# DRONE AMERICA January 12, 2015 Docket Management Facility US Department ofTransportation 1200 NewJersey Avenue, SE West Building Ground Floor Room W12-140 Washington DC 20590-0001 RE: Section 333 Petition for Exemption Dear FAA: Drone America, Inc. petitionsfor reliefofspecific regulations with regards to airworthiness certification underSection 333, 14 CFR 11.81. The proposed requestfor exemption would allowforthe use and operation of Unmanned Aircraft Systems {UAS) within the National Airspace {NAS) for emergency response. The application is to aid and assist emergency personnel from hazardous conditions, bodily harm and provide communication relay. In the event of National, or local emergencies it may be deemed necessaryfor unmanned aircraft operations. Drone America requestthatthe FAA approve an exemption based on aspecific platform of size, weight, speed and limited operating range. Whereas, under normal circumstances might not otherwise conform to guidelines set forth in 8900.1, Volume 16, Chapter5, Section 4 {16-5-4-3) and {16-5- 4-5) for Emergency and National Disaster Operations. Our request for exemption is based on public safety and integrationto supportfirefighting, disaster relief, search and rescue, law enforcement, crewtraining and to participate in research ofvarious National Aeronautics and Space Administration {NASA) and National Oceanic and AtmosphericAdministration {NOAA) environmental studies. In the interestofpublic safety and research, to datethe FAA has already authorized emergency service agencies limited use of unmanned aircraftforcritical operations. Operational control would remain within Drone America's Emergency Services Division in which "due regard" for rules, regulations and operational procedures will be adhered to. The purpose ofissuance for an Emergency COA exemption is:
• An emergency situation that is defined as acondition ofdistress or urgency; or • The proposed Unmanned Aircraft is operating undera current approved COAfor adifferent purpose or location. OR; For non-emergency COA's is to request exemptionsthatfall outside ofthese parameters be considered for:
• Crewtraining • Flights totestsensor capabilities • Flights overcongested areas • Flights in Class Cairspace DroneAmerica, Inc. 2015 Section 333 Exemption for UAS Operations 1The platform in consideration for Section 333 Exemption is the DAx8. This platform is an eight-blade rotorcraft designed to assess and evaluate critical situations priorto releasing emergency response teams into hazardous conditions. Othercapabilities ofthe DAx8 are ISR/IR applicationsfor search and rescue operationsthat provide lightweight mobility and the abilityfor rapid deployment in life threatening situations.

Sincerely,



## v~·-~ __,a-c"vu....--· v

**~** Scott Lether - Operations Manager Drone America, Inc. 3555 Airway Drive Suite 310 Reno, NV 89511 775-473-9998 1775-624-3416 www.DroneAmerica.com

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### DAxB

2Drone America, Inc. Federal Aviation Regulations for Exemption 

# SECTION 333 PETITION FOR EXEMPTION DroneAmerica request relieffrom thefollowing regulations in partorwhole thereof: 

### PART 21THAT DESCRIBES PROCEDURAL REQUIREMENTS FORTHE COMPLIANCE OF: • Subpart G; Production Certificates • Subpart H; Airworthiness Certificates • Subpart I; Provisional Airworthiness Certificates • Subpart K; Parts ManufacturerApproval • Subpart L; Export Airworthiness Approvals • Subpart N; Acceptance ofAircraft Engines, Propellers and articles for Import • Subpart 

### 0; Technical Standard Order Approvals 

### PART 45THAT REQUIRES IDENTIFICATION AND REGISTRATION MARKINGS: Due to platform size and airframe configuration, 2" regulation markings will notfit in accordance with Part 45.11 and therefore, request for modification to comply with only Part 45.13 fire proof identification plate located on the inside ofthe platform. The DAx8 is an unmanned aircraft and cannot meetthe requirements for display of markings ofthis size, nor does the DAx8 have a door or cabin to display the word "Experimental". 

### PART 61.113 PRIVATE PILOT PRIVILEGES AND LIMITATIONS: a) Except as provided in paragraphs (b) through (h), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passenger or propertyfor compensation or hire; nor may that person, for compensation or hire, act as pilot in command. b) A private pilot may, for compensation or hire, act as pilot in command of aircraft in connection with any business or employment if: 1) The flight is only incidental tothat business or employment; and 2) The aircraftdoes notcarry passengers or property for compensation or hire. Drone America's request for relief of requiring a private pilots license and limitations is thatthe aircraft size, weight, speed and limiting operational range are contributing factors forthat do not necessarily require a private pilots license to operate. The UA weighs less than 20 lbs. and does not exceed a maximum speed of28 mph. The aircraft will be operated within a horizontal visual line of sight (VLOS) from the surface notto exceed 400 feetAGL. Operations are conducted from a handheld tablet through touch commands and waypoints with auto takeoffand landing capabilities. Operators are required to complete an FAA approve flight training ground school and hold a 2nd Class medical.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### 1Drone America, Inc. Federal Aviation Regulations for Exemption 

### PART 91.7 CIVILAIRCRAFT AIRWORTHINESS: a) No person may operate a civil aircraft unless it is in airworthy condition. b) The pilot in command ofa civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur. Drone America's aircraftvehicle operators (AVO's) are responsible forthe inspection and safe operation ofthe aircraft. Aircraft will be inspected prior to each flight and maintenance performed as necessary to ensure flight safety. Should the condition ofsafe flight not be met, resolved or repaired the flight will be terminated until discrepancies are corrected. See Section 11- DAx8 Preflight and Checklist. 

