### February 3, 2015 U.S. Department ofTransportation Docket Operations M-30 West Building GroundFloor, Roomw12-140 1200 NewJersey Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal AviationRegulations DearMadam, 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 oftheDJI S-1000+ Unmanned Aircraft System ("S-1000+") and a DJI Phantom 2 Vision+ ("Vision"), seeks an exemption from the Federal AviationRegulations ("FARs") listedbelow: 

## • 14 C.F.R. 21 

## • 14 C.F.R. 45.23 

## • 14 C.F.R45.29 

# • 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 oflicensedprofessional 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-1000+ 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 ofsafetyto currently authorized operations using manned aircrafts. The S-1000+ and Visionwillbe operatedby an individual who fulfill the following requirements:

• Has successfullypassed amanufacturer'straining program for the S-1000+ andVision; • Has aPrivate Pilot license;1. 

### CHARACTERISTICS OF THE AIRCRAFT 

### The S-1000+ is a small (41 inches between rotors) and ultra-light (maximum take-offweight 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 S1000+ takes a collection ofhigh-definition still images that are used later to generate maps and contour lines ofthe surveyed area. The Vision takes high-definition video that is used later to generate maps, photographs, and contourlines ofthe surveyed area The four main characteristics ofthe S-1000+ andVision are:

a. Very lightweight The S-1000+ and Vision are so light that the operator can launchthem 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 ofhazardous situations. Finally, the rotor arms ofthe S-1000+ are detachable and made ofrounded composite materials with no sharp edges. The rotor arms ofthe Vision are rounded and made ofplastic with no sharp edges. b. Electric-powered The S-1000+ 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-1000+ and Vision autopilot system continuously analyzes data from the Inertial Measurement Unit and from the onboard GPS and takes care ofall the aspects ofthe flight underthe supervision ofthe operator. d. Optionfor Manual control Additionally, the S-1000+ 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 ofrock and unstable slopes, thus reducing the danger to and increasing the safety for those professionals. Additionally, the use of the S-1000+ 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 ofthe helicopter, and personnel on the ground. The use of UAV will also reduce the need for conventional aircraft in gatheringphotogrammetric data, thus improvingpublic safety. 3. APPLICABLELEGAL STANDARD UNDERSECTION333



### a. Operatingrequirements 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 mainrestrictions are summarizedbelow:

• Operations to be conducted over private or public controlled-access property where approved; • Permissionfrom the land owner/authorityrequired before commencing any flight; • Operations over congested areas shall be avoided; • Operations mustnot interfere withmanned aircraft operations, must yield the right ofway to manned aircraft, and operators must See & 

### Avoid other aircraft and obstacles at all times. Use ofanADS-B receiverbythe VO will assist inmonitoring the presence ofother proximal aircraft; • Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours; • Aircraft operations must remain within Visual Line ofSight (VLOS) and will be visually monitored at all times; • VLOS guaranteedwith a GPS geo-fence around operator of0.5 miles; • Flight ceilingpre-programed at 400 feet; • All operations conductedwithin 5miles from an airport shall onlybe initiated after verbal coordination with the airport authority, or air traffic control when a control tower is present atthe airport; • All operations shall comply with required permissions and permits established by territorial, state, county or cityjurisdictions; including local law enforcement, fire, or other appropriate governmental agencies; • The S-1000+ and Vision operations will be compliant with existing safety procedures inherentto the activities oftherelated company. b. OperatorRequirements The S-1000+ andVisionPilotinCharge (PIC) will have aPrivatePilotlicense. The PIC and Visual Observer (VO) will meetthe requirements outlined in FAA PolicyN 8900.227 Section 16 Personnel Qualifications. Additionally, the PIC and VO will perform maintenance onthe system andwill complete a course ofmaintenance instruction as part oftheir initialtraining. Dueto the 3

### simplicityofthe system, we do not anticipate the need for a supplemental pilot inthe field. 3. CONCLUSION We submitthatthe combinationofthe aircrafts' lightweight, historically demonstrated flight performance, fully qualified flight crew and strict operationunderthe guidelines established in 8900.227, the FAA canhave confidence thatthe operationwillhave an equivalent or greater level ofsafety ofmanned aircraftperformingthe same mission. The name and contact information ofthe 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. 

