard: 

Manufacturer: DJI 

Model: "S-1 000+" or "Phantom 2 Vision+" 

Serial Number: 15-XXXX 

Registered to: 

Vertical Solutions, Inc. 

123 Shasta Street 

Anytown, CA 12345 

If found please contact: (800)-222-1234. 

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. 

Given the size of the S-1 000+ and Vision (rotor to rotor distance of 41 and 13.8 inches, 

respectively), this requirement is impossible to match. We feel that the permanent placard 

discussed in the previous paragraph will provide the aircraft's registration information should it 

be found on the ground. We will also display at the ground station a high contrast flag or banner 

that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. 

Since the aircraft will operate within 1/2 NM of the ground station, the banner should be visible 

to anyone that observes the aircraft and chooses to investigate its point of origin. 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness 

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

condition. Should the exemption be granted allowing commercial operation of the S-1 000+ 

without an airworthiness certificate, no standard will exist for airworthiness ofthe S-1000+. An 

equivalent level of safety will be achieved by insuring compliance with the S-1 000+ Pilot 

Operating Handbook (flight manual) prior to each flight. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. VSI assumes that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. VSI requests an 

exemption to this requirement since the aircraft is not only too small to carry documentation, that 

the documentation would not be available to the crew. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, 

ii 
approved Pilot Operating Handbook (Appendix F) must be available to the crew at the ground 

station anytime the aircraft is in, or preparing for, flight. 

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The S-1 000+ and Vision 

ground control stations are based on a small hand-held computer and while they do not offer a 

second set of "controls", both the student and instructor can, and will, operate the single set of 

controls simultaneously. Both the S-1 000+ and Vision can be controlled from a ground station 

tablet or from the transmitter so, in essence, they have dual control capability and redundancy. 

With both student and instructor having "hands-on" the controls during flight, we feel that this 

technique meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR § 91.119: Minimum Safe Altitudes 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 400 feet AGL, the S-1 000+ cannot comply with this requirement. 

The equivalent level of safety will be achieved because the S-1 000+ and Vision will only fly over 

property with the permission of the landowner(s) or public agencies. The operator will define 

before every flight a working area radius and a flight area ceiling, preventing the S-1 000+ to go 

beyond the flight area. 

The landowner and the persons who may be on the ground in the flight area will be briefed of the 

expected route of flight and the associated risks to persons and property on the ground. Due to the 

small size of the S-1 000+ and the material with which the S-1 000+ is built, the hazard to persons, 

vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in 

granting the exemption. 

Moreover, the aircraft will not be operated over congested areas nor over any open-air assembly 

of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. 

14 CFR 91.121- Altimeter Settings 

This section requires that 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 below 18,000 feet MSL to: 

• The current reported altimeter setting of a station along the route and within 1 00 nautical 

miles of the aircraft; 

• 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; 

• 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. 

iii 
To provide an equivalent level of safety, the S-1 000+ autopilot calculates the reference altitude 

(ground level) with the on-board GPS during the pre-flight tests. The GPS and barometer data are 

merged with respect to their respective precisions. The GPS provides reliable information to 

correct potential barometric bias, while rapid variations in altitude are detected through the 

barometer. Hence, barometric bias induced by environmental factors is rejected. The IOSD 

telemetry of the S-1 000+ provides the CIP and VO real time flight data via the GPS and also 

performs flight recording. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. 

Given the area of operation for the S-1 000+ and Vision, VSI believes that an equivalent level of 

safety is already achieved with the specific procedure preventing the S-1 000+ or Vision from 

accepting a take-off order if the battery level is below a given value. Moreover, VSI will monitor 

the battery levels of the S-1 000+ and Vision during flight and return the aircraft to home when 

battery levels reach 25 to 30 percent capacity (depending on distance from home). DJI has 

integrated battery level warnings into controllers operated for these aircraft. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

• No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The S-1000+ and Vision weigh only 24 and 3.5 pounds (max take-offweight), respectively. As 

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

them on the UAS. In addition, there is no pilot or passengers on board the aircraft. 

To obtain an equivalent level of safety and meet the intent of 91.203, VSI proposes that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the operator at 

the ground control station in the S-1 000+ and Vision box and available for inspection upon 

request 

14 CFR Subpart E (91.401 - 91.417) -Maintenance, Preventive Maintenance, and 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be "approved for return to service by a person authorized under Part 43.7" 

after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the 

issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep 

records showing certain maintenance work that has been accomplished by certificated mechanics, 

iv 
under Part 43, or licensed pilots and records of approval of the aircraft for return to service. 