### PART 91.9 CIVIL AIRCRAFT FLIGHT MANUAL, MARKING AND PLACARD REQUIREMENTS: a) No person may operate a civil aircraftwithout complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings and placards, or as otherwise prescribed by the certificating authority ofthe county of registry. Request for relief is thatthe DAx8 is not capable ofcomplying with Part 91.9, however, a flight manual with operating limitations and placards will be immediately accessible tothe AVO during flight as prescribed. 

### PART 91.107 USE OF SAFETY BELTS, SHOULDER HARNESSES AND CHILD RESTRAINTS: Part 91.107 Subpart B, is not applicable to Unmanned Aircraft. 

### PART 91.119 MINIMUM SAFE ALTITUDES: Relief for exemption of minimum safe altitude is that emergencies can happen anywhere. This will require operations to be performed on the scene ofthe incident up to, but not exceeding 400 feet AGL. Mitigating factors will be considered prior to flight operations, and operational perimeter setbacks placed to ensure emergency personnel safety. Procedural protocols will be enforced to ensure proper operational parameters are adhered to. 

### PART 91.203 CIVIL AIRCRAFT: CERTIFICATIONS REQUIRED: Drone America request relieffor exemption of Part 91.203 in whole thatthe DAx8 is Experimental and does not require airworthiness certification based on size, weight, speed and limiting operating range. The DAX8 does not carry fuel or passengers. 

### PART 91.207 EMERGENCY LOCATORTRANSMITTERS:

Drone America, Inc. 2015 

### a) Except as provided in paragraphs (e) and 

### (f) ofthis section, no person may operate a U.S. registered civil airplane unless -
Section 333 Exemption for UAS Operations 2Drone America, Inc. Federal Aviation Regulations for Exemption 

### 1) There is attached tothe airplane an approved automatic type emergency locator transmitter that is in operable condition for the following operations, except thatafterJune 21, 1995, an emergency locatortransmitterthat meets the requirements of TSO-C91 may not be used for new installations. The DAx8 is equipped with an audible lost aircraft alarm that notifies the operator of lost Comm in flight. Inthe event flight is non-recoverable the ballistic parachute is deployed and the operator may retrieve the aircraft if lost by listening forthe alarm. 

### PART 91.405 MAINTENANCE REQUIRED: Each owner or operator ofan aircraft: a) Shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter. Drone America requests for relief ofexemption of Part 91.405 (a) in parton the basis ofthe size, weight, speed and limited range ofthis unmanned aircraft. Drone America's aircraftvehicle operators (AVO's) will be responsible forthe inspection and safe operation ofthe aircraft. The aircraftwill be inspected prior to each flight and maintenance performed as necessary to ensure flight safety. 

### Ifthe condition cannot be resolved or repaired the flight will be terminated until discrepancies are corrected. 

### PART 91.407 OPERATION AFTER MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, ORALTERATION: a) No person may operate any aircraftthat has undergone maintenance, preventive maintenance, rebuilding, oralteration unless - 1) 

### It has been approved for return to service by a person authorized under 43.7 ofthis chapter; and Drone America requests for relief ofexemption of Part 91.407 (1) in parton the basis that Drone America is the sole operator and the DAx8 is considered Experimental and the AVO is responsible for all maintenance, preventive maintenance, rebuilding and/or alterations. 

### PART 91.409 INSPECTIONS: a) No person may operate an aircraft unless, within the preceding 12 calendarmonths2) 

### It has had an inspection for the issuance ofan airworthiness certificate in accordance with Part 21 ofthis chapter. Inspections and preventive maintenance is performed priorto each flight, therefore, Drone America requests for relief ofexemption of Part 91.409 (a)(2).

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 3Drone America, Inc. Federal Aviation Regulationsfor Exemption 

### PART 91.417 MAINTENANCE RECORDS: a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section:

Drone America, Inc. 2015 

### 1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (Including the airframe) and each engine, propeller, rotor and appliance ofan aircraft. The records must include: i) A description (or reference to data acceptable tothe Administrator) ofthe work performed; and 

### ii) The date ofcompletion ofthe work performed; and iii) The signature, and certificate number ofthe person approving the aircraft for return to service. 2) Records containing the following information: i) The total time in service ofthe airframe, each engine, each propeller and each rotor. ii) The current status of life-limited parts ofeach airframe, engine, propeller, rotor and appliance. iii) The time since last overhaul ofall items installed on the aircraftwhich are required to be overhauled on a specified time basis. iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program underwhich the aircraftand its appliances are maintained. v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD orsafety directive involves recurring action, the time and date when the next action is required. vi) Copies ofthe forms prescribed by 43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. b) The owner or operator shall retain the following records for the periods prescribed: 1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work, or for 1year afterthe work is performed.