### ExemptionRequest and Equivalent Level ofSafety B. Academy ofModel Aeronautics Safety Requirements C. Privacy Issues D. Safety Case E. Maintenance Procedures F. UserManual G. Training Program H. AviationExperience

4

### APPENDIXA: EXEMPTIONREQUESTAND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDERAPPLICABLE RULES SUBJECT TO EXEMPTION 

### VSI requests an exemption from the following regulations as well as any additional regulations thatmaytechnically applyto the operation ofthe S-1000+ andVision: 14 C.F.R. Part21, SubpartH: Airworthiness Certificates 

### Thispartestablishes the procedures for the issuance ofan airworthiness certificate. While the FAA continues to workto develop airworthiness standards for UAS, we request an experimental certificate be issued for the S-1000+ and Visionunder either orbothofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a)

### Research anddevelopment. Testingnewaircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, ornewuses for aircraft. (b) 

### Showingcompliance with regulations. Conducting flight tests and other operations to show compliance withthe airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiatemajor design changes, and flights to show compliance withthe function andreliability requirements ofthe regulations. Sincethe experimental certificate canbe used for commercialpurposes such as market surveys, sales demonstrations, and customer crewtraining, we would expectthat an experimental certificate wouldpermit our commercialpurpose as well. The aircraft will not carrypersons orproperty, will not carry fuel, and will only fly under strict operational requirements. Combinedwiththe fact thatthe aircraft are lightweight, wepropose thatthe S-1000+ and Visionwill be at least as safe, ifnot safer, than a conventionally certificated aircraftperformingthe same mission. Ifan experimental airworthiness certificate is not appropriate for this application, then we request an exemption of14 CFRPart 21, Subpart H, andthe requirementfor an airworthiness certificate in general, citingthe equivalent level ofsafety outlined inthe previous paragraph.

14 CFR91.203(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-1000+ 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 ofsafety and meetthe intent of91.203, wepropose that documents deemed appropriate for these aircraftby the FAAwill be co-locatedwiththe crewat

### the ground control station and available for inspectionuponrequest. In orderto identify the aircraft, we propose thatthe information found on airworthiness andregistration certificates be permanently affixed to the aircraft viaplacard:

Manufacturer: DJI Model: "S-1000+" or "Phantom2 Vision+" SerialNumber: 15-XXXX Registeredto: Vertical Solutions, Inc. 123 Shasta Street Anytown, CA 12345 Iffound please contact: (800)-222-1234. 14 C.F.R. § 45.23 & 

### 14 C.F.R. § 45.29: Display ofmarks; size 

### ofmarks 

### 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.

Giventhe size ofthe S-1000+ and Vision (rotorto rotor distance of41 and 13.8 inches, respectively), this requirementis impossible to match. We feel thatthe permanentplacard discussed inthe previous paragraphwill provide the aircraft's registrationinformation should it be found on the ground. We will also display at the ground station ahigh contrast flag orbanner that contains the words "UnmannedAircraft Ground Station" in letters 3 inches high or greater. Sincethe aircraftwill operate within 1/2 NM ofthe ground station, thebanner shouldbe visible to anyone that observes the aircraft and chooses to investigate its point oforigin. 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-1000+ 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-1000+ Pilot Operating Handbook (flightmanual) priorto 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 ofthis 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 documentationwouldnotbe 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, orpreparing for, flight. 14 C.F.R. § 91.109(a) & 91.319(a)(1): FlightInstruction 

### 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-1000+ 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-1000+ 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 equivalentlevel ofsafety. 14 CFR § 91.119: Minimum SafeAltitudes 

