May 20, 2015

Exemption No. 11626

Regulatory Docket No. FAA–2015–0537

Mr. Cameron R. Cloar

Associate

Nixon Peabody, LLP

One Embarcadero Center, 18th Floor

San Francisco, CA 94111-3600

Dear Mr. Cloar:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated February 20, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Olsson Associates (hereinafter petitioner or operator) for an exemption. The 

exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct aerial inspection, documentation, survey, mapping, photography, videography and 

data collection.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. However, the FAA 

received one comment in support of the petition made to the docket.

Airworthiness Certification

The UAS proposed by the petitioner are the Draganfly Innovations X4-ES, Draganflyer, 3D 

Robotics Aero-M, and 3D Robotics X8+.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Olsson Associates is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

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

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.
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Conditions and Limitations

In this grant of exemption, Olsson Associates is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Draganfly 

Innovations X4-ES Draganflyer, 3D Robotics Aero-M, and 3D Robotics X8+ when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
4

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

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

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Cameron R Cloar

Associate

T 415-984-8285

ccloar@nixonpeabody.com

One Embarcadero Center, 18th Floor

San Francisco, CA 94111-3600

415-984-8200

4847-4394-2433.3

February 20, 2015

U.S. Department of Transportation

Docket Management System

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 Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”

or “Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Olsson

Associates (“Olsson”) seeks an exemption from the Federal Aviation Regulations (“FARs”)

listed below and discussed in Appendix A to allow it to operate three different small Unmanned

Aircraft Systems (collectively, the “sUAS”): the Draganfly Innovations X4-ES Draganflyer, the

3D Robotics Aero-M, and the 3D Robotics X8+. Olsson is a successful engineering and design

firm that offers solutions for public and private infrastructure projects.1 Olsson plans to use the

sUAS for aerial inspection and documentation services for its projects located across the United

States. The services include aerial surveys and mapping, inspections and obtaining still

photographs, video and other data collected via onboard sensors.

The safety and public benefits of using sUAS for commercial surveying and mapping, project

documentation, and inspection services are significant. The sUAS reduce the need to operate

manned aircraft in unconventional operations, provide more accurate data in a manner that is

more safe, economical and efficient, and with a reduced impact on the environment. Because

Olsson plans to utilize the sUAS in many of its public infrastructure and related projects, the

operations will also directly translate to measurable savings for local, state and federal agencies

and ultimately, taxpayers.

1 Olsson’s design and consulting services touch upon numerous industries and subject matters, including:

water/wastewater, water resources, land development, landscape architecture, urban planning, environmental

resources and compliance, transportation, technology, municipal, geotechnical, and mechanical and electrical.
4847-4394-2433.3

February 20, 2015

Page 2

Operations pursuant to the exemption will be subject to strict operating requirements and

conditions to ensure at least an equivalent level of safety to currently authorized operations

using manned aircraft and under conditions as may be modified by the FAA as required by

Section 333. At 5.5 pounds for the Draganfly X4-ES, 7.9 pounds for the 3D Robotics Aero-M,

and 7.3 pounds for the X8+, including payload, the proposed sUAS are small in size and are

powered electrically via small, rechargeable, lithium batteries. The sUAS have extensive

automated control features, redundant systems, and integrated fail-safes, and will be operated

under controlled conditions and at low altitudes in airspace that is limited in scope.

Though the sUAS may safely be operated by one person, flight operations performed pursuant

to this exemption will consist of at least two people: a pilot-in-command (the “PIC”) and visual

observer. The PIC is responsible for the direct and safe operation of the sUAS, monitoring its

status and flight dynamics while maintaining visual line of sight and keeping the flight within

the manufacturer’s specified limits in terms of wind, flight range, battery life, etc. The observer

will be responsible for monitoring the airspace for other aircraft and hazards, advising the PIC

before and during flight of all such observed risks, and monitoring the controlled operating area.

Individuals acting as the PIC will complete manufacturer-approved training specific to the

sUAS. The PIC will be a certificated airman with private pilot privileges and limitations, and

maintain a current third-class medical certificate.

Because the sUAS will be used in lieu of comparatively higher risk operations now conducted

with fixed wing and rotary manned aircraft, the FAA can have confidence that Olsson’s

operations will achieve at least an equivalent level of safety and fulfill the Secretary of

Transportation’s responsibilities under Section 333(c) of the Reform Act to “establish

requirements for the safe operation of such aircraft systems in the national airspace system.”

Applicant Information

The name of the applicant is:

Olsson Associates

The primary contact for this application is:

Jonathan Harris

Unmanned Systems Program Director

Olsson Associates

760 Horizon Drive, Suite 102

Grand Junction, CO 81506

Ph: 970.263.6029

Fax: 970.263.7456
4847-4394-2433.3

February 20, 2015

Page 3

Exemptions Requested

Olsson respectfully requests exemptions from the following regulations:2

14 C.F.R. Part 21, Subpart H;

14 C.F.R. § 91.7;

14 C.F.R. § 91.9(b)(2);

14 C.F.R. § 91.113;

14 C.F.R. § 61.113(a), (b);

14 C.F.R. § 61.133(a);

14 C.F.R. § 91.119(c);

14 C.F.R. § 91.151;

14 C.F.R. § 91.203;

14 C.F.R. § 91.405(a) and (b);

14 C.F.R. § 91.407(a)(1);

14 C.F.R. § 91.409(a)(1)-(2); and

14 C.F.R. § 91.417(a).

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Grant of this exemption application for use of the sUAS in precision aerial surveys, mapping

and inspection operations will advance the Congressional mandate in Section 333 of the

Reform Act to accelerate the introduction of UAS into the national airspace system ("NAS")

if it can be accomplished safely. This law directs the Secretary of Transportation to consider

whether certain UAS may operate safely in the NAS before completion of the rulemaking

required under Section 332 of the Reform Act. In making this determination, the Secretary is

required to determine which types of UAS do not create a hazard to users of the NAS or the

public, or pose a threat to national security in light of the following:

 The UAS's size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the operator.

2 As set forth in Appendix C, Olsson will operate under similar operating conditions as those required in the other

grants of exemption, in which exemptions for certain FARs was deemed by the FAA as “not necessary.”

Accordingly, Olsson does not request FAA exemption from 14 C.F.R. 45.23(b), 91.103, and 91.109(a). Should the

FAA determine that relief from these or any other regulation is required for the operations proposed herein, Olsson

will be happy to submit an amendment to this request and include justifications for those necessary additional

exemptions.
4847-4394-2433.3

February 20, 2015

Page 4

Reform Act § 333(a)(1). If the Secretary determines that such vehicles "may operate safely in

the national airspace system, the Secretary shall establish requirements for the safe operation

of such aircraft in the national airspace system." Id. §333(c) (emphasis added).3

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have a current

airworthiness certificate and those regulations requiring commercial pilots to operate aircraft

in commercial service:

The Administrator may grant an exemption from a requirement

of a regulation prescribed under subsection (a) or (b) of this

section or any of sections 44702-44716 of this title if the

Administrator finds the exemption is in the public interest.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704.

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as

amended; the strong equivalent level of safety surrounding the proposed operations; and the

significant public benefit, including enhanced safety and cost savings associated with

transitioning to UAS for aerial surveys, mapping and inspections. Olsson therefore respectfully

requests that the FAA grant the requested exemption without delay.

Airworthiness of the sUAS

One element of the exemption application involves evidence of the airworthiness of the sUAS.

Olsson and the manufacturers of the sUAS – 3D Robotics and Draganfly Innovations – believe

that the sUAS have been shown to be airworthy and compliant with a significant level of safety.

Indeed, as discussed more fully in Draganfly Innovations own exemption request, Docket No.

FAA-2014-0963, numerous public agencies and organizations have received FAA permission to

operate X4 models including, without limitation, the Mesa County (CO) Sheriff’s Office,

Illinois State Police, University of North Dakota, Texas A&M University and the Northern

Plains UAS Test Site, just to name a few. In Canada, moreover, the X4 models have been

operating since 2008 under the authority of Transport Canada and Special Flight Operations

3

This provision places a duty on the Administrator to not only process applications for exemptions under

Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order

to allow approval, to supply conditions for the safe operation of the UAS. Olsson welcomes the opportunity to

consult with FAA staff to address any issues or concerns that this proposal may raise that they believe may

require modification.
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February 20, 2015

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Certificates issued by that federal agency to federal and state law enforcement agencies,

universities and for various commercial operations in Canada.

To enhance safety, it is also important to note that the sUAS are equipped with automated

features which enhance safe takeoff, flight, and landing in many conditions, further details of

which are provided in the descriptions of both aircraft (Appendices C-E), the X4-ES, Aero-M

and X8+ manufacturer manuals, and in the Olsson General Operations Manual (“GOM”).4

To maintain airworthiness, Olsson will follow a strict inspection and maintenance program.

That program is enhanced by several automatic checks performed by the sUAS. Malfunctions

that occur during flight will be detected by the sUAS fault detection systems, which

communicate a fault warning to the PIC to take necessary action. For certain malfunctions and

faults (i.e., lost communications), the sUAS may be preprogrammed to automatically respond

and land either at a designated location (e.g., a return-to-home or point of take-off) or in-place.

In addition, Olsson will maintain emergency checklists for proper and safe malfunction

responses that will be used by the PIC during operation of the sUAS. In the event of any

malfunction, the sUAS will undergo all maintenance required by the manufacturer and undergo

flight testing before recommencing commercial operations.