Section 333 Exemption for UAS Operations 4Drone America, Inc. Federal Aviation Regulations for Exemption 2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthe time the aircraft is sold. 3) A list ofdefects furnished to a registered owner, or operator under 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. Drone America proposes a similar maintenance program that provides a general maintenance plan to maintain a safe condition for Unmanned Aircraft System (UAS) operations, with consideration for relief ofa licensed aircraft mechanic to perform maintenance. The Aircraft Maintenance Manual (AMM) predicates the scope of maintenance to be performed by the AVO priorto each flight followed by a postflight inspection. The maintenance manual is a separately controlled document that describes and compiles the scope ofdetail and maintenance procedures recommended by the manufacture, Drone America, Inc. This program is developed to identifythe maintenance and inspections to be performed progressively as each flight occurs. Major and minor components will require service, repairs and standard maintenance to maintain a condition ofsafe operations. To ensure flight safety and standards of safe conditions, the operator is required to use the Preflight Checklist as referenced in 81.30.34C; Appendix A for a Maintenance and Inspection Program. Aircraft maintenance is recorded in the aircraft maintenance logbooks specific tothat aircraft, describing all maintenance procedures and repairs as defined by the manufacturer's limitations. Maintenance, repairs and general conditions are in accordance with Title 14 CFR Part 43 Appendix D, as to the applicable aircraft and inspection schedules set forth bythe aircraft manufacturer. The manufacturer's checklists and the Aircraft Maintenance Manual define inspection schedules and scope ofdetails. The Progressive Maintenance and Inspection program is predicated to continuous safety and is conducted on a routine schedule throughout a 12-month calendar year. Inspections are to be performed based on the hours of UA, or cycles ofoperations. The inspection program prescribed is to be performed by a person who is an authorized manufacture's technician. The authorized technician is required to inspectthe aircraft, document thefindings and record all required maintenance, and return to service in a safe condition for flight. Inspections shall be done in compliance with 14 CFR 43.13 Appendix D and in accordance with the manufacturer's inspection checklist.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 5Drone America, Inc. Federal Aviation Regulations for Exemption 

# UMANNANED AIRCRAFT SYSTEM OPERATIONS 1. OPERATIONALAND DESIGN CHARACTERISTICS: DAx8 is a VTOL (Vertical Takeoff and Landing) class aircraft. This UA is made of light-weight composite material for structural strength and increased payloads that is intended for hovering and low speed normal flight configurations. Configured as a land base Unmanned Aircraft Vehicle (UAV) this robust multirotor aircraft is designed for commercial, industrial and ISR applications. The unique 8 rotor configuration allows the DAx8 to carry a large payload while providing more safety and redundancy tothe system. The advance software and GPS guidance system provide the aircraftwith self-stabilizing capability and multiwaypoint navigation. The DAx8 is powered by eight electric brushless motors that produce high level performance and thrust. The aircraft is intended to carry payloads such as atmospheric sensors, surveying sensors, mapping equipment, and high definition stabilized video and data links. Structural analysis and physical characteristics ofthe aircraft and electric motor analysis demonstrates that the airframe is capable of a thrust range of 19.9 to 29.2 pounds ofthrust. Through indoorflighttestingthe DAx8 will be evaluated in various flight maneuvers, and is not capable of fluttering throughout the flight envelope duetothe lack ofmoving parts. Throughout flighttest parameters, stress analysis will provide data for positive or negative structural integrity. Based on other flight experience with similar platforms, flight data has not presented any unsafe conditions that would cause concern for safety while conducting flight within the normal category as defined in the user's manual. The airframe is constructed from 100% composite material, laid up in CNC molds utilizing standard wet layup bagging method. The carbon fiber airframe typically consists of four-layers that is applied one layer at a time, utilizing standard composite layup practices of sequenced alternating layers. The carbon fiber layup is alternated in a unilateral direction of 

## oo and 45° bias layers, which provides a light weight durable airframe capable of withstanding harsh environments and abuse. Manufactured parts are vacuum bagged and oven baked to a temperature of 160° and temperature controlled through a ramped up and ramped down process to assure proper cure as instructed perthe resin manufacturer. Work is performed in accordance with AC 20-107B as guidance and in compliance with 14CFR Part 23.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 6Drone America, Inc. Federal Aviation Regulations for Exemption 

### UAS PreflightOperations: Preflight planning is a multi-task process requiringweather briefing, mission planning, preflightsafety checklist, and UAS walk-around inspections. Weather Briefings: Weather briefings may be obtained through various sources: • Flight Service Station (FSS) • Telephone Information BroadcastSystem (TIBS) • Transcribed Weather Broadcast System (TWEBS) • Direct UserAccess Terminal System (DUATS) Weather analysis must be recorded priorto each flight and logged on thefollowingweather analysis tables denoting current and forecasted conditionswithinthetime ofthe operation. Regional weather updates may be obtained within the vicinity of the airport or the operation area by contacting these agencies to obtain current weather information and verify suspected deteriorating conditions: • The Automated Weather Observation System (AWOS) • Automated Terminal Information Service (ATIS) The Mission Commander must present a detailed mission plan prior to the mission outlining the scope and objectives of the operation. The Mission Commander in conjunction with the Operations Manager is responsible forthe developmentand the outcome ofthe operation. The initial scope of preflight planning objectives will be developed as part ofthe operational flight testing, development and eventual marketing. This provides for expectations to be readily met, or exceeded in the operational preflight and planning process. Preflight communications amongst crewmembers and Operation Managers establishesthe objective ofthe mission criteria and expectations. In the preflight briefing the Operations Manager will assign a Mission Commander for the test operation to be responsible for organizing personnel, UAS systems and equipment for the mission. Should the Mission Commander find the resources to conduct the mission adequately and safely are unavailable, he is to notify the Operations Managerto resolve the problem/s. Atthe time the Mission Commander is assigned the responsibility ofthe operation, he becomes the point of contact for all mission-related issues. The Mission Commander mustdiscuss mission objectives, weather and address any requests in regards to the mission. The Mission Commander must keep record of all correspondence and documentation pertainingtothetest operations. The Mission Commander must brief all personnel before the commencement of the test operations and allocate duties atthis time. The briefing should take place before departure ifoperations are at a remote site.

DroneAmerica, Inc. 2015 Section 333 Exemption for UAS Operations 7Drone America, Inc. Federal Aviation Regulations for Exemption
All personnel and support crew must be briefed on: • Mission objectives • Crew Duties and responsibilities • Operating conditions • Flight planning • Perceived difficulties (ifany) • Emergency procedures • Currency and training requirements • Flight Planning Flight planning shall be the responsibility ofthe Mission Commander and is considered a key factor in the success of every operation. The Mission Commander must consider weather, UAS payloads, performance, and battery endurance. No person may begin a flight in the UA under VFR, or IFR conditions unless consideration for meteorological conditions is taken into consideration and conditions have been calculated to determine there is adequate battery life to complete the planned mission and return to the scheduled point of landing under normal operational speed. In addition, backup batteries must be fully charge and available for replacement when necessary for the duration ofthe operation. 

### Payloads: The DAx8 payload is client specific and the DAx8 is capable ofcarrying awide range of payloads weighing upto4.4 pounds, including stabilized EO/IR gimbal, multi-spectral sensors, geo-imaging payload, etc. Due tothe nature of UAS operations with awide range of payloads, all internal and external payloads require the UAto have weightand balance calculation priorto every flight. The payload compartment is located in the center ofthe aircraft, directlyoverthe desired CG, makingthis task straightforward. 

### Flight: All commands duringflight operations are directed and changed via the GCS software controls interface in real-time. i. During flight, theAVO monitorstelemetry data and makes appropriate changes in altitude, speed, heading and waypoints using keyboard/touch screen inputs and/or mouse point and click commands. Additionally, theAVO can also control the UA using astylus for point and touch to controlthe UA's direction. ii. The systems required for normalflightoperations includethe GCS, the ground side data link and associated antennas, the autopilotand 3D GPS, static air pressure sensor, and air data link.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 8Drone America, Inc. Federal Aviation Regulations for Exemption
iii. Critical process points include: • Adequate number ofGPS satellites acquired to provide 3D solution • Functional primary communication data link • Functional autopilot Flight Core and IMU • Current maps and weather data are loaded on theGCS • Batteries are fully charged priortotakeoff • Motors are inspected for proper rotation direction and correct propeller orientation is verified. • Sensor/payload is installed correctly and securely. a. The DAx8 control mode is selected bytheflight mode switch on theAVO Hand Held Controller, or by selectingtheflight mode in the ground station user interface. The flight control modes available depend upon the hardware installed. The following three optionsforflight modes are available: 1. Manual- Direct control via RC controller 2. Attitude mode- Autopilotself-levelsthe aircraft, while still being guided by the AVO 3. Autonomous- Fully controlled via the autopilotand uploaded waypointset b. The control panel screen will displaythe control mode ofthe UA. c. In-Flight Plan Deviations: In-flight deviations are madethrough the autopilotsystem. The course is quickly changed through the Command Loops screen by setting a newwaypoint and commandingthe UAV totracktothe new course. The autopilotwill askthe AVO to confirm this command priorto makingthe deviation. The flight plan may also be changed through the EFIS by sliding, orclicking on the altitude, airspeed and heading bugs to set a new course. These methods also require aconfirmation bytheAVO prior to execution ofthe command. d. Lost Communications:

Drone America, Inc. 2015 AVHF communication radio allowsforacommunication linktoATC orthe controlling agency. Additionally, there are also handheld air band radios in case of lost communication toATC orcontrolling agency. Ifcommunication is lostwith ATC, or the controlling agency the UA will maintain lastflight plan, or return to base via predetermined/pre-planned routes until communication with ATC, orthe controlling agency is re-established.

Section 333 Exemption for UAS Operations 9Drone America, Inc. Federal Aviation Regulations for Exemption 4. Landing and Recovery: Landing is performed in the same way as takeoffor launching in a hovered configuration.
5. Post Flight: a. Systems required forsafe postflight operations include aircraft retrieval, aircraft shut down, proprietary equipment properlystored and the aircraft secured. i. After each flightthe UA will be plugged in so that its onboard telemetry data can be downloaded and avisual inspection can be performed. ii. During post flight, priorto power off, the data from the autopilot must be downloaded forfuture replay in software in loop simulation. iii. Post flight inspection • Inspectforvisible damagefrom hard landings/debris ingestion into

propellers (bugs, rocks, sand etc). • Inspect all exposed fasteners and screws for security. • Inspect camera/payload/sensorfor any damage. • Inspect batteries and wiringfor excess heat generation which may

suggest a pendingfailure. • Inspect all antennae and exposed equipmenttoensure they are free

ofdamage. b. Post flight inspection happens afterthe electric motors are shut down and the DAx8 power is OFF. The Crew Chiefwill conduct avisual walk around inspection ofthe aircraft and connectthe data terminal cable from the GCS tothe aircraftto download theflighttelemetry. 6. Operating History: Currentlythe DAx8 is in production with a projected rollout in early December 2014. Initial testflights have been conducted indoors at Drone America's productionfacility. Initial gain tuning has been completed and stable flight has been demonstrated. Initial flighttestingwill be performed in an indoor arena. Flight testingwill continue indoors until authorization is approved for outdoor testing.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 10Drone America, Inc. Federal Aviation Regulations for Exemption 

### 2. Maintenance, Inspection and Repairs: Referto page 7forthe description ofthe maintenance, inspection and repairs procedures. Prescribed Maintenance Procedures: 

## LIST OF EFFECTIVE PAGES CHPTR TITLE PAGE(s) REV EFFECTIVE DATE Contents v, vi Original 17Sept2014 1 DAx8 Progressive Inspection 76 Original 17Sept2014 Conditionsfor Return to Service 76 Original 17Sept2014 2 UAS Aircraft Data 77 Original 17Sept2014 3 Owner/OperatorAttitude 77 Original 17Sept2014 4 DATA 77 Original 17Sept2014 5 Records 77 & 78 Original 17Sept2014 6 General Access and Conditions 79 Original 17Sept2014 7 General Cleanliness 79 Original 17Sept2014 8 Portable Ground Control Station 79 &80 Original 17Sept2014 9 Aircraft Electrical System 81 Original 17Sept2014 10 Aircraft Equipment/Furnishings 81 Original 17Sept2014 11 MiscellaneousAirframe Insp. 82 Original 17Sept2014 12 Aircraft Exterior Inspection 82 Original 17Sept2014 13 Landing Gear Inspection 82 Original 17Sept2014 15 Electric Motor Inspection 83 Original 17Sept2014 16 BatterySystems 83 Original 17Sept2014 17 Propellers 83 Original 17Sept2014 18 Ground Control Station 84 Original 17Sept2014 Equipment/Furnishings 19 Special Inspections 85 Original 17Sept2014 20 Conditions of Inspection 86 Original 17Sept2014 Statement 21 Weightand Balance Sheet 87 Original 17Sept2014 22 Airworthiness Directive Sheet 88 Original 17Sept2014 AppendixA 1-A Original 17Sept2014 Airman's Preflight Checklist 1-A,thru 8-A Original 17Sept2014 23 Appendix B 1-B Original 17Sept2014 Squawk Sheet 1-B Original 17Sept2014

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 11Drone America, Inc. Federal Aviation Regulationsfor Exemption 

## REVISION PAGE CONTROL SHEET Removed Effected Page Date Inserted Effected Page Date Pages Description Pages Description

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 12Drone America, Inc. Federal Aviation Regulations for Exemption 

# ProgressiveInspectionChecklist Current dateofissue: September 16, 2014 Reference Data: FAA Order8130.34C, CFR 21 Certification Procedures for Products and Parts CFR 23 Airworthiness Standards, CFR 43 Maintenance, CFR 45 Markings, CFR 47 Registration, CFR 39 Airworthiness Directives, CFR 91 Subpart E, Maintenance, Preventative Maintenance and Alterations, CFR 145 Repair Stations, AC 43.13-18 Acceptable Methods,Techniques and Practices and 2B Major Repair and Alterations and the Manufacture's Maintenance Manual. 

# Conditionsfor Return to Service 1) The unmanned aircraft system (UAS) must be returned to service in condition for safe operation. Inspection is to ensure thatthe aircraft is notsubjectto unusual wear, structural damage and/or system malfunctions. 2) Aircraft configuration and components installed must be consistent with manufacturer's drawings, specifications and otherdata that are part ofthe equipment list. 

### NOTE:
NOTE: 

### Ifeitherof theseconditionsarenotmet, theunmannedaircraftwouldnotbe consideredsafe foroperationandcannotbereturnedtoservice. This isamanufacturesreferenceguidefora Progressive Condition inspection checklistspecifictoDroneAmerica'sexperimentalUnmannedAircraft. This checklisthasnotbeenapprovedbytheFAA atthetimeof publishingthisoriginal document. Referencetothemanufacturer'smaintenancemanualisnot exhaustiveandconsideration toCFR43AppendixDshouldbeconsulted. Inspection checklistsare updatedperiodicallyandpersonnelperformingsafety inspectionsshouldreference www.droneamerica.commaintenance for update revisionspriortoinspections. The owner/operatorisresponsibleformaintainingthe UASin asafecondition, including compliancewithallmanufacturer'sdirectives andoperatinglimitations. The owner/operatoris also responsiblefor theinspection of the UASsystemtoinsurethattheaircraftis in compliance with CFR23AirworthinessStandards, andCFR43AircraftMaintenance.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 13DroneAmerica, Inc. Federal Aviation Regulations for Exemption 

## UAS Aircraft Data: UAS Model:-------- N-Number: ________ _ Serial Number: _______ _ Year:



## --- Owner/OperatorAttitude: Does Owner/Operator have a constructive attitudetoward Compliance? Order2150.3A Par. 205 

### Yes D No D N/ AD Verify MaintenanceTechnicians authorization CFR 65.91 

## DATA: Yes D NoD N/AD



### 1. Manufacturer's Maintenance Manuals available? Yes D NoD N/AD 2. Alterations- By what means are they approved? Manufacture D Field Approval D or Other D 3. Instructionsfor continued safe operations? Yes D NoD N/AD CFR 23.1529 

### 4. Aircraft Flight Manual? AFM Date: /Rev# 5. Aircraft Placards CFR45.13 

### 6. Verify all eight motors make/model are the same: Motors: KDE2814XF-775 CFR 45.11

DroneAmerica, Inc. 2015 Section 333 Exemption for UAS Operations 

### Yes D NoD N/AD
Yes D NoD N/AD 1-Hours:



## --- 2-Hours:
__ _ 3-Hours:
__ _ 4-Hours:

--- 

### 5-Hours:



## --- 6-Hours:
__ _ 7-Hours:
__ _ 8-Hours:



## ---

14Drone America, Inc. Federal Aviation Regulations for Exemption 

### 7. Verify critical component placards and serial numbers. 8. Verify life limited parts placards. 

## Records: 1. Verify current Ground Control Station software updates CFR 91.9 

### Yes D NoD N/AD Yes D NoD N/AD
Yes 0 NoD N/AD 2. Verify Experimental Airworthiness Certificate in GCS (Original Issue) Yes D NoD N/AD CFR 91.319 

### 3. Previous inspection: Total time: ___ _ Date completed:
__ _ Certified MaintenanceTechnician#_______ _ Yes D NoD N/AD CFR 43.11, 91.417 

### 4. Verify current and reoccurring AD's- Record in Aircraft maintenance logbooks: 

### 1. Airframe Yes D NoD N/AD 2. Motors Yes D NoD N/AD 3. Propellers Yes D No D N/ AD 4. Appliances- See additional pages ifapplicable CFR 91.417 

### Yes D NoD N/AD 5. Verifystatus of life limited parts. Go to: www.droneamerica.com maintenance for Effective Date: ___ _ CFR 43.10 

### 6. Verify currentAircraft Flight Manual (AFM) is available CFR 91.9 

### 7. Verify currentweight and balance sheets are available Verifysignature and date. 8. Verify ID plate is secured to UAS fuselage exterior. 9. Verify maintenance records for each motor, propeller, airframe and appliance is in accordance with CFR 91.417. 10. VerifyATC Transponder/wADS-B has been checked within the past 24 calendar months per CFR 91.413 11. Verify autopilot/altimeter has been checked within the past 24 calendar months perCFR 91.411, 43 Appendix E
Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### Yes D NoD N/AD

Yes D NoD N/AD Yes D NoD N/AD
Yes D NoD N/AD
Yes D NoD N/AD
Yes D NoD N/AD

15DroneAmerica, Inc. Federal Aviation Regulations for Exemption 

### 12. Verify autopilot-pitot/staticsystem has been tested within the Past 24 calendar months perCFR 43 Appendix F 13. Record deferred items per Part 91 fordaytimeVFR operations: a. Is the component placarded? b. Is there a maintenance record entry? c. Is the component disabled or removed? 

### General Access and Conditions:

a. Remove lowerairframe hatches b. Remove optical payloads
c. LOCK OUT- 

### Install 1fT" 

### pin in ballistic recovery parachute 

### General Cleanliness: 1. Wash/Clean exteriorofaircraft 2. Clean aircraft interior 3. Clean all motors and propellers 

### Portable Ground Control Station Inspection:

1. Verify placards are correct and readable pertheAFM. CFR 23.1541-1567, CFR 91.31 

### 2. Verify INOP placards: CFR 91.213 

### a. INOP instruments may only be disabled or removed byanA&P. b. Verifycurrent equipment list. 

### c. Verify maintenance records entries are updated. d. VerifyWeight and Balance records are current. CFR 91.9 Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### Yes D NoD N/AD
Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD

Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD

Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD

Yes D NoD N/AD
Yes D NoD N/AD
Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD

16Drone America, Inc. Federal Aviation Regulations for Exemption



### 3. Verify compass is correct in the primaryflight display as shown in Electronic Flight InstrumentSystem (EFIS). Yes 0 No 0 N/AO 4. Verify clock is settothe correcttime zone on the monitor panels. Yes 0 No 0 N/AO 

### 5. Verify Handheld Nav Radios Part Numbers: a. P/N 

### 1 b. P/N 2 

### 6. VerifyTransponder Part Number: a. P/N 

### 7. Verifythere are no unusual odors (Such burning electrical smells). 

### 8. Verify Portable Ground Control Station registration concurs with Data plate. 

### 9. Verifyfire extinguisher is charged, properly rated and accessible. 

### 10. Verify speed controllers are operational. 11. Verifythrottletravel is not restrictive and consistent with RPM, figures (Ifapplicable) on the Controller Configuration Screen. Yes 0 No 0 N/AO Yes 0 No 0 N/AO
Yes 0 No 0 N/AO Yes 0 NoD N/AD
Yes 0 NoD N/AD Yes 0 NoD N/AO Yes 0 NoD N/AD
(Perform motor run-up -Idle, advance to max. RPM, backto Idle) Yes 0 NoD N/AD 12. Verify condition of Portable Ground Control Station. Yes D No D N/ AD 13. Verify electrical wires are properly identified. Yes 0 No D N/ AD 14. Verifythere are NO loose electrical connections. 15. Verify electrical wires are secure. 16. Instruments: 

### AirwareAutopilotSystem CFR 91.205 

### a. Verify autopilot-altimeter has been tested within 24 calendar months. CFR 91.411 

### b. Verify Electronic Flight Instrument System has been tested Yes 0 NoD N/AD Yes 0 NoD N/AD

Yes 0 NoD N/AD within the past 24 calendar months. Yes 0 No D N/ AD c. Verify Direction Indicator is accurate perAirware Systems. Yes 0 No D N/ AD Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 17Drone America, Inc. Federal Aviation Regulations for Exemption 

### d. Verifythe operations ofthefollowing flight instruments have been inspected perAirware's inspection program: 

### 1. Airspeed Indicator 2. Altimeter 

### Aircraft Electrical System: 1. Verify condition ofaircraft switch. Yes D NoD N/AD Yes D NoD N/AD

Yes D NoD N/AD 2. Verifyvoltage and current draw (System Status Monitor).Yes D No D N/ AD 

### 3. Inspect aircraft wire harnesses for: AC 43.13 Ch. 11 

### a. Chafed orfrayed wires Yes D NoD N/AD b. Insulation penetration Yes D NoD N/AD c. Outer insulation cracking Yes D NoD N/AD d. Damaged orexposed wires Yes D NoD N/AD e. Evidence ofoverheating Yes D NoD N/AD f. Evidence ofarcing Yes D NoD N/AD g. Evidence ofchemical contamination Yes D NoD N/AD 

### 4. Verify aircraftwires are properly labeled. Yes D NoD N/AD 

### 5. Verify aircraftwires are marked by gage size. Yes D NoD N/AD 

### 6. Inspect bus barfor burned ortripped conditions. Yes D NoD N/AD 7. Verify grounding point nuts are tight and free ofcorrosion. Yes D NoD N/AD 8. Verifywires are properlyclamped and secure. Yes D NoD N/AD 

### Aircraft Equipment/Furnishings: 1. Verify installed equipmentfunctions properly. Yes D NoD N/AD 2. Verify correct Flight Manual for applicable aircraft being operated from the Portable Ground Control Station is available. Yes D NoD N/AD 3. Verify batteries are charged. Yes D NoD N/AD 4. Verify batteries are properlysecured. Yes D NoD N/AD
Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 18Drone America, Inc. Federal Aviation Regulations for Exemption 

### 5. Verify backup batteries are charged. Yes D NoD N/AD 6. Visually inspect ballistic recovery parachute. Yes D NoD N/AD 7. Visually inspect autopilotforsecurity and no adverse conditions.Yes D NoD N/AD 

### MiscellaneousAirframe Inspection: 1. Verify antenna connections. 2. Inspect for corrosion on, or around antenna connections. 3. Inspect hatch seals for cleanliness, cuts, orabrasions. 4. Inspect lower hatch fastener blind nuts and hardware. 

### Aircraft Exterior Inspection: 1. Inspect airframefor delamination, pin holes, cracks, blisters and chipped paint. See manufactures AMM for acceptable limits. 2. Inspect registration markings. (Replace or repair ifrequired) CFR 45.22(b) 

### 3. Inspect beacon. 4. Inspect condition ofnavigation lights. 

### Landing Gear Inspection: 1. Lift aircraft and turn overto inspect landing gear for bent, fatigued orcracked struts. 2. Inspect foroverweight landings. See Special Inspections and AMM for procedures.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD

Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD Yes D NoD N/AD

Yes D NoD N/AD
Yes D NoD N/AD

19Drone America, Inc. Federal Aviation Regulations for Exemption 

### Electric Motor Inspection: 1. Perform a motor inspection byvisually checking fordebris in thewindings or bearings. Physicallyturn the propellers to ensure smoothness ofoperation. Yes D No D N/ AD CFR 43.15 

### 2. Inspect motorcontrol arms for cracks or delamination's. Yes D NoD N/AD 3. Inspect condition ofmotorwires. Yes D NoD N/AD 4. Inspect overall condition ofmotors Yes D NoD N/AD 

### BatterySystems: 1. Inspect condition ofbatterycells. Yes D NoD N/AD 2. Verify batteries are secure. Yes D NoD N/AD 4. Verify batteries are charged. Yes D NoD N/AD 

### Propellers: The DAx8 uses 8 counter rotating propellers; 4 CW and 4 CCW. These alternate in rotation direction. The #1 propeller is the front left. This is a CW propeller as viewed from above. Each consecutive propellershould alternatefrom CW to CCW to CW as inspected in aclockwise fashion around the perimeterofthe DAx8. Each propellershould be inspected as follows: 

### 1. Verifycorrect propeller rotation direction and orientation (thrust direction) 2. Inspect propellersfor physical signs ofdamage or abuse 3. Checkthat propeller bolts are tight Propellertype: Fixed Propeller Material: Composite 

### 1. Is the propeller maintenance record logbook available? Yes D NoD N/AD 2. Ifthere is no propeller maintenance logbook, sign inspection offin Airframe Logbook. 3. Inspect propellers condition for nicks, cracks and delamination's.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### Yes D NoD N/AD Yes D NoD N/AD

20Drone America, Inc. Federal Aviation Regulations for Exemption 

### 4. In the event ofpropeller damage, remove and replace propeller. Yes D NoD N/AD Special Inspection: 

### In the event of propeller damage, DO NOT attemptto repair. 5. Verify proper propellerscrews are used per manufacturer's recommendations. 

### Ground Control Station Equipment/Furnishings: 1. PanasonicTough Pad 

### 2. COMMS 

### 1 

### &2- Garmin/GTR 

### 225 

### 3. Airware AutopilotSystems 

### 4. SageTech XPS-TR ModeSwith ADS-BOutTransponder 

### 5. Video Receiver

### 6. Video and Voice Recorder

## 7. Ground Data Terminal GDT 

### 2100- TECOM Industries. 

### 8. Spectrum Analyzer

### 9. Range Attenuator

### 10. Antenna Selector Control - 

### 11. Verify Portable Ground Control Station batteries are charged. 

### 12. Verify Portable Ground Control Station is connected to main power supply. 

### 13. Verify Ground Control Station Operating Handbook is readily available. 

### 14. VerifyAircraft Flight Manual (AFM) is applicableto aircraft currently being operated. 

### 15. Verify current aircraft registration.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### Yes D NoD N/AD
Yes D NoD N/AD

S/N S/N S/N S/N S/N S/N S/N S/N S/N S/N Yes D NoD N/AD
Yes D NoD N/AD
Yes D NoD N/AD
Yes D NoD N/AD Yes D NoD N/AD

21DroneAmerica, Inc. Federal Aviation Regulations for Exemption 

### Special Inspections: Occurrence 1. Structural Damage Inspection: 

### Visible damagetothe skin ofthe DAx8 less than a quarter ofan inch in diameter is notconsidered structural damage. Damage exceeding morethan a quarterofan inch in diameter, consultthe AMM for engineered fix. Ifaircraft has experience hail damage, consult engineering priorflight. The structural components which