### 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 of400 feet AGL, the S-1000+ cannot comply withthis requirement. The equivalent level ofsafety will be achievedbecause the S-1000+ and Visionwill only fly over property with the permission ofthe landowner(s) or public agencies. The operator will define before every flight a working area radius and a flight area ceiling, preventing the S-1000+ to go beyondthe flight area. The landowner and the persons who may be onthe ground in the flight area will be briefed ofthe expectedroute offlight and the associatedrisks to persons and property onthe ground. Due to the small size ofthe S-1000+ and the material with whichthe S-1000+ 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 hazardto persons orproperty onthe surface. 14 CFR91.121- Altimeter Settings 

### This section requires that each person operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, when operatingbelow 18,000 feet MSL to:

• The current reported altimeter setting ofa station along the route and within 1 00 nautical miles ofthe aircraft; • Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the currentreported altimeter setting ofan appropriate available station; • Inthe case ofan aircraftnot equippedwith aradio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.
iii

### To provide an equivalent level ofsafety, the S-1000+ autopilot calculates the reference altitude (ground level) with the on-board GPS during the pre-flighttests. 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 ofthe S-1000+ 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 Flightin 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 ofintended landing and to fly after thatfor at least 30 minutes. Given the area ofoperation for the S-1000+ and Vision, VSI believes that an equivalent level of safety is already achieved with the specific procedure preventing the S-1000+ or Vision from accepting a take-offorder ifthe battery level is below a given value. Moreover, VSI will monitor the battery levels ofthe S-1000+ 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 integratedbattery level warnings into controllers operated for these aircraft. 14 C.F.R. § 91.203 (a) & 

### (b): Carrying CivilAircraft Certification and Registration 

### This regulationprovides 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) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legibleto 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 onthe UAS. In addition, there is no pilot orpassengers onboardthe aircraft. To obtain an equivalent level of safety and meet the intent of 91.203, VSI proposes that documents deemed appropriate for this aircraftbythe FAA will be co-located withthe operator at the ground control station in the S-1000+ and Vision box and available for inspection upon request 14 CFRSubpartE (91.401 - 91.417) -Maintenance, PreventiveMaintenance, and Alterations 

### Theregulationprovides thatthe operatoris primarilyresponsible for maintainingthe aircraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by aperson authorized under Part43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certainmaintenance workthat has been accomplished by certificated mechanics, iv

### underPart43, or licensedpilots and records ofapproval ofthe aircraft forreturnto service. VSI proposes that the maintenance of the S-1000+ 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 inthe public docket. An equivalent level ofsafety will be achieved because the S-1000+ 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 maintainthe aircraftinan airworthy condition andto ensure an equivalentlevel ofsafety.