VSI proposes that the maintenance of the S-1 000+ and Vision will be accomplished by the 

owner/operator according to the maintenance manual, provided by DJI. VSI requests the FAA 

treat the S-1000+ and Vision training programs as proprietary under 14 C.F.R. 11.35(b) and not 

include these documents in the public docket. 

An equivalent level of safety will be achieved because the S-1 000+ and Vision are small in size, 

they are not a complex mechanical device, and they will operate only in restricted predetermined 

areas. Moreover, the operator is the person most familiar with the aircraft and is best suited to 

maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. 

v 
APPENDIX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS 

v 
Academy of Model Aeronautics National Model Aircraft Safety Code 

Effective January 1, 2014 

A. GENERAL: A model aircraft is a non-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations of this code and is 

intended exclusively for sport, recreation, education and/or competition. All model flights must be conducted in accordance with this safety code and any 

additional rules specific to the flying site. 

1. Model aircraft will not be flown: 

(a) In a careless or reckless manner. 

{b) At a location where model aircraft activities are prohibited. 

2. Model aircraft pilots will: 

(a) Yield the right of way to all human-carrying aircraft. 

(b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document #540-D.) 

(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an airport without notifying the airport operator. 

(d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement. 

(e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane program. (AMA Document 520-A.) 

(D Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. {This 

does not apply to model aircraft flown indoors.) 

(g) Not operate aircraft with metal-blade propellers or with gaseous boosts except for helicopters operated under the provisions of AMA Document #555. 

(h) Not operate model aircraft while under the influence of alcohol or while using any drug that could adversely affect the pilot's ability to safely control the 

model. 

(i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a 

hazard to persons or property. 

Exceptions: 

• Free Flight fuses or devices that burn producing smoke and are securely attached to the model aircraft during flight. 

• Rocket motors (using solid propellant) up to a G-series size may be used provided they remain attached to the model during flight. Model rockets may 

be flown in accordance with the National Model Rocketry Safety Code but may not be launched from model aircraft. 

• Officially designated AMA Air Show Teams (AST) are authorized to use devices and practices as defined within the Team AMA Program Document. 

(AMA Document#718.) 

U) Not operate a turbine-powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #51 0-A.) 

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations unless: 

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. 

{b) An inexperienced pilot is assisted by an experienced pilot. 

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply 

with comparable standards. 

B. RADIO CONTROL (RC) 

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others. 

2. A successful radio equipment ground-range check in accordance with manufacturer's recommendations will be completed before the first flight of a new or 

repaired model aircraft. 

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.) 

(a) Only personnel associated with flying the model aircraft are allowed at or in front of the safety line. 

{b) At air shows or demonstrations, a straight safety line must be established. 

(c) An area away from the safety line must be maintained for spectators. 

(d) Intentional flying behind the safety line is prohibited. 

4. RC model aircraft must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly 

licensed by the FCC are authorized to operate equipment on Amateur Band frequencies. 

5. RC model aircraft will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. (AMA 

Documents #922 and #923.) 

6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors 

closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline. 

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, except to divert it from striking an 

individual. 

8. RC night flying requires a lighting system providing the pilot with a clear view of the model's attitude and orientation at all times. Hand-held illumination 

systems are inadequate for night flying operations. 

9. The pilot of an RC model aircraft shall: 

(a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot. 

(b) Fly using the assistance of a camera or First-Person View (FPV) only in accordance with the procedures outlined in AMA Document #550. 

(c) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560. 

C. FREE FLIGHT 

1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is launched. 

2. Launch area must be clear of all individuals except mechanics, officials, and other fliers. 

3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has completed its function. 

D. CONTROL LINE 

1. The complete control system (including the safety thong where applicable) must have an inspection and pull test prior to flying. 

2. The pull test will be in accordance with the current Competition Regulations for the applicable model aircraft category. 

3. Model aircraft not fitting a specific category shall use those pull-test requirements as indicated for Control Line Precision Aerobatics. 

4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to any above-ground electric utility lines. 

5. The flying area must be clear of all nonessential participants and spectators before the engine is started. 
Academy of Model Aeronautics 

5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262- Membership Services 

www.modelaircraft.org 

11SEE AND AVOID11 GUIDANCE 

A. General: 

•• 

A 'if.~ ACADEMY OF 

MODEL AERONAUTICS 

1. The primary means to avoid collisions between all aircraft flying within our National Airspace System 

(NAS) is "See and Avoid." 