Proposed Operations and Associated Conditions

Olsson intends to use the sUAS that weigh significantly less than 55 pounds for the purpose of

conducting aerial surveys and mapping of land, as well as aerial inspection and documentation

of its projects. In the survey and mapping context, for example, the sUAS will be used to

acquire photogrammetric datasets for use in land development and vertical infrastructure design.

Similarly, Olsson plans to provide engineering-related inspection services with the sUAS to a

number of industries. This includes, without limitation, the inspection of transportation

infrastructure, such as rail and automotive bridges, the inspection of utility infrastructure,

including wind turbines and transmission lines, and the inspection of proposed future building

sites for overall project feasibility.

All of the sUAS operations will occur under tightly controlled conditions on public or privately

owned land at the owner’s request and consent, solely during daylight hours, and at altitudes

well below that which would pose a risk to other aircraft. The operations will take place in areas

away from people, crowds and airports. Moreover, due to the nature and purpose of the

operations, Olsson anticipates that it will fly the sUAS at relatively low altitudes and speeds.

The risk of interference with another aircraft is therefore minimal.

Grant of the exemptions to Olsson will be subject to the conditions listed in Appendix B, which

are based upon the operating conditions required by the FAA's previous grants of exemptions.

4 At the request of the FAA, Olsson will be pleased to provide, under confidentiality, its General Operations

Manual.
4847-4394-2433.3

February 20, 2015

Page 6

In terms of the specific aircraft Olsson will use for its operations, all are characterized by a high

degree of pre-programmed control and various built-in technical capabilities that limit the

potential for operation outside of the conditions set forth in Appendix B. They were also

designed with internal functional and safety features to assist the operator in safe and reliable

operation. With pre-programmed flights and manual control, operators can easily maintain

separation from manned aircraft operations and avoid other hazards. In the controlled

environment under the operations conditions in Appendix B, operations will remain within

visual line-of-sight (VLOS) and below 400 feet AGL. In addition, Olsson will obtain a

Certificate of Waiver or Authorization from the FAA Air Traffic Organization to address

airspace requirements and provide notification by a Notice to Airman (NOTAM).

Operator Requirements

Olsson will use a dedicated staff for the sUAS operations. As a condition to the grant of the

exemptions, Olsson will require that the PIC hold a private pilot's certificate and a valid thirdclass medical certificate. The PIC will have accumulated and logged a minimum number of

flight cycles and hours for daytime operations, as necessary. The PIC will also be subject to the

flight review requirements pursuant to the Federal Aviation Regulations (“FARs”).

In addition, the PIC must complete a manufacturer-approved training program for the sUAS that

he or she will operate. This training is specific to each sUAS and familiarizes the PIC to the

operations and limitations of each sUAS. Training will also include discussions on the basic

fundamentals of UAS aerodynamics and technical limitations, as well as the more general topics

of weather, the National Airspace System, and the legal and regulatory framework.

Olsson does not believe that certified airmen, medical certificates, and the related operating

conditions, are necessary or required to operate the sUAS. However, Olsson will accept these

requirements as a condition to the grant of the exemptions. If, and when, the FAA finds such

conditions unnecessary for operations conducted pursuant to Section 333 exemptions, Olsson

respectfully reserves the right to amend its operating conditions and request exemptions from

the relevant FARs to operate without such conditions.

Public Interest

The use of the sUAS in lieu of comparatively hazardous operations currently conducted with

conventional fixed wing and rotary aircraft offers a net safety benefit and will achieve an

enhanced level of safety, as mandated under Section 333(c) of the Reform Act. Approval of this

application will also benefit the public interest by allowing better, safer, and more cost efficient

information for Olsson and the public.

Conventional aerial survey and inspection operations using manned aircraft involve heavy aerial

aircraft that must transit from airports to the operational location, carrying significant amounts

of combustible fuel, and a multi-person crew. The nature of surveying and inspection operations
4847-4394-2433.3

February 20, 2015

Page 7

magnify the dangers of using conventional aircraft, as the aircraft fly in unconventional

operations under FAA waivers and at dangerous altitudes in populated and developed areas.

Aerial inspection and analysis by traditional manned aircraft is also often times impractical

because the required altitudes for safe flight can reduce the operative visibility below levels

necessary to obtain meaningful data.

By contrast, use of the sUAS is safe, economical and efficient. The X4-ES weighs a mere 5.5

lbs, the Aero-M weighs 7.9 lbs., and the X8+ weighs 7.3 lbs., including payload, they operate

on battery power, are carried (not flown) to and from the area of activity, remove the need for

an airborne crew, and pose less risk to people and infrastructure on the ground, as well as other

aircraft. sUAS operations also avoid the need for inspection personnel to risk their lives on

buildings, bridges and other structures to perform inspections. If more detailed in-person

inspections are required, planners can use preliminary sUAS data and target areas of concern

without putting inspectors and other individuals at risk in hazardous areas. More frequent, safer,

and cost-efficient inspections by sUAS will also increase safety to the public. In addition, the

sUAS can map the conditions and problem areas of Olsson projects, assisting personnel to

determine areas of potential hazard and the need for heightened safety measures. Increased

inspections will also help to maintain buildings and other structures, keeping the public safe

from building deterioration and improved building responses during significant weather events.

No national security issue is raised by the grant of the requested exemptions. Given the size,

load-carrying capacity, speed at which the sUAS operate (the X4-ES at 30 mph, the Aero-M at

56 mph, and the X8+ at less than 15 mph), and the fact that they do not carry explosives or other

dangerous materials, the use of the sUAS pose no threat to national security. In fact, the threat

of causing damage to critical national infrastructure is significantly reduced with the extremely

low sUAS weights and limited operating areas. Any other security concerns are ameliorated by

the fact that all individuals holding a private pilot certificate are subject to a security screening

by the U.S. Department of Homeland Security.

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333, the Federal Aviation Act,5the high and equivalent level of safety of the proposed

operations, and the significant public benefit, including enhanced safety and cost savings to be

realized as a result of the use of sUAS for aerial inspection and mapping services. Accordingly,

Olsson respectfully requests that the FAA grant the requested exemption without delay.

5

The Federal Aviation Act ("FAAct") expressly grants the FAA the authority to issue exemptions: The Administrator may grant

an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-

44716 of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. § 44701(f).
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Very truly yours,

NIXON PEABODY, LLP

Cameron R Cloar

CRC
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APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

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

Certificates 14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21,

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the very small

size of the aircraft and the limited operating area associated with their utilization, it is

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to

achieve or exceed current safety levels.6

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness

certificate, upon consideration of the size, weight, speed, operational capability, and

proximity to airports and populated areas of the UAS involved.

In this case, an analysis of these criteria demonstrates that the sUAS operated without an

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer,

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The X4-

ES weighs 5.5 lbs., the Aero-M weighs 7.9 lbs., and the X8+ weighs 7.3 lbs., including

payload. The sUAS do not carry a pilot or passenger, will not carry flammable fuel, and will

operate exclusively within an area pre-disclosed and in compliance with conditions set forth

herein. Operations under this exemption will be tightly controlled and monitored by the

operator, pursuant to the conditions set forth in Appendix B, the Olsson GOM, the

manufacturers’ manuals, and by local public safety requirements.

The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt

of the prior permission of the land owner (or lessee), the size of the aircraft, the lack of

flammable fuel, and the fact that the aircraft is carried to the location and not flown there all

establish the equivalent level of safety. The sUAS provide at least an equivalent level of

6 The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that

the sUAS provide an equivalent level of safety when compared to aircraft normally used for the same application.

These criteria are satisfied and therefore no exemption is needed. See, e.g., Grant of Exemption to Astraeus Aerial,

Docket No. FAA-2014-0352 at 13-14, 22. Should the FAA determine that some characteristics of the sUAS fail to

meet the requirements of the Reform Act, Olsson respectfully requests an exemption.
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safety to that of such operations being conducted with conventional manned aircraft that

would be orders-of-magnitude larger and would be carrying passengers, cargo, and

flammable fuel. The safety features including the redundant sensor systems, as described in

Appendices C-E, the manufacturers’ manuals, and throughout this document, underscore

the importance placed on safety and reliability in the design and manufacture of the sUAS.

14 C.F.R. § 91.7(a)-(b); Civil Aircraft Airworthiness

Section 91.7(a) requires that a civil aircraft must be in airworthy condition to be operated.

The FAA has concluded that no exemption is required under 14 C.F.R. § 91.7(a) to the

extent that the requirements of Part 21 are waived or otherwise found inapplicable. See FAA

Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352, Exemption No. 11062,

pp. 14-15, 19, 22. Olsson therefore respectfully requests that the FAA find the requirements

for section 91.7(a) in accordance with the agency’s determination on 14 C.F.R. Part 21,

Subpart H, discussed supra.

The agency similarly found that relief from section 91.7(b) is not warranted, which places

responsibility on the PIC to ensure an aircraft is in a condition safe for flight. See Grant of

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352, Exemption No. 11062, p. 19.

To the extent, an exemption is required under section 91.7(a) or (b), Olsson respectfully

requests that the FAA find compliance with the manufacturer’s manuals, the Olsson GOM,

and requirements of the grant of exemption, a sufficient means for ensuring the sUAS are

and remain in an airworthy condition.