vAPPENDIX B: ACADEMY OFMODELAERONAUTICS SAFETYREQUIREMENTS

v

### AcademyofModelAeronautics NationalModelAircraftSafety Code Effective January 1, 2014 A. GENERAL: Amodel aircraft is anon-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations ofthis code and is intended exclusivelyfor sport, recreation, education and/orcompetition. All model flights must be conducted in accordance with this safety code and any additional rules specific to the flying site. 1. Model aircraftwill not be flown: (a) In acareless or reckless manner. {b) At alocation where model aircraft activities are prohibited. 2. Model aircraft pilots will: (a) Yield the rightofwayto all human-carrying aircraft. (b) See and avoid all aircraft and aspotter must be used when appropriate. (AMA Document#540-D.) (c) Notfly higherthan approximately400 feet above ground level within three (3) miles of an airportwithout notifying the airport operator. (d) Not interfere with operations and traffic patterns at any airport, heliport orseaplane base exceptwhere there is amixed use agreement. (e) Not exceed atakeoffweight, including fuel, of55 pounds unless in compliance with the AMA Large Model Airplane program. (AMA Document520-A.) (D Ensure the aircraft is identified with the name and address orAMA numberofthe owneron the inside or affixed to the outside ofthe model aircraft. {This does not applyto model aircraftflown indoors.) (g) Notoperate aircraftwith metal-blade propellers orwith gaseous boosts exceptfor helicopters operated underthe provisions ofAMA Document#555. (h) Notoperate model aircraftwhile underthe influence of alcohol orwhile using any drug that could adversely affectthe pilot's abilityto safely control the model. (i) Notoperate model aircraft carrying pyrotechnicdevices that explode or burn, orany device which propels aprojectile ordrops any objectthat creates a hazard to persons or property. Exceptions: • Free Flightfuses ordevices that burn producing smoke and are securely attached to the model aircraft during flight. • Rocket motors (using solid propellant) up to aG-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) Notoperate aturbine-powered aircraft, unless in compliance with the AMAturbine regulations. (AMA Document#510-A.) 3. Model aircraftwill not be flown in AMA sanctioned events, airshows or model demonstrations unless: (a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated priorto the specific event. {b) An inexperienced pilot is assisted by an experienced pilot. 4. When and where required by rule, helmets must be properlyworn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved orcomply with comparable standards. B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles orstructures and shall avoid endangermentof life and property of others. 2. Asuccessful radio equipment ground-range check in accordance with manufacturer's recommendations will be completed before the firstflight of anew or repaired model aircraft. 3. At all flying sites asafety line(s) must be established in front ofwhich all flying takes place. (AMA Document#706.) (a) Only personnel associated with flying the model aircraft are allowed at or in front ofthe safety line. {b) At airshows ordemonstrations, astraight safety line must be established. (c) An area awayfrom 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 bythe Federal Communications Commission (FCC). Only individuals properly licensed bythe FCC are authorized to operate equipment on Amateur Band frequencies. 5. RC model aircraftwill not knowingly operate within three (3) miles of any pre-existing flying site without afrequency-management agreement. (AMA Documents #922 and #923.) 6. With the exception of events flown underofficial AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors closerthan 25 feetto any individual, exceptforthe pilot and the pilot's helper(s) located atthe flightline. 7. Under no circumstances may apilot orother person touch an outdoor model aircraft in flightwhile it is still underpower, exceptto divert itfrom striking an individual. 8. RC nightflying requires alighting system providing the pilotwith aclearview ofthe model's attitude and orientation at all times. Hand-held illumination systems are inadequate for nightflying operations. 9. The pilot of an RC model aircraft shall: (a) Maintain control during the entire flight, maintaining visual contactwithout enhancement otherthan by corrective lenses prescribed forthe pilot. (b) Fly using the assistance ofacamera or First-Person View (FPV) only in accordance with the procedures outlined in AMA Document#550. (c) Fly using the assistance of autopilot orstabilization 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 otherfliers. 3. An effective device will be used to extinguish anyfuse on the model aircraft afterthe fuse has completed its function. D. CONTROL LINE

1. The complete control system (including the safetythong where applicable) must have an inspection and pull test priorto flying. 2. The pull testwill be in accordance with the current Competition Regulations forthe applicable model aircraft category. 3. Model aircraft notfitting aspecific category shall use those pull-test requirements as indicated for Control Line Precision Aerobatics. 4. The flying area must be clear of all utilitywires or poles and amodel aircraftwill not be flown closerthan 50 feetto 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