2. Vigilance must be maintained by each person operating an aircraft (whether model or manned) so as to 

"see and avoid" other aircraft. 

3. Model aircraft must avoid manned aircraft. Our privilege to fly model aircraft in the NAS depends on our 

commitment to remain "well clear" of manned aircraft. 

4. Simply avoiding an actual collision is not enough. A "near miss" is not acceptable. 

5. Unless flying at a mixed-use site where manned and model aircraft routinely share airspace through 

their own site-specific rules, model aircraft must fly sufficiently far away from manned aircraft so as not to 

create a collision hazard. 

6. Model aircraft flying must not only be safe, it must be perceived to be safe by the greater manned 

aviation community. Modelers must continually demonstrate their respect for the safety of manned 

aircraft by remaining vigilant and well clear. 

7. Whenever a potential conflict arises between model aircraft and manned aircraft, the pilot of the model 

aircraft must always give way to the manned aircraft. 

8. The pilot of a model aircraft must never assume the pilot of a manned aircraft can see the= model or will 

perform any maneuver to avoid the model's flight path. 

9. Visual Line of Sight is required by the Safety Code. It means that visual contact with the aircraft must be 

maintained without enhancement other than by corrective lenses prescribed for the model aircraft pilot. 

All RC flying must remain clear of clouds smoke or any other obstruction to the line of sight. 

10. "Blue Sky" is a term used to explain the method used to increase separation between a model and a 

manned aircraft in the same vicinity. The modeler should maneuver the aircraft in such a way as to 

increase the amount of blue sky perceived between the model and the manned aircraft. By increasing the 

blue sky separation, the question about depth perception is taken out of the equation and the modeler 

need not worry whether the model is closer to him than the manned aircraft or further away. Increasing 

the blue sky between the model and the manned aircraft automatically increases separation between 

them. 

Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262 I Membership Services I www.modelaircraft.org 
Academy of Model Aeronautics 

5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262 - Membership Services 

www.modelaircraft.org 

•• 

A~A: ACADEMY OF 

MODEL AERONAUTICS 

11. A modeler should never place any consideration for the well-being of the model aircraft above the 

safety of manned aircraft. Maneuvering to avoid the conflict may require that the model aircraft be 

sacrificed. 

12. Free flight models should not be launched with relatively low altitude manned 

aircraft in sight and downwind or headed downwind from the launch site. 

B. Spotters: 

1. Before a flight, the pilot must insure that the spotter understands his/her duties 

and expectations. 

2. A spotter should be used to assist in monitoring the surrounding airspace for manned aircraft whenever 

a flight is expected to exceed 400 feet above the ground and that operation is expected to be in proximity 

to known manned aircraft traffic such as at a mixed-use facility or within three miles of an airport. The 

spotter must have sufficient visual acuity and be mature enough to take this responsibility very seriously. 

3. A spotter should also be prepared to assist his/her pilot in the event that another model aircraft or 

spectators become endangered or in turn are perceived to be a danger to the pilot or the pilot's model 

aircraft. 

4. If a model aircraft pilot experiences what he or she considers a near miss with a manned aircraft, that 

model aircraft pilot should notify AMA Headquarters with a written report of the incident, including action 

taken by the model aircraft pilot to avoid the manned aircraft. This report is intended to help the modeler, 

the club, and the AMA capture as much detail as possible so that it may be used to assist all parties in 

recalling the particulars of the incident at a later time. Call1-800-435-9262 (1-800-IFLYAMA) extension 230 

or 251 for assistance with this report. 

Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262 I Membership Services I www.modelaircraft.org 
Academy of Model Aeronautics 

AMA Advanced Flight Systems Committee 

amaflightsystems@gmail.com 

AMA Document # 560 

Radio Controlled Model Aircraft Operation 

Utilizing Failsafe, Stabilization and Autopilot Systems 

1. DEFINITION OF TERMS: 

Please refer to Page 3, section 7 which contains an alphabetical listing of the definitions of the 

terms in italics that are used in this document. 

2. GENERAL: 

All model aircraft flights utilizing stabilization and autopilot control systems must be conducted 

in accordance with AMA's current National Model Aircraft Safety Code and any additional rules 

specific to a flying site/location. 