14 C.F.R. § 91.113; Right-of-Way Rules

Section 91.113 requires that vigilance be maintained by each person operating an aircraft to

see and avoid other aircraft. Unlike manned aircraft, the sUAS pilot is not on-board the

aircraft to observe and avoid other aircraft, operating the sUAS from the ground.

Olsson’s proposed operating conditions will achieve an equivalent or greater level of safety.

All operations will involve two individuals—one certificated private pilot as the PIC and one

visual observer who will monitor the immediate and surrounding airspace of the sUAS

operation for potential obstruction hazards and other possible intrusions. The sUAS will also

be limited to designated areas below 400 feet AGL and within a virtual fence. Olsson will

notify the FAA and other pilots of the sUAS operations by NOTAM.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot

in Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the sUAS in this case are
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remotely controlled with no passengers or property of others on-board. Section 61.133(a)

requires an individual with a commercial pilot’s license to act as pilot in command of an

aircraft for compensation or hire.

Olsson respectfully proposes that operator requirements should take into account the

characteristics of the particular UAS. Here, the sUAS have a high degree of pre-programmed

control and various built-in technical capabilities that strictly limit the potential for operation

outside of the operating conditions set forth in Appendix B and the exemption application. The

small size, endurance, range and payload capacities of the sUAS mean that no passengers

and/or cargo will ever be carried by the aircraft. Rather, commercial operations will be strictly

limited to conducting aerial surveys and mapping, inspections and acquiring aerial imagery.

Considering these conditions, operating limitations and restrictions, an equivalent level of

safety will be provided by allowing operation of the sUAS by Olsson with individuals who

possess a valid FAA private pilot certificate and Class III medical certificate. The risks

associated with the operation of the sUAS (given their small size, speed, operational

capabilities and limitations, and lack of combustible fuel) are so diminished from the level of

risk associated with commercial operations (and even operations permitted with a private pilot

certificate) contemplated by Part 61 with manned aircraft, that allowing operations of the sUAS

as set forth in Appendix B meets and exceeds the present level of safety provided under 14

C.F.R. § 61.113(a)-(b), and does not call for a commercial pilot certificate as set forth in §

61.133.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c)

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those cases, the aircraft may

not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the sUAS will not operate at higher than 400 feet AGL. The sUAS will,

however, be operated to avoid congested or populated areas. Because aerial survey work must

be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an

exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with

which the sUAS are built. Also, no flight will takeoff or land without the permission of the land

owner or those who control the land. Because of the advance notice to the landowner, all

affected individuals will be aware of the flights.

Compared to operations conducted with aircraft or rotorcraft weighing far more than the sUAS,

and carrying flammable fuel, any risk associated with these operations will be significantly less
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than those currently allowed with conventional aircraft operating at or below 500 feet AGL.

Indeed, the low-altitude operations of the sUAS will maintain separation from operations of

conventional aircraft that must comply with Section 91.119.

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

This regulation prohibits an individual from beginning “a flight in an airplane under VFR

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

to the first point of intended landing and, assuming normal cruising speed – (1) During the day,

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The X4-ES is powered by a removable, rechargeable, lithium-polymer battery that provides

approximately 20 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the

X4-ES flights by Olsson would not be permissible. The Aero-M is also powered by a lithiumpolymer battery that provides up to 40 minutes of powered flight. Without an exemption from

91.151 for it, flights would be limited to 10 minutes in duration. Given the limitations on the

proposed operations and their locations, a longer time frame for flight in daylight VFR

conditions is reasonable. Similarly, the battery on the 3DR Robotics X8+ provides up to 15

minutes of powered flight. Without an exemption from 91.151 for it, flights would be

impossible.

An exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See

Grant of Exemption to Lockheed Martin Corporation, Docket No. FAA-2014-10673 (allowing

operations without compliance with 91.151(a). Operating the sUAS, without 30 minutes of

reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent

given the size and speed at which the sUAS operate. The fact that they carry no pilot,

passenger, or cargo also enhances their safety. As does the fact that the operations will be

conducted within the VLOS of the PIC and in a strictly controlled location. In the unlikely

event that the sUAS should run out of fuel, each aircraft is designed to land on its own (e.g.,

an auto-land function is initiated upon a critical battery warning). Given their design, weight

and construction material, the risks are less than contemplated by the current regulation.

For the X4-ES, an equivalent level of safety can be achieved by maintaining 5 minutes of

reserve fuel, which would be more than adequate to return the UAS to its planned landing zone

from anywhere in its operating area given that the systems are designed to be flown within

direct VLOS of the PIC.

For the Aero-M, an equivalent level of safety can be achieved by maintaining 10 minutes of

reserve fuel, which would be more than adequate to return the aircraft to its planned landing

zone from anywhere in its operating area, particularly since it must be flown within direct

VLOS of the PIC.
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For the X8+, an equivalent level of safety can be achieved by maintaining 5 minutes of reserve

fuel, which would be more than adequate to return the aircraft to its planned landing zone from

anywhere in its operating area, particularly since it must be flown within direct VLOS of the

PIC.

Similar exemptions have been granted to other operators and systems. See Docket Nos.

2689F, 5745, and 10673.

14 C.F.R. §§ 91.9(b)(2); 91.203(a)-(b); Carriage of Civil Aircraft Airworthiness

Certificate and Registration

Sections 91.9(b) and 91.203(a)-(b) require an aircraft operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft at all times. Because the sUAS

are small in size and contain no cabin or flight deck, carriage of such documents and

manuals is impossible.

The intent of these regulations is to ensure that the PIC has access to important documents

during flight. Here, an equivalent level of safety is achieved if the PIC has access to the

applicable sUAS manual(s), registration certificate and other required documents from the

Ground Control Station from which he or she is operating the sUAS. This is consistent with

a prior opinion of the FAA Office of the Chief Counsel, and other grants of exemptions for

commercial UAS operations. See Memorandum from Mark Bury, FAA Assistant Chief

Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight

Standards Service (Aug. 8, 2014); see also FAA Grant of Exemption to Astraeus Aerial,

Docket No. FAA-2014-0352, Exemption No. 11062, pp. 16-18.

14 C.F.R. §§ 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected

as prescribed in subpart E of this part and shall between required inspections, except as

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of

this chapter....” Section 91.407 similarly makes reference to requirements in Part 43; 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, under Part 43, or licensed pilots

and records of approval of the aircraft for return to service.

An equivalent level of safety will be achieved because the sUAS are small in size, will solely

operate in restricted predetermined areas and are not complex mechanical devices. Olsson will

perform all maintenance and inspections in accordance with the manufacturers’ manuals and

any required manufacturer Safety or Service Bulletins. In addition, the PIC will conduct a preflight inspection of the sUAS and all associated equipment to account for all discrepancies
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and/or inoperable components, pursuant to the Olsson GOM. Maintenance will be performed

and verified to address any conditions potentially affecting safe operation of the sUAS and no

flights will occur unless and until all flight critical components of the sUAS have been found

to be airworthy and in a condition for safe operation. A functional flight test will be conducted

following the replacement of any flight-critical components. As required by the Olsson GOM,

the PIC who conducts the functional test flight will make an entry for the flight in the aircraft

records.

The Olsson GOM also includes requirements to follow the manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements for all applicable

components identified by each manufacturer. In addition, the GOM includes procedures to

document and maintain a record of sUAS maintenance under this grant of exemption. Finally,

Olsson will incorporate any additional required high-time component maintenance and

replacement requirements into its GOM that is requested by Draganfly, 3D Robotics and/or

the FAA.
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APPENDIX B

OLSSON OPERATING RESTRICTIONS AND LIMITATIONS

1) Operations shall be limited to the following aircraft described in the Olsson General

Operations Manual (“GOM”): the Draganfly Innovations X4-ES Draganflyer model

aircraft, and the 3D Robotics Aero-M and X8+ (collectively “sUAS”). All three of the

aircraft weigh less than 10 pounds. Proposed operations of any other aircraft will require

a new petition or a petition to amend this grant.

2) The sUAS shall not be flown at a ground speed exceeding 100 mph or no more than the

maximum permissible operating speed required by the manufacturer, whichever is less.

3) Above Ground Level (“AGL”) altitude shall be restricted to 400 feet, as indicated by the

procedures specified in the GOM. All altitudes reported to Air Traffic Control (“ATC”)

shall be in feet AGL.

4) The sUAS shall be operated within Visual Line-of-Sight (“VLOS”) of the pilot-incommand (“PIC”) and visual observer at all times. The PIC must use human vision

unaided by any device other than corrective lenses, as specified on the PIC’s FAAissued medical certificate.

5) All operations must utilize a visual observer. The visual observer may be used to satisfy

the VLOS requirement as long as the PIC maintains VLOS capability. The observer and

PIC must be able to communicate verbally at all times. The PIC must be designated

before the flight and cannot transfer his or her designation for the duration of the flight.

The PIC must confirm that the visual observer can perform the functions prescribed in

the GOM.

6) Any and all additional requirements identified in the exemption grant by the FAA shall

be added to the GOM. The GOM must be maintained and made available to the

Administrator upon request. If a discrepancy exists between the conditions and

limitations in the granted exemptions and the GOM, the conditions and limitations in the

granted exemptions shall take precedence and must be followed. Otherwise, the operator

must follow the procedures outlined in the GOM.