11

# SEE 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 mustfly sufficientlyfar away from manned aircraft so as notto 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 forthe safety of manned aircraft by remaining vigilant and well clear.
7. Whenever a potential conflict arises between model aircraft and manned aircraft, the pilot ofthe model aircraft must always give wayto the manned aircraft. 8. The pilot ofa model aircraft must never assume the pilot ofa manned aircraft can see the= model orwill perform any maneuverto avoid the model's flight path. 9. Visual Line ofSight is required by the Safety Code. It means thatvisual contact with the aircraft must be maintained without enhancement otherthan 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 ofsight. 10. "Blue Sky" is aterm used to explain the method used to increase separation between a model and a manned aircraft in the same vicinity. The modeler should maneuverthe aircraft in such away 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 ofthe equation and the modeler need notworry whetherthe model is closer to him than the manned aircraft orfurther 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 forthe well-being ofthe 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 aflight, the pilot must insure that the spotter understands his/her duties and expectations. 2. A spotter should be used to assist in monitoringthe surrounding airspace for manned aircraft whenever aflight is expected to exceed 400 feet above the ground and that operation is expected to be in proximity to known manned aircrafttraffic such as at a mixed-use facility or within three miles ofan airport. The spotter must have sufficientvisual 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 eventthat another model aircraft or spectators become endangered or in turn are perceived to be a danger to the pilot orthe pilot's model aircraft. 4. Ifa model aircraft pilot experiences what he or she considers a near miss with a manned aircraft, that model aircraft pilot should notifyAMA Headquarters with awritten report ofthe incident, including action taken by the model aircraft pilotto 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 ofthe incident at a latertime. 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 autopilotcontrol 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 autopilotsystems 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 ofthe model aircraft. 

### c) AMA Pilots must perform an RIC Test Flightof a model aircraft before activating a newly installed autopilotor stabilization system and/or after any repairs or replacement of model aircraft essential flightsystems. 

### d) Model aircraft exceeding 151bs and/or ?Omph may only use an autopilotfor 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 ofthe 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 ofthe 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 autopilotfor 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) Ifyour radio system lacks failsafe capability, consider using programmable digital servos or auxiliary failsafe modules. In the event ofa radio signal failure these components will activate desired safe servo settings or an autopilotfor return to base/launch (RTL). b) When using an autopilotsystem 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 ofthe 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 autopilotsystems for model aircraft flying to enhance flight performance, correct bad tendencies ofthe 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 generallyjust to make an airplane easier and safer to fly. e) When purchasing stabilization and autopilotsystems, 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 technologyfor aerial surveillance with radio control model aircraft having the capability of obtaining high-resolution photographs and/orvideo, or using any types of sensors, for the collection, retention, or dissemination ofsurveillance 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 Pilotis an AMA memberwho 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. AutopilotSystems 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 memoryfor 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 onboard camera's cockpit view to orient and control the aircraft. (AMA Document #550). FlightEnvelope 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 autopilotor stabilization systems that can be activated and deactivated in flight by the pilot without affecting manually controlled stable flight). RIC TestFlight requires an AMA Pilot to manually operate an R/C transmitter to control a model aircraft's flight path and determine ifthe 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 ofattitudes. Systems are often based on rate/heading hold gyros or inertial motion sensors utilizing multi-axis gyros and accelerometers for attitude stabilization. Visual Line ofSight(VLOS) is the distance atwhich the pilot is able to maintain visual contact with the aircraft and determine its orientation and attitude without enhancements otherthan corrective lenses.

PAGE 3 OF 3 (Revision 07/20/2013)APPENDIX C: PRIVACYISSUES The S-1000+ and Vision are proposed to be flown over sterile, unpopulated to lightly populated areas. In addition, we propose to obtain landownerpermissionto fly overproperties as partofour services and to notify and obtain waivers ofconsent from non-landowners over which we will be flying. Finally, most ofour flights will be 300 to 400 feet above ground surface, making visual recognition ofpeople on the ground difficult. Because ofthe 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 ofpeoples or properties in areas within our studies or outside ofour studyboundaries.