3. OPERATIONS- REQUIREMENTS- LIMITATIONS: 

a) AMA members flying radio controlled model aircraft equipped with flight stabilization and 

autopilot systems must maintain VLOS with the aircraft at all times including programmed 

autopilot waypoint flight. 

b) AMA Pilots must be able to instantaneously deactivate programmed flight of autopilot 

systems at any time during flight and resume manual control of the model aircraft. 

c) AMA Pilots must perform an RIC Test Flight of a model aircraft before activating a newly 

installed autopilot or stabilization system and/or after any repairs or replacement of model 

aircraft essential flight systems. 

d) Model aircraft exceeding 151bs and/or ?Om ph may only use an autopilot for a programmed 

"return to launch" (RTL) flight and not for programmed waypoint flying of a predetermined 

course. 

e) STABILIZATION & AUTOPILOT SYSTEMS MAY BE USED FOR/TO: 

• Stabilization/automatically stabilize aircraft to level flight when control sticks are centered. 

• Recovery/activate TRX switch to recover an out of control aircraft to level flight. 

• Heading/activate TRX switch to hold a model aircraft's heading for precision flight path. 

• Altitude/activate TRX switch to maintain fixed aircraft altitude while allowing directional control. 

• Return GPS/activate TRX switch to return aircraft via GPS to launch point. 

• Return FSS/failsafe activated from radio signal loss to return aircraft via GPS to launch point. 

• Fixed circle/activate TRX switch to circle aircraft at point of activation at fixed altitude. 

• Waypointlactivate TRX switch to initiate an autopilot programmed flight path via waypoints. 

• Fencing/autopilot programed to display site unique boundaries on video monitor/goggles. 

PAGE 1 OF 3 (Revision 01/14/2013) 
4. RANGE -ALTITUDE -WEIGHT- SPEED: 

a) One of the requirements in Federal Law (Public Law 112-95 Sec 336 (c) (2) February 14, 

2012) for model aircraft to be excluded from FAA regulations is that model aircraft be 

flown within VLOS of the operator. 

b) Model aircraft must be flown at or below 400 feet AGL when within 3 miles of an airport as 

stated in the AMA Safety Code. 

c) Model aircraft utilizing an autopilot for waypoint flying are limited to a maximum weight 

(including fuel, batteries, and onboard autopilot systems) of 151bs and a speed of 

70mph. 

5. RECOMMENDATIONS & INFORMATION: 

a) If your radio system lacks failsafe capability, consider using programmable digital servos or 

auxiliary failsafe modules. In the event of a radio signal failure these components will 

activate desired safe servo settings or an autopilot for return to base/launch (RTL). 

b) When using an autopilot system the "return to launch" {RTL) feature should be 

programmed to return the aircraft to a safe location and safely terminate the flight should 

manual control of the aircraft be lost. When using RTL, pay particular attention to the 

manufacturer's throttle recommendations to prevent stalling. 

c) The use of stabilization systems is recommended when flying FPV to improve flight 

stability and video quality. 

d) Pilots usually choose to incorporate stabilization and autopilot systems for model aircraft 

flying to enhance flight performance, correct bad tendencies of the model aircraft, 

maintain stability in windy weather, establish precision heading holds for 

takeoffs/landings, flight training for novice pilots, create a steady flight platform for 

cameras, and generally just to make an airplane easier and safer to fly. 

e) When purchasing stabilization and autopilot systems, always try to select quality equipment 

from reputable dealers, ensure for compatibility with other onboard systems, and install 

components according to manufacturers' instructions. 

6. PRIVACY PROTECTION SAFEGUARDS: 

The use of imaging technology for aerial surveillance with radio control model aircraft 

having the capability of obtaining high-resolution photographs and/or video, or using any 

types of sensors, for the collection, retention, or dissemination of surveillance data or 

information on individuals, homes, businesses, or property at locations where there is 

a reasonable expectation of privacy is strictly prohibited by the AMA unless written 

expressed permission is obtained from the individual property owners or managers. 

PAGE 2 OF 3 (Revision 01/14/2013) 
7. DEFINITIONS OF TERMS: 

AMA Pilot is an AMA member who is capable of manually operating an R/C transmitter to 

control a model aircraft's flight path within its safe intended flight envelope without losing 

control or having a collision. 

Autopilot Systems incorporate programmable flight stabilization with an altitude sensor and 

a GPS receiver for accurate positioning and to navigate/control a radio controlled model 

aircraft's flight path. Advanced systems offer software for entering navigable waypoints. The 

flight data waypoints may be saved to autopilot's/GPS memory for programmed flight. 

Essential Flight Systems are any systems or components necessary to maintain 

stable flight within a model aircraft's flight envelope. (This includes primary RIC systems 

and any stabilization or gyros required to maintain stability and heading in certain 

types of model aircraft that would be uncontrollable/unstable without their use). 

Failsafe Systems are designed to minimize or prevent damage and safely terminate a 

flight when a radio controlled model aircraft loses radio signal. Modern radio systems can 

be programmed to position servos to a desired control setting in the event of radio signal 

failure. 

First Person View (FPV) refers to the operation of a radio controlled (R/C) model aircraft 

using an on board camera's cockpit view to orient and control the aircraft. (AMA Document 

#550). 

Flight Envelope is defined as the range of airspeeds, attitudes and flight maneuvers which 

a model aircraft can safely perform/operate for its intended use. 

Non-Essential Flight Systems are any systems or components that are not necessary to 

maintain stable flight within the model aircraft's intended flight envelope. (This includes 

autopilot or stabilization systems that can be activated and deactivated in flight by the pilot 

without affecting manually controlled stable flight). 

RIC Test Flight requires an AMA Pilot to manually operate an R/C transmitter to control 

a model aircraft's flight path and determine if the aircraft is capable of maintaining stable 

flight within its safe intended flight envelope. 

Stabilization Systems are designed to maintain intended model aircraft flight attitudes. 

The pilot can install, program and/or activate a system to stabilize yaw, pitch, or roll or any 

one attitude or combination of attitudes. Systems are often based on rate/heading hold 

gyros or inertial motion sensors utilizing multi-axis gyros and accelerometers for 

attitude stabilization. 

Visual Line of Sight (VLOS) is the distance at which the pilot is able to maintain visual 

contact with the aircraft and determine its orientation and attitude without enhancements 

other than corrective lenses. 

PAGE 3 OF 3 (Revision 07/20/2013) 
APPENDIX C: PRIVACY ISSUES 

The S-1 000+ and Vision are proposed to be flown over sterile, unpopulated to lightly populated 

areas. In addition, we propose to obtain landowner permission to fly over properties as part of our 

services and to notify and obtain waivers of consent from non-landowners over which we will be 

flying. Finally, most of our flights will be 300 to 400 feet above ground surface, making visual 

recognition of people on the ground difficult. Because of the sterile environment and the prenotification of landowners and personnel on the ground, privacy compromises due to VSI 

activities are anticipated to be alleviated. Under no circumstances will VSI's aircraft be utilized 

to purposefully invade the privacy of peoples or properties in areas within our studies or outside 

of our study boundaries. 

VI 
APPENDIX D: SAFETY CASE 

Safety of our flight crew, other aircraft, people on the ground, and public and private properties is 

of utmost importance to VSI. VSI's Pilot in Command (PIC) will be responsible for all safety 

procedures and protocols while on the ground. The Visual Observer (VO) will assist the PIC in 

maintaining safety procedures throughout the course of a project. Safety procedures to be utilized 

in the filed include the following: 

• A full diagnostic check of the aircraft by the PIC and VO using a pre-flight checklist will 

be performed on the ground prior to commencement of each project; 

• High visibility (day-glow orange or green) will be worn by the flight crew during each 

project. In addition, at the ground station, a high contrast flag or banner that contains the 

words "Unmanned Aircraft Ground Station" will be placed prior to any flights; 

• Operations to be conducted over private or public controlled-access property where 

approved; 

• Permission from the land owner/authority required before commencing any flight; 

• Operations over congested areas shall be avoided; 

• Operations will not interfere with manned aircraft operations, will yield the right of way to 

manned aircraft, and operators must See & A void other aircraft and obstacles at all times. 

Use of an ADS-B receiver by the VO will assist in monitoring the presence of other 

proximal aircraft; 

• Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight 

hours 

• Aircraft operations will remain within Visual Line of Sight (VLOS) and will be visually 

monitored at all times; 

• Use of a high-definition first-person view from the aircraft will assist the PIC and VO 

identify potential flight conflicts and terminate or alter the pre-programmed flight plan; 

• VLOS guaranteed with a GPS geo-fence around operator of 0.5 miles 

• Flight ceiling pre-programed at 400 feet; 

• All operations conducted within 5 miles from an airport shall only be initiated after verbal 

coordination with the airport authority, or air traffic control when a control tower is 

present at the airport; 

• All operations will comply with required permissions and permits established by 

territorial, state, county or city jurisdictions; including local law enforcement, fire, or other 

appropriate governmental agencies; 

• In areas where the aircraft will operate over sensitive structures or habitat, the use of a 

deployable drop-safe parachute affixed to the aircraft will be utilized; 

• Post-flight inspection of the aircraft will be performed by the PIC and VO utilizing a postflight checklist; 

• The S-1 000+ and Vision operations will be compliant with existing safety procedures 

inherent to the activities of the related company. 

Vll 
APPENDIX E: MAINTENANCE PROCEDURES 

VSI's maintenance procedures for our rotor-powered aircraft are as follows: 

• PROPELLER CARE 

- Propellers must be checked each flight for nicks or cracks 

- Propellers are designed to last indefinitely if they do not impact dust, dirt or more. 

• BATTERY CARE AND USE 

Refer to instruction sheet included from the battery manufacturer. Typical 

information follows: 

- Batteries are highly flammable and can explode, especially when fully charged. 

Improper charging, vibration, impact, high discharge, etc. can lead to explosion and 

fire. Batteries must be charged under constant supervision and using proper 

precautions. 

Batteries fully charged must be handled with extreme care. 

- Any battery that puffs up is considered damaged and must not be used. It is in a 

dangerous state. Never charge a puffed up battery. 

- Any battery which holds less than 80% of its rated capacity should be discarded. 

Cycle test each battery after every 50 cycles or if a battery is suspected to 

have lost as significant amount of its capacity to determine the current 

capacity. 

- Properly dispose of batteries. First discharge the battery fully using a battery cycler. 

Bring to a recycler such as a home improvement store. 

Always charge flight batteries under "balance" mode. 

- Flight Battery Recommended Charge Rate: 1 C which takes approximately 1 hour to 

charge 

- Flight Battery Maximum Charge Rate: May exceed 5C. Charge rates higher than 1 C 

will decrease life cycles. Maximum charge rating per the manufacturer will provide 

300+ cycles. Use the lowest charge rate which is practical. 

Battery Rest Time between discharging and charging: 30 minutes 

minimum, 1 hour maximum. 

- Do not charge if the battery is more than 2°C warmer than ambient, especially if the 

temperature is above 20°C. The outer surface is cooler than the inner core after use. 

Damage will occur when charging a warm battery. 

- Recommended Battery Discharge Amount: 80%. Using more of the capacity of 

the battery will decrease the life cycles 

- As battery temperature approaches freezing the capacity of Lithium Polymer 

batteries decrease. Keep warmer than 5°C before installing into the UV 

(unmanned vehicle). 

- Battery capacity decreases at higher discharge rates. Using more batteries 

decreases the discharge rate of each battery thereby extending individual 

battery capacity slightly. 

- Lower discharge rates improve the life cycles. 

- Batteries are rated at greater than 300 life cycles. 1 ,000+ life cycles are possible. 

Batteries must not be stored above 60% charged state for extended periods. 

Batteries should be stored below 25°C for extended periods 

viii 
Store batteries between 40% - 60% charged state. Fully charge just before use. 

Fully charged batteries which are not to be used within 24 hours should be discharged 

to 40% - 60% charged state using the battery discharger. 

Using more than one battery at a time requires the proper wiring harness so that the 

voltage is no more than 25.2V. Over voltage will cause serious damage to electrical 

equipment. 

• PREVENTATIVE MAINTENANCE 

ANNUAL INSPECTION (SUGGESTED) 

• If the airframe has in excess of 300 hours in a one year period, an annual 

inspection must be completed by an approved technician. 

• An approved technician should disassemble the A V and inspect all components 

for wear and replace any components as required. 

• Test all batteries for capacity. 

• Upgrade firmware and software to latest revisions 

500 HOUR PM (SUGGESTED) 

• An approved technician should disassemble the A V and inspect all components 

for wear and replace any components as required. 

• Replace all 8 motors. 

• Test all batteries for capacity. 

• Upgrade firmware and software to latest revisions. 

IX 
APPENDIX F: USER MANUALS & HANDBOOK 

User manuals for the Dn S-1000+ and Vision are included in this appendix. The Pilot's 

Operating Handbook prepared for the S-1 000+ is also included within this appendix. 

X