The operator may update or revise its GOM. It is the operator’s responsibility to track

such revisions and present updated and revised documents to the Administrator upon the

request. The operator must also present updated and revised documents if it petitions for

an extension or amendment of the granted exemptions. If the operator determines that

any update or revision would affect the basis upon which the FAA granted the

exemptions, then the operator must petition for amendment to its exemptions. The
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FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding

updates or revisions to the GOM.

7) Prior to each flight the PIC must inspect the sUAS to confirm that it is in a condition for

safe flight. The PIC shall not operate the aircraft if the inspection reveals a condition

that affects the safe operation of the sUAS until the necessary maintenance has been

performed and the sUAS is found to be in a condition for safe flight. The Ground

Control Station (“GCS”) shall be included in the preflight inspection. All maintenance

and alternations must be properly documented in the aircraft records.

8) Any sUAS that has undergone maintenance or alterations that affect the sUAS operation

or flight characteristics (e.g., replacement of a flight critical component) must undergo a

functional test flight in accordance with the GOM. The PIC who conducts the functional

test flight must make an entry in the sUAS aircraft records of the flight. The

requirements and procedures for a functional test flight and aircraft record entry shall be

included in the GOM.

9) Olsson must follow the manufacturer’s UAS aircraft/component maintenance, overhaul,

replacement, inspection, and life limit requirements, with particular attention to flight

critical components that may not be addressed in the manufacturer’s manuals.

10) Olsson shall carry out their maintenance, inspections, and record keeping requirements,

in accordance with the GOM. Maintenance, inspection, and alterations must be noted in

the aircraft logbook, including total flight hours, description of work accomplished, and

the signature of the authorized sUAS technician returning the sUAS to service.

11) sUAS technicians must receive and document training referenced in the GOM.

12) sUAS maintenance technicians must make a record entry in the sUAS logbook or

equivalent document of the corrective action taken against discrepancies discovered

between inspections.

13) The PIC must possess at least a private pilot certificate and at least a current third-class

medical certificate. The PIC must also meet the flight review requirements specified in

14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14) Olsson will not permit any PIC to operate the sUAS unless and until that PIC has

demonstrated through the training and currency requirements set forth in the GOM, that

the PIC is able to safely operate the sUAS in a manner consistent with how the sUAS

will be operated pursuant to this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.
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15) Prior to the operation, the PIC must have accumulated and logged a minimum of 1 hour

as sUAS pilot operating the sUAS and three take-offs and three landings within the

preceding 90 days.7

16) Prior to operations, a flight demonstration as set forth in the GOM, administered by an

Olsson-approved and qualified-pilot must be successfully completed and documented.

This documentation must be available for review upon request by the Administrator. The

flight demonstration shall be conducted in accordance with the GOM.

17) The sUAS shall not be operated directly over any person, except authorized and

consenting individuals, below an altitude that is hazardous to persons or property on the

surface in the event of a sUAS failure or emergency.

18) Operating of the sUAS may be conducted at distances less than 500 feet from

participating persons, vessels, vehicles or structures that perform an essential function in

connection with these special purpose operations. Operations closer than 500 feet from

the PIC, visual observer, operator trainees, and essential persons, are permitted when

operationally necessary; but never so close as to present an undue hazard, per §

91.119(a).

19) Operations of the sUAS may be conducted at distances less than 500 feet from vessels,

vehicles or structures so long as the owner/controller grants such permission and the

operation closer to these objects presents no safety hazard to nonparticipating persons or

property.

20) Operation of the sUAS must be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures.

21) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a

pre-determined location within the security perimeter and land or be recovered in

accordance with the GOM.

22) The sUAS must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the GOM.

23) The PIC is prohibited from beginning a sUAS flight unless (considering wind and

forecast weather conditions) there is enough power to fly to the intended point of

7 Training, proficiency, experience-building, and take-off and landing currency flights can be conducted under this

grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency,

experience building, and take-off and landing currency flights all persons not essential for flight operations are

considered nonparticipants and the operator must operate the sUAS with appropriate distance from nonparticipants

in accordance with 91 C.F.R. § 91.119.
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landing and, assuming normal cruising speed, to fly after that for at least 5 minutes for

the X4-ES and the X8+, and at least 10 minutes for the Aero-M.

24) Olsson shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver of

Authorization (COA) prior to conducting any operation. This COA will also require the

filing of the NOTAM not more than 72 hours in advance, but not less than 48 hours

prior to the operation.

25) All aircraft operated in accordance with the requested exemption must be identified by

serial number, registered in accordance with 14 C.F.R. Part 47, and have identification

(N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall

be as large as practicable.

26) Each sUAS must comply with all manufacturer System and Safety Bulletins.

27) The preflight inspection required in the GOM shall account for all discrepancies (i.e.,

inoperable components, items, or equipment) not covered in the relevant pre-flight

inspection sections of the manufacturer’s operating manual.

28) The radio frequency spectrum used for operation and control of the sUAS must comply

with Federal Communication (FCC) or other appropriate government oversight agency

requirements.

29) The documents required under 14 C.F.R. §§ 91.9 and 91.203 shall be available to the

operator at the Ground Control Station of the sUAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

official upon request.8

30) The sUAS must remain clear and yield the right of way to all other manned operations

and activities at all times (including, without limitation, ultralight vehicles, parachute

activities, parasailing activities, hang gliders, etc.).

31) Operations shall occur under Visual Meteorological Conditions (VMC); flights under

special visual flight rules (SVFR) shall not be conducted.

32) sUAS shall not be operated from any moving device or vehicle.

8 This is consistent with an FAA Office of Chief Counsel Opinion, dated August 8, 2014, and prepared by Dean E.

Griffith, AGC-220, in which it was acknowledged that the intent of 14 C.F.R. § 91.9(b) and 91.203(a), (b) is met if

the PIC of the sUAS has access to the aircraft flight manual, registration certificate, and other required documents

from the ground control station from which he or she is operating the sUAS. Memorandum from Mark Bury, FAA

Assistant Chief Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards

Service (Aug. 8, 2014); see also FAA Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352,

Exemption No. 11062,pp. 16-18.
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33) sUAS shall not be operated less than 500 feet below or less than 2,000 feet horizontally

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

34) Operations shall not occur in congested or densely populated areas. The sUAS may not

operate in Class B, C, D or E airspace without written approval from the controlling

authority. Operations will not be conducted within a 5 NM range of the geographic

center of an airport as denoted on a current FAA-published aeronautical chart unless

permission has been obtained from the local control tower or, in the case of a nontowered airport, written notice has been provided to the airport’s management, and the

operation is conducted in accordance with a NOTAM as required by the grant of this

exemption.

35) Take-off and landing operations shall be conducted over private and/or controlled-access

property (i.e. no unauthorized persons). Permission from the landowner, controller,

manager or authorized representative will be obtained for each flight to be conducted.

36) Any incident, accident, or flight operation that transgresses the lateral or vertical

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

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents shall be

reported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site: www.ntsb.gov.

37) UAS operations may not be conducted during night, as defined by 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (“VMC”). Flights

under special visual flight rules (SVFR) are not authorized.
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APPENDIX C

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

Draganfly X4-ES

Draganfly systems have been approved by the FAA for operational COAs and have a

demonstrated safety track record. The Draganfly UAS platforms were the first to officially fly

at the first operational the FAA's UAS Test Sites (Northern Plains UAS Test Site, North

Dakota). Many customers from emergency services, to education to police and even

commercial operations for industrial inspections have been given approval to fly in US,

Canada, UK, Australia, Japan, amongst others. As to the X4-ES, the FAA has granted COAs

to the Mesa County Sheriff’s Office and the Grand Forks Sheriff’s Office.

Systems Overview

The Draganflyer X4-ES system can carry payloads up to 1.8 lbs. The X4-ES operates with a

maximum wind threshold of 30 mph for sustained winds and wind gusts up to 35 mph. The

system contains 11 sensors on-board, including 3 gyros, 3 magnetometers, 3 accelerometers, a

barometric pressure sensor and GPS module. This sensor package provides for default of level

flight and does not allow the X4-ES to go beyond a 38 degree angle. This eliminates the

difficult portion of flying. Meaning that, the operator is only steering the aircraft (controlling

the system’s latitudinal direction) and adjusting its altitude.

All flight operations are capable of control through GPS, making the system easy to navigate. In

the case of lost GPS, a manual user flight mode is enabled which allows the pilot-in-command

(“PIC”) to provide manual navigation inputs to assist in landing the vehicle. At all times

through the ground control station, the PIC is able to monitor the sUAS location through the

mapping function and is provided with continuous altitude information. In GPS mode, the

aircraft compensates for wind at the altitude the system is operating. The end result is a system

capable of gathering high quality aerial data at much higher wind thresholds and is a trait that is

imperative for many aerial inspection operations. While GPS Position Hold mode is one

available benefit of the system, it is not necessary for operation of the aircraft. When GPS is

either not available or has degraded, the PIC may still ensure safe operations.

The X4-ES has an operational range of over 1/2 a mile,9but was designed to be flown within

the direct Visual Line-of-Sight (“VLOS”) of the operator at all times. All flight operations take

place as a result of direct input by the PIC. Flight adjustments are made based on a two

joystick control system, which allows for very precise movements and makes it extremely

9

Control transmission signal is rated for in excess of 1/2 mile; however, battery flight endurance limits require the

operator to restrict maximum distance to ensure safe return of the sUAS.
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easy to navigate in either Manual or GPS Position Hold. In the Manual mode, flight altitude is

maintained based on barometric pressure and can be easily adjusted by the PIC using the left

joystick. In the GPS Position Hold mode, the system is designed to hold its GPS position (and

altitude and heading) if the PIC is not explicitly commanding the system to move. Camera

stability is further enhanced by a 2 axis brushless mount to ensure the most stability and least

amount of vibration regardless of the wind speed.

The Draganfly X4-ES provides two semi-autonomous flight modes using a two joystick

configuration and video interface. The user controls the aircraft in either a Manual/Altitude

(Manual) Hold mode or GPS Position Hold mode to the areas of interest maintaining VLOS of

the aircraft at all times. Instrumentation indicating heading, bearing, altitude, climb rate,

horizontal speed, GPS position, battery level, data link, and GPS accuracy are additional aids

made available to the PIC on the ground control station (“GCS”).

Autonomous operations are also available through pre-programmed flight plans, which must be

uploaded to the aircraft prior to take-off. After departing the ground, the PIC can execute the

preprogramed flight. At any time during the programmed flight, the PIC can provide inputs to

abort and/or override the programmed flight to take immediate control of the aircraft. For preprogrammed flight, the PIC may utilize additional navigation settings, including landing zones

and flight area (including visual no-fly zones, maximum altitude, and minimum altitude), so that

the sUAS operates only within operator-specified flight parameters. In other words, Olsson will

set up virtual fencing around the operational area, preventing the X4-ES and the PIC from

operating outside the planned flight area, including altitude. This reduces the needed operating

area by omitting the need to factor in additional room for PIC operating error.

The ability to fly in both Manual mode and GPS Position Hold, as well as in a GPS deprived

environment, makes the X4-ES one of the safest choices for both urban and nonurban

environments. Many advanced safety features were also designed into the aircraft, including

intelligent fault handling that allows the aircraft to detect a system fault while airborne, and to

automatically fly back to its take-off location and land. For example, the X4-ES detects a loss

of GPS and warns the PIC of the status. Other faults that can be detected include loss of

communication, low battery levels, magnetic anomalies, battery cell imbalances, and

temperature fluctuations. Prior to takeoff, the aircraft completes a sensor self-check. If an error

is detected in the pitch, roll or yaw gyros between the time motors are engaged and takeoff, the

aircraft will abort the takeoff and issue an alarm message. It should also be noted that the PIC

can create maximum flight altitudes so the sUAS cannot go above a pre-set maximum altitude.
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Physical Characteristics of the X4-ES

Dimensions

- Width: 87cm (34.25in)

- Length: 87cm (34.25in)

- Height: 30cm (12in)

Weight and payload

- Helicopter weight w/battery: 1,670g (3.7lbs)

- Payload capacity: 800g (1.8Ibs)

- Max take-off weight: 2,470g (5.4lbs)

Flight characteristics

- Max climb rate: 2m/s (6.5ft/s)

- Max descent rate: 2m/s (6.5ft/s)

- Max turn rate: 90 degrees/sec

- Approx max air speed: 50km/h (30mph)

- Minimum air speed: 0km/h (0mph)

- Launch type: VTOL

- Max altitude ASL 2,438m (8,000ft)

- Approx sound at 1 meter distance: 72db

- Approx sound at 3 meters distance: 62db

Landing style/type - Autonomous vertical lift

Propulsion System

 Engines - The X4-ES is powered by 4 electric direct drive brushless DC

motors.

 Batteries - The X4-ES utilizes a removable, rechargeable, lithium-polymer

battery. The charge level status from the battery on the aircraft is continually

monitored and real time levels are displayed on the control system used by the

PIC. Predefined voltage levels indicate a low battery warning, which provides

the PIC with a warning alarm that is both visual and audible. A critical battery

warning alarm that is both visual and audible is also provided to the PIC. At the

critical battery warning alarm, the aircraft also initiates a safe descent and land

at a pre-determined controlled rate. At any time during the battery warnings,

full control of the aircraft is maintained. However, ignoring the critical battery

warning and overriding the descent feature could result in a critical flight

system failure at which point the aircraft may crash. The battery is charged

using a standard wall charger that is provided with the aircraft.
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Maintenance - The X4-ES is nearly maintenance free. The airframe has only 2 ceramic

bearings per motor and, thus, has very few moving parts. Maintenance consists of inspections

and verification of communications performed by a qualified person prior to each flight.

Preflight checklist includes but is not limited to:

 Visual inspection of the airframe, including the boom and canopy, side arms,

landing gear, rotors, motors, and canopy;

 Visual inspections of rotor integrity;

 All payload system connections and components;

 Check charge of all batteries (aerial vehicle, control system, video repeater

station).

Reliability – The X4-ES is designed for maximum reliability and to maintain performance

over its life. The only components that experience routine wear are rotors, batteries, motors,

and legs. Battery and motor conditions are monitored by the system with deviations reported

to the operator.

Contact with other objects during flight may cause other components, particularly rotors, and

motor arms, to become damaged. Damaged components are likely to be detected during the

full visual inspection of the airframe performed before each flight.

TheX4-ES detects numerous conditions which may make flying unsafe, such as reduced GPS

accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature

fluctuations. Automatic pre-flight calibration checks prevent the aircraft from taking off if such

conditions are present. An automatic preflight check also tests the calibrations of the pitch, rolls

and yaw gyros, and aborts the takeoff and delivers an alarm message, should an error be

detected. During flight, a degradation or loss of communications between the X4-ES and the

ground station may initiate a failsafe action of return-to-home, where the aircraft returns to its

point of take-off at its current altitude. At that point, the PIC may land the aircraft, or an autoland is initiated in which the aircraft descends at a controlled rate from its current position. For

the failsafe action of Return-To-Home, the X4-ES must be in GPS Position Hold mode.

Otherwise, the aircraft is set for a default to auto-land. In the event that the system senses a low

battery of the X4-ES during a Return-to-Home action, the aircraft defaults to the auto-land

maneuver.

Command and Control Systems - The Draganflyer GCS, which is used by the X4-ES (and

several other Draganflyer models), allows the PIC simultaneous control over the aircraft and

any payloads. The joysticks, located on the GCS, allow for quick navigation and the display

screen provides all essential flight data to the PIC. Telemetry data is transmitted to the GCS at

least once per second. The GCS display screen provides all essential data to the operator.
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Displayed on GCS:

 Barometric Altitude

 Bearing

 Heading10

 Attitude

 Ground Speed

 Climb Rate

 Flight Time

 Data Link

 Position

 GPS Satellite (number of satellites)

 GPS Satellite Precision Dilution of Precision (PDOP)11

 GPS satellite errors

 Control system battery level

 X4-ES battery level

 Local time

 UAS failsafe action

 UAS Status

Onboard Flight Instruments - The X4-ES is equipped with an Inertial Navigation System (3-

axis gyroscope, 3-axis magnetometer, 3 axis accelerometers, GPS receiver, barometric

pressure sensor and GPS module).

On-board computer systems - The X4-ES is equipped with on-board computer systems to

monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate

(control, telemetry, etc.) with the PIC.

On-board Guidance and Navigation Equipment - The X4-Es can operate autonomously. As

described, supra, autonomous flight first requires the PIC to initiate and complete the takeoff

sequence, and then place the aircraft into GPS mode. The PIC also retains the ability to

immediately take control of the X4-ES with Manual flight mode.

Frequency Allocations – 900 MHz, 2.4 GHz, and 5.8 GHz.

Flight termination link – A flight termination link is available to the PIC on the GCS to

prevent a "fly away" or other potentially dangerous situation.

10 The X4-ES may be pointed in one direction yet fly towards a completely different direction. In other words, the

heading and bearing can be different. Thus, both parameters are displayed on the X4-ES GCS home screen.

11 This is the accuracy to the real time GPS reading.
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Takeoff and Landing – The X4ES has vertical lift autonomous launch. For takeoff, the UAS

will takeoff and hover approximately 3-4 feet until further inputs are made by the PIC.

Horizontal position of the aircraft is controlled by the PIC using the right joystick.

Navigation System – In most cases, navigation of the aircraft is through the visual line-ofsight of the PIC. However, the X4-ES may also be operated through pre-programmed flight

plans, which are uploaded to the aircraft prior to take-off. Once the auto-takeoff is complete,

the PIC can execute the programmed flight which is performed through an autopilot function.

At any time during the preprogrammed flight, the PIC can override the autopilot, abort the

mission, and take immediate control of the aircraft. In preprogrammed flight, there are several

navigation settings and/or tools, including landing zones and flight areas (including visual nofly zones, maximum altitude, and minimum altitude). This has the effect of creating a virtual

fencing around the operational area.

Redundant Systems – The X4-ES combines the input from a multitude of sensors. Even

though the data from all sensors is required for optimal system performance, dependent on the

sensor, a single sensor malfunction is likely to result in degraded performance rather than a

fatal response.

Emergency Procedures and System Failures

Sensor Failure – A failure of onboard flight instruments and/or sensors will degrade

the X4-ES performance and will result in either a fatal critical response or a non-fatal

critical response.12 The type of response will depend on the nature and severity of the

failure. If the aircraft becomes unstable due to sensor failure, this may result in loss of

performance or features. In most instances, the aircraft remains in stable flight so that

the PIC may initiate a landing, the aircraft itself initiates an auto-land. For instance, a

magnetometer failure may lead to a non-fatal critical response. In extreme cases, like

an accelerometer failure, a fatal response may result that causes the aircraft a fatal

response such as a crash.

Motor Failure – This will cause a fatal response in flight performance if one or more

motors fails.

Airframe Failure – Depending on the nature and severity, an airframe failure may

result in decreased flight performance or a fatal response such as a crash, depending on

the nature of the airframe failure.

12 A fatal response generally references a complete and catastrophic systems failure leading to the loss of control of

the aircraft, causing it to enter an uncontrolled descent and ultimately impacting the ground or other object.
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Navigation System Failure – In a navigation system failure, degraded GPS will result

in a response warning to the pilot in which the system would be flown in manual mode.

This will result in degraded GPS position performance, but manual flight by the PIC is

not affected.

Power Failure – A complete battery failure which results in power loss to the aircraft

will result in a fatal response and the aircraft may shutdown and crash, if airborne.

Low Battery Condition – The PIC/operator is alerted of a low battery condition through

both a visual and aural warning. In a critical battery condition, the PIC/operator is

again alerted through an aural and visual warning, and the X4-ES will begin an autoland at a controlled and safe rate of descent.

Line-of-Sight Loss – All flight operations will be conducted with the X4-ES within

visual sight of the pilot. If the PIC's view becomes obstructed and line-of-sight is lost,

the PIC may instruct the aircraft to hover in place until line-of-sight is re-established,

return to the takeoff position, or land at the current position.

Security – The X4-ES and communications links are encrypted by the manufacturer’s

proprietary software.
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APPENDIX D

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

3D Robotics Aero-M

Systems Overview

The 3D Robotics Aero-M system can carry payloads up to 1.1 lbs. It operates with a maximum

wind threshold of 25 mph. The system contains two full Inertial Measurement Unit (“IMU”)

sensor suites, one acting as the primary flight sensor and the other used as a comparison for

monitoring IMU health and full failover functionality, if it becomes necessary. The system

also contains two barometer sensors. This eliminates the difficult portion of flying. The pilotin-command (“PIC”) has the ability to control the speed, roll, yaw and pitch of the aircraft.

The Aero-M has an operational range of approximately 250 acres,13 but was designed to be

flown within the direct Visual Line-of-Sight (“VLOS”) of the operator at all times. All flight

operations take place as a result of direct input by the PIC. Flight adjustments are made based

on a two control stick system that is located on the Ground Control Station (“GCS”).

Instrumentation indicating heading, altitude, climb rate, horizontal speed, GPS position, battery

level, data link, and GPS accuracy are additional aids made available to the PIC through the

flight data screen located on the GCS. The aircraft was designed to operate in six different flight

modes. In the basic “Manual” operations mode, the PIC controls all axes of the Aero-M without

any assistance from the system’s autopilot function. The remaining control methods are semiautonomous in functionality.

An autonomous operations, or “Auto,” mode is available through available pre-programmed

flight plans, which must be uploaded to the aircraft prior to take-off using the 3D Robotics

Mission Planner software application. The PIC may set the Aero-M to either an automatic

takeoff or manual takeoff setting. After departing the ground, the aircraft initiates the

preprogramed flight. At any time during the programmed flight, the PIC can provide inputs to

abort and/or override the programmed flight to take immediate control of the Aero-M. For preprogrammed flight, the PIC may utilize additional navigation settings, including landing zones

and flight area (including visual no-fly zones, maximum altitude, and minimum altitude), so that

the Aero-M operates only within operator-specified flight parameters. In other words, Olsson

will set up virtual fencing around the operational area, preventing the Aero-M and the PIC from

operating outside the planned flight area, including altitude. This reduces the needed operating

area by omitting the need to factor in additional room for PIC operating error.

13 Control transmission signal is rated for in excess of 1

/2 mile; however, battery flight endurance limits require the

operator to restrict maximum distance to ensure safe return of the sUAS.
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In a “Fly by Wire” mode, the autopilot manages the control surfaces and navigates the Aero-M

based on direction by the PIC. In a “Return to Launch” mode, the Aero-M returns to the

position where it acquired GPS lock and enters a circle pattern at an altitude of 100 meters

which is programmable by the operator. Similarly, in the “Loiter” mode, the Aero-M enters a

circle pattern with a radius of 60 meters at its current altitude, which is again programmable by

the PIC. Finally, “Stabilize” mode allows for manual control by the PIC. When the PIC releases

the right control stick, however, the Aero-M will automatically return to level flight.

The Aero-M utilizes GPS for many modes of operation, making the system easy to navigate. In

the case of lost or degraded GPS signal, the PIC may enable either the Manual or Fly by Wire

operations modes to navigate the aircraft to a safe landing point. At all times through the GCS,

the PIC is able to monitor the location of the Aero-M through the flight data screen.

Many advanced safety features were also designed into the aircraft, including intelligent fault

handling that allows the aircraft to detect a system fault while airborne, and to automatically

initiate the Return-to-Launch operations mode. For example, the Aero-M detects a loss of GPS

and warns the PIC of the status. Other faults that can be detected include loss of

communication, and low battery levels. The PIC can also create maximum flight altitudes so

the Aero-M cannot go above a pre-set maximum altitude.

Physical Characteristics of the Aero-M

Dimensions

- Width: 188 cm (74 in) (wingspan)

- Length: 129 cm (51 in)

Weight and payload

- Aircraft weight w/battery: 6.8 lbs

- Payload capacity: 1.1 lbs

- Max take-off weight: 7.9 lbs

Flight characteristics

- Maximum Turbulence Rating: light

- Radio Range: .6 miles14

- Flight Time: 40 minutes

- Max Operational Wind Speed: 25 mph (11 m/s)

- Approx max airspeed: 56 mph (90 kmh)

- Approx min airspeed: 22 mph (35 kmh)

- Max altitude ASL: approximately 8,000 feet15

- Landing Accuracy: 6.5 feet latitude x 131 feet longitude (2 m x 40 m)

14 This figure reflects estimated values at ideal operating conditions. Environmental conditions may affect flight

time, range, area coverage, and ground sampling distance.

15 Olsson will not operate the aircraft above 400 ft. AGL.
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Landing style/type – Approach and controlled descent / manual or automatic landing

available

Propulsion System

 Engines - The Aero-M is powered by 1 Tiger AT2820-7, 830 kV motor that is

connected to a Gemfan 11x7 propeller.

 Batteries - The Aero-M utilizes a removable, rechargeable, lithium-polymer

battery. The charge level status from the battery on the aircraft is continually

monitored and real time levels are displayed on the control system used by the

PIC. Predefined voltage levels indicate a low battery warning, which provides

the PIC with a warning alarm that is both visual and audible. In such an

instance, the aircraft will automatically return to circle above the point of

launch/take-off and circle overhead. If the battery reaches 25% of charge, the

aircraft will result in an additional low battery alarm that is both visual and

audible. At any time during the battery warnings, full control of the aircraft is

maintained. Ignoring the critical battery warning could result in a critical flight

system failure. The battery is charged using a standard wall charger that is

provided with the aircraft.

Maintenance - The Aero-M is nearly maintenance free. The airframe has only 2 ceramic

bearings in its motor and, thus, has very few moving parts. Maintenance consists of

inspections and verification of communications performed by a qualified person prior to each

flight.

Preflight checklist includes but is not limited to:

 Visual inspection of the airframe, including the airframe, tail and tail boom, the

servo rods, airspeed sensor, and proper balance of the aircraft;

 All payload system connections and components;

 Check charge of all batteries (aerial vehicle and control system).

Reliability – The Aero-M is designed for maximum reliability and to maintain performance

over its life. The only components that experience routine wear are the propeller, batteries,

motor, and servos. Battery conditions are monitored by the system with deviations reported to

the operator.

Contact with other objects during flight may cause other components, particularly the

propeller, wings and servos to become damaged. Damaged components are likely to be

detected during the full visual inspection of the airframe performed before each flight.
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The Aero-M detects numerous conditions which may make flying unsafe, such as reduced GPS

accuracy, low battery charge, and lost-link with the GCS. Automatic pre-flight calibration

checks prevent the aircraft from taking off if such conditions are present. During flight, a

degradation or loss of communications between the Aero-M and the GCS may initiate a failsafe

action of Return-to-Launch. This is displayed visually on the GCS. At that point, the PIC may

land the aircraft, or an auto-land is initiated in which the aircraft descends at a controlled rate

from its current position.

Command and Control Systems - The GCS allows the PIC simultaneous control over the

aircraft and any payloads. The right and left control sticks are located on the GCS and permit

quick navigation. The flight data display screen provides all essential flight data to the PIC.

The transmission of telemetry data to the GCS is selectable to the PIC at a rate up to 20 hz.

Displayed on GCS:

 Barometric Altitude

 Heading

 Bank Angle

 Attitude

 Ground Speed

 Climb Rate

 Flight Time

 Ground Station Signal

 Position (Latitude and Longitude)

 Mode of Operation

 GPS Satellite (number of satellites)

 GPS Satellite HDOP

 GPS Status

 GCS Battery Status

 Aero-M Battery Status

 Local time

 UAS Failsafe Action (e.g., low battery, etc.)

Onboard Flight Instruments - The Aero-M is equipped with an Inertial Navigation System

(3- axis gyroscope, 3-axis magnetometer, 3 axis accelerometers, GPS receiver, barometric

pressure sensor and GPS module).

On-board computer systems - The Aero-M is equipped with on-board computer systems to

monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate

(control, telemetry, etc.) with the PIC.
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On-board Guidance and Navigation Equipment - The Aero-M can operate autonomously

for take-off, inflight operations, and landing. In automatic takeoff, the PIC must set the aircraft

to autonomous mode and it then senses direction of movement and launches the aircraft in that

direction. For autonomous inflight operations 3D Robotics utilizes the Mission Planner

software application. Mission Planner is a computer-based application for the PIC or operator

to build a flight plan that is loaded to the Aero-M prior to takeoff. In automatic landing, the

PIC must input a pattern of waypoints into a mission prior to takeoff. The waypoints are set at

different locations and altitudes so that the aircraft gradually descends in a controlled and

gradual manner to land safely. The PIC retains the ability to immediately take control of the

Aero-M with a manual flight mode.

The Aero-M has six different operations modes:

 Auto: This is used for autonomous missions preprogrammed using the 3D Robotics

Mission Planner software application.

 Fly by Wire: An assisted manual control where the autopilot system manages the

flight control surfaces and navigates the aircraft based on inputs from the PIC.

 Return-to-Launch: This mode directs the aircraft tto circle over the takeoff or launch

point. The aircraft will enter a circle pattern at an altitude of 100 meters.

 Loiter: By selecting this mode, the PIC directs the aircraft to enter a circle pattern with

a radius of 60 meters at the current altitude. The PIC may adjust the position of the

circle pattern with the right control stick.

 Stabilize: This mode consists of manual control by the PIC with an additional

safeguard that returns the aircraft to a level flight orientation with release of the right

control stick.

 Manual: This is full manual control without assistance of the autopilot.

Frequency Allocations - 900 MHz, 2.4 GHz, and 5.8 GHz.

Takeoff and Landing – Manual and automatic takeoff and landing functions exist on the

Aero-M. In automatic takeoff, the PIC must set the aircraft to autonomous mode and it then

senses direction of movement. The PIC stands into the wind holding the aircraft above his or

her head. The PIC then runs and throws the Aero-M at an upwards angle. The aircraft senses

the throw, powers the motor, and climbs to the altitude specified by the “takeoff” waypoint

preprogrammed in the Mission Planner application uploaded to the aircraft prior to flight. In

manual mode, the Aero-M is launched into the air from the same running position used in

automatic takeoff, however, the PIC must immediately adjust the GCS to control the aircraft

once it is airborne.

In automatic landing, the PIC must input a pattern of waypoints into a mission, using the

Mission Planner software application, prior to takeoff. The waypoints are set at different

locations and altitudes so that the aircraft gradually descends in a controlled and gradual
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manner to land safely. In manual landing mode, the PIC directs the Aero-M to a circle pattern

(similar to a traffic pattern used in manned aircraft flight), followed by a final approach pattern

flown into the wind at decreasing altitude.

Navigation System – The Aero-M is capable of navigation solely by the visual line-of-sight

of the PIC and in manual mode operation. However, the aircraft may also be operated through

pre-programmed flight plans, which are uploaded to the aircraft prior to take-off. An auto

takeoff may be performed, after which the aircraft then begins its preprogrammed flight plan.

Alternatively, the PIC may conduct a manual takeoff and then initiate the preprogrammed

flight plan. At any time during the preprogrammed flight, the PIC can override the autopilot,

abort the mission, and take immediate control of the aircraft. The aircraft supports complex

and simple geo-fencing features that allow the PIC to create vertical and horizontal virtual

walls to prevent the aircraft from operating outside that preprogrammed area.

Redundant Systems — The Aero-M combines the input from a multitude of sensors. Even

though the data from all sensors is required for optimal system performance, dependent on the

sensor, a single sensor malfunction is likely to result in degraded performance rather than a

fatal response.

Emergency Procedures and System Failures

Motor Failure - This will cause a fatal response in flight performance if the motor

fails. However, the flight control surfaces will remain responsive and the aircraft can

glide to the ground under manual control.

Airframe Failure – Depending on the nature and severity, an airframe failure may

result in decreased flight performance or a fatal response16.

Navigation System Failure – In a navigation system failure, or loss of communications

channels required for autonomous operations, a failsafe visual and aural warning will

display on the GCS and the Aero-M will initiate Return to Launch mode. Manual

control may also be initiated on the GCS.

Power Failure – A complete battery failure which results in power loss to the aircraft

will result in a fatal response.

Low Battery Condition – The PIC is alerted of a low battery condition through both a

visual and aural warning, and the Aero-M initiates Return to Launch mode where it

16 In a fatal response, the autopilot will maintain the aircraft operating above stall speed and it will descend along

its flight path. Assuming the aircraft is within the VLOS of the PIC, the PIC would then take manual control and

land the aircraft.
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enters a circle pattern. In a critical battery condition, the PIC is again alerted through

an aural and visual warning.

GCS Fail or Shutdown – A failure or shutdown of the GCS automatically initiates

Return-to-Launch mode. In “Auto” mode, the aircraft will continue on its mission.

Line-of-Sight Loss – All flight operations will be conducted with the Aero-M within

visual line-of-sight of the PIC. If the PIC's view becomes obstructed and line-of-sight

is lost, the PIC may immediately place the aircraft into the Return to Launch or Loiter

modes of operations.

Security – The Aero-M and communications links are encrypted by the manufacturer’s

proprietary software.
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APPENDIX E

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

3D Robotics X8+

Systems Overview

The 3D Robotics X8+ system can carry payloads up to 1.7 lbs. The system contains two full

Inertial Measurement Unit (IMU) sensor suites, one acting as the primary flight sensor and the

other used to compare data inflight and failover functionality, if it becomes necessary. The

system also contains a barometer sensor. This eliminates the difficult portion of flying. The

pilot-in-command (“PIC”) has the ability to control the speed, roll, yaw and pitch of the

aircraft.

The X8+ was designed to be flown within the direct Visual Line-of-Sight (“VLOS”) of the

operator at all times. All flight operations take place as a result of direct input by the PIC. Flight

adjustments are made based on a two control stick system that is located on the Ground Control

Station (“GCS”). Instrumentation indicating heading, altitude, horizontal speed, GPS position,

battery level, data link, and GPS accuracy are additional aids made available to the PIC through

the flight data screen located on the GCS. The aircraft was designed to operate in three different

flight modes. In the basic “Manual” operations mode, the PIC controls all axes of the X8+

without any assistance from the system’s autopilot function.

An autonomous operations, or “Auto,” mode is available through available pre-programmed

flight plans, which must be uploaded to the aircraft prior to take-off using the 3D Robotics

Mission Planner software application. The PIC may set the X8+ to either an automatic takeoff

or manual takeoff setting. At any time during the programmed flight, the PIC can provide inputs

to abort and/or override the programmed flight to take immediate control of the aircraft. For

pre-programmed flight, the PIC may utilize additional navigation settings, including landing

spots and flight area (including visual no-fly zones, maximum altitude, and minimum altitude),

so that the aircraft operates only within operator-specified flight parameters. In other words,

Olsson will set up virtual fencing around the operational area, preventing the X8+ and the PIC

from operating outside the planned flight area, including altitude. This reduces the needed

operating area by omitting the need to factor in additional room for PIC operating error. In

addition to the pre-programmable parameters, the X8+ is also set to default limits of 300 meters

in distance and 100 meters in altitude.

In a “Return-to-Launch” mode, the X8+ returns to the position where it acquired GPS lock and

completes an automatic landing. Similarly, in the “Loiter” mode, the X8+ enters a hover at its

current altitude, which is again directed by the PIC on the GCS. In “Land” operations mode, the

X8+ initiates an automatic landing at its current location.
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The X8+ utilizes GPS for many modes of operation, making the system easy to navigate. In the

case of lost or degraded GPS signal, the aircraft automatically switches to Manual operations

mode so that the PIC may navigate the aircraft to a safe landing point. At all times through the

GCS, the PIC is able to monitor the location of the X8+ through the flight data screen.

Many advanced safety features were also designed into the aircraft, including intelligent fault

handling that allows the aircraft to detect a system fault while airborne, and to automatically

initiate the Return-to-Launch operations mode. For example, the X8+ detects a loss of GPS,

warns the PIC of the status and automatically enters Manual operations mode. Other faults that

can be detected include loss of communication, and low battery levels. The PIC also comes

with default geo-fence settings that limit the aircraft’s operating altitude and operating

distance.

Physical Characteristics of the X8+

Dimensions

- Width: 35 cm

- Length: 51 cm

- Height: 20 cm

Weight and payload

- Aircraft weight w/battery: 5.6 lbs

- Payload capacity: 1.7 lbs

- Max take-off weight: 7.3 lbs

Flight characteristics

- Maximum Turbulence Rating: light

- Radio Range: .6 miles17

- Flight Time: 15 minutes

- Airspeed: 14.5 mph default (6.5 m/s)

- Max altitude ASL: approximately 8,000 feet (MSL)18

Landing style/type – vertical lift / manual or automatic landing available

Propulsion System

 Engines - The X8+ is powered by SunnySky V2216-12 KV800 II motors that

are connected to 8 APC propellers.

 Batteries - The X8+ utilizes a removable, rechargeable, lithium-polymer

battery. The charge level status from the battery on the aircraft is continually

monitored and real time levels are displayed on the control system used by the

17 This figure reflects estimated values at ideal operating conditions. Environmental conditions may affect flight

time, range, area coverage, and ground sampling distance.

18 Olsson will not operate the aircraft above 400 AGL.
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PIC. Predefined voltage levels indicate a low battery warning, which provides

the PIC with a warning alarm that is both visual and audible. In such an

instance, the aircraft will automatically initiate a landing at its current location.

At any time during the battery warnings, full control of the aircraft is

maintained. The battery is charged using a standard wall charger that is

provided with the aircraft.

Maintenance - The X8+ is nearly maintenance free. Maintenance consists of inspections and

verification of communications performed by a qualified person prior to each flight.19

Preflight checklist includes but is not limited to:

 Visual inspection of the aircraft, including the airframe, the front and rear arms,

the propellers, and GPS mast;

 All payload system connections and components;

 Check charge of all batteries (aircraft and control system).

Reliability – The X8+ is designed for maximum reliability and to maintain performance over

its life. The only components that experience routine wear are the propeller, batteries, motor,

and servos. Battery conditions are monitored by the system with deviations reported to the

PIC.

Contact with other objects during flight may cause other components, particularly the

propeller, wings and servos to become damaged. Damaged components are likely to be

detected during the full visual inspection of the airframe performed before each flight.

The X8+ detects numerous conditions which may make flying unsafe, such as reduced GPS

accuracy, low battery charge, and lost-link with the GCS. Automatic pre-flight calibration

checks prevent the aircraft from taking off if such conditions are present. During flight, a

degradation or loss of communications between the X8+ and the GCS will initiate a failsafe

action of Return-to-Launch and complete an automatic landing. This is displayed visually on the

GCS.

Command and Control Systems - The GCS allows the PIC simultaneous control over the

aircraft and any payloads. The right and left control sticks are located on the GCS and permit

quick navigation. The flight data display screen provides all essential flight data to the PIC.

The transmission of telemetry data to the GCS is selectable to the PIC at a rate up to 20 hz.

Displayed on GCS:

 Barometric Altitude

 Ground Speed

19 Olsson specific maintenance procedures can be found in the Olsson GOM.
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 Flight Time

 Ground Station Signal

 Position (Latitude and Longitude)

 Mode of Operation

 GPS Satellite (number of satellites)

 GPS Status

 GCS Battery Status

 X8+ Battery Status

 Meters from Launch Point

 UAS Failsafe Action (e.g., low battery, etc.)

Onboard Flight Instruments - The X8+ is equipped with an Inertial Navigation System (3-

axis gyroscope, 3-axis magnetometer, 3 axis accelerometers, GPS receiver, barometric

pressure sensor and GPS module).

Onboard Computer Systems - The X8+ is equipped with on-board computer systems to

monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate

(control, telemetry, etc.) with the PIC.

On-board Guidance and Navigation Equipment - The X8+ can operate autonomously for

take-off, inflight operations, and landing. In automatic takeoff, the PIC must first arm the X8+

and its propellers in standard mode. The PIC then switches the X8+ to automatic mode and

raises the throttle. For autonomous inflight operations 3D Robotics utilizes the Mission

Planner software application. Mission Planner is a computer-based application for the PIC or

operator to build a flight plan that is loaded to the X8+ prior to takeoff. In automatic landing,

the PIC must input a landing waypoint into a mission prior to takeoff. The aircraft will land

automatically at the landing waypoint, but the PIC must lower the throttle fully down so that

the propellers disarm after the aircraft completes the landing. The PIC retains the ability to

immediately take control of the X8+ with manual flight mode.

The X8+ has three different operations modes:

 Auto: This is used for autonomous missions preprogrammed using the 3D Robotics

Mission Planner software application.

 Loiter: By selecting this mode, the PIC directs the aircraft to enter a hover.

 Standard: This is full manual control without assistance of the autopilot.

The X8+ has two additional landing modes:

 Land: By selecting this switch, the PIC directs the X8+ to end its flight and land at the

current position. The throttle joystick must be lowered fully down so that the X8+

automatically disarms the propellers upon touchdown. During the land sequence, the

PIC may reposition the X8+ using the right joystick.
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 Return-to-Launch: With this switch selected, the X8+ returns to the launch point and

initiates an automatic landing. The throttle joystick must be lowered fully down so that

the X8+ automatically disarms its propellers upon touchdown. During the automatic

landing, the PIC may reposition the X8+ using the right joystick. Note that the Returnto-Launch landing point is the location where the X8+ was armed prior to takeoff.

Frequency Allocations – 900 MHz, 2.4 GHz, and 5.8 GHz.

Takeoff and Landing – Manual and automatic takeoff and landing functions exist on the

X8+. Automatic takeoff requires the use of the Mission Planner software application. To

initiate the automatic takeoff, the PIC must arm the aircraft and its propellers and then switch

the aircraft into automatic mode and raise the throttle. For manual takeoff, the X8+ must be

armed at which point the motors will spin. The X8+ will also initiate an automatic landing

when operating in an autonomous mode using the Mission Planner application. In the Returnto-Launch mode, the X8+ will return to its point of launch and automatically land. Similarly,

in the Land mode, the X8+ will land at its current location.

Navigation System – The X8+ requires GPS lock prior to operation. The X8+ is capable of

navigation solely by the visual line-of-sight of the PIC and in manual mode operation.

However, the aircraft may also be operated through pre-programmed flight plans, which are

uploaded to the aircraft prior to take-off. An auto takeoff may be performed, after which the

aircraft then begins its preprogrammed flight plan. Alternatively, the PIC may conduct a

manual takeoff and then initiate the preprogrammed flight plan. At any time during the

preprogrammed flight, the PIC can override the autopilot, abort the mission, and take

immediate control of the aircraft. The X8+ is set to default geo-fence settings that prevent the

aircraft from exceeding an altitude of 100m (328 ft), and a distance of 300m (984 ft) from the

GCS. If those limitations are exceeded, the aircraft automatically initiates the Return-toLaunch mode and lands.

Redundant Systems – The X8+ combines the input from a multitude of sensors. Even though

the data from all sensors is required for optimal system performance, dependent on the sensor,

a single sensor malfunction is likely to result in degraded performance rather than a fatal

response.

Emergency Procedures and System Failures

Airframe Failure – Depending on the nature and severity, an airframe failure may

result in decreased flight performance or a fatal response20.

20 In a fatal response, the autopilot will maintain the aircraft operating above stall speed and it will descend along

its flight path. Assuming the aircraft is within the VLOS of the PIC, the PIC would then take manual control and

lands the aircraft.
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Navigation System Failure – The X8+ requires GPS for operations. GPS must lock

prior to takeoff. If the X8+ loses GPS lock in flight, an aural and visual warning is

provided to the PIC. The aircraft automatically switches into manual control (altitude

hold mode) on the GCS. The PIC may also change this failsafe from manual control to

an automatic landing.

Power Failure – A complete battery failure which results in power loss to the aircraft

will result in a fatal response.

Low Battery Condition – The PIC is alerted of a low battery condition through both a

visual and aural warning, and the X8+ initiates an immediate landing mode at its

current location.

GCS Fail or Shutdown – A failure or shutdown of the GCS automatically initiates

Return to Launch mode. In “Auto” mode, the aircraft will continue on its mission.

GCS Signal Loss – If the X8+ loses contact with the GCS, the aircraft returns to the

launch point and lands automatically. The PIC is alerted to this situation with a

blinking yellow status LED on the GCS.

Line-of-Sight Loss – All flight operations will be conducted with the X8+ within visual

line-of-sight of the PIC. The X8+ is set to a default of a geo-fence of 300m (984 ft). If

the X8+ travels beyond the 300m geo-fence, it automatically returns to its launch point

and lands. The default setting may be disabled by the PIC.

Altitude Failsafe – The X8+ has a 100m (328 ft) altitude geo-fence enabled by default.

If the geo-fence is exceeded, the X8+ automatically switches to Return-to-Launch.

Security – The X8+ and communications links are encrypted by the manufacturer’s

proprietary software.
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APPENDIX F

FEDERAL REGISTRY SUMMARY

Pursuant to 14 C.F.R. Part 11, Olsson offers the following summary for publication in the

Federal Register, should publication be necessary:

Olsson Associates seeks an exemption from the following rules:

14 C.F.R. Part 21, Subpart H; 14 C.F.R. § 91.7; 14 C.F.R. § 91.9(b)(2); 14

C.F.R. § 91.113; 14 C.F.R. § 61.113(a)-(b); 14 C.F.R. § 61.133(a); 14 C.F.R. §

91.119(c); 14 C.F.R. § 91.151; 14 C.F.R. § 91.203; 14 C.F.R. § 91.405(a)-(b); 14

C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(1)-(2); and, 14 C.F.R. § 91.417(a).

Approval of these exemptions will permit Olsson to conduct commercial unmanned

aircraft systems (“UAS”) operations in a number of industries and applications. The

exemptions will enhance safety by reducing risk to the general public and property

owners from the risk and hazards associated with performing equivalent work through

conventional manned aircraft.