VIAPPENDIX D: SAFETY CASE Safety ofour flight crew, other aircraft, people on the ground, and public and private properties is ofutmost 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 throughoutthe course ofa project. Safetyprocedures to be utilized in the filed includethe following:

• A full diagnostic check ofthe aircraft by the PIC and VO using a pre-flight checklist will be performed on the groundpriorto commencement ofeachproject; • High visibility (day-glow orange or green) will be worn by the flight crew during each project. In addition, atthe ground station, a high contrast flag or banner that contains the words "UnmannedAircraft Ground Station" will beplacedpriorto any flights; • Operations to be conducted over private or public controlled-access property where approved; • Permission from the land owner/authorityrequired before commencing any flight; • Operations over congested areas shall be avoided; • Operations will not interfere with manned aircraft operations, will yieldthe right ofway 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 will remain within Visual Line ofSight (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 identifypotential flight conflicts andterminate or alterthe pre-programmedflight plan; • VLOS guaranteedwith a GPS geo-fence around operator of0.5 miles • Flight ceilingpre-programed at400 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 atthe airport; • All operations will comply with required permissions and permits established by territorial, state, county or cityjurisdictions; 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 affixedto the aircraftwill be utilized; • Post-flight inspection ofthe aircraft will be performed by the PIC and VO utilizing a postflight checklist; • The S-1000+ and Vision operations will be compliant with existing safety procedures inherentto the activities ofthe related company.

VllAPPENDIX E: MAINTENANCE PROCEDURES VSI's maintenance procedures for ourrotor-powered aircraft are as follows:

• PROPELLER CARE

- Propellers mustbe checked each flight for nicks or cracks

- Propellers are designed to last indefinitely ifthey do notimpact 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 leadto explosion and fire. Batteries mustbe chargedunder constant supervision and using proper precautions. Batteries fully charged mustbe 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 apuffedup battery.

- Any battery which holds less than 80% ofits rated capacity should be discarded. Cycle test each battery after every 50 cycles or ifa battery is suspected to have lost as significant amount of its capacity to determine the current capacity.

- Properly dispose ofbatteries. First discharge the battery fully using a battery cycler. Bringto a recycler such as a home improvement store. Always charge flight batteries under "balance"mode.

- FlightBattery Recommended Charge Rate: 1 Cwhichtakes approximately 1hourto charge

- FlightBattery Maximum Charge Rate: May exceed 5C. Charge rates higherthan 1 C will decrease life cycles. Maximum charge ratingperthe manufacturer will provide 300+ cycles. Use the lowest charge rate which is practical. Battery Rest Time between discharging and charging: 30 minutes minimum, 1hour maximum.

- Do not charge ifthe battery is more than 2°C warmerthan ambient, especially ifthe temperature is above 20°C. The outer surface is coolerthan the inner core after use. Damage will occurwhen charging a warm battery.

- Recommended Battery Discharge Amount: 80%. Using more ofthe capacity of the battery will decrease the life cycles

- As battery temperature approaches freezing the capacity ofLithium Polymer batteries decrease. Keep warmer than 5°C before installing into the UV (unmannedvehicle).

- 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 greaterthan 300 life cycles. 1,000+ life cycles are possible. Batteries must not be stored above 60% charged state for extendedperiods. Batteries shouldbe storedbelow 25°C for extendedperiods viiiStore batteries between40%

- 60% charged state. Fully chargejustbefore use. Fully chargedbatteries which are notto be used within 24 hours shouldbe discharged to 40%

- 60% charged state usingthe 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.

• PREVENTATIVEMAINTENANCE ANNUAL INSPECTION (SUGGESTED) • Ifthe airframe has in excess of300 hours in a one yearperiod, an annual inspection mustbe completed by an approved technician. • An approvedtechnician should disassemble the AV and inspect all components for wear and replace any components as required. • Test all batteries for capacity. • Upgrade firmware and software to latestrevisions 500 HOURPM (SUGGESTED) • An approvedtechnician should disassemble the AV and inspect all components for wear and replace any components as required. • Replace all 8motors. • Test all batteries for capacity. • Upgrade firmware and softwareto latestrevisions.

IXAPPENDIXF: USERMANUALS & HANDBOOK Usermanuals for the 

### Dn S-1000+ and Vision are included in this appendix. The Pilot's Operating Handbookpreparedfor the S-1000+ is also includedwithinthis appendix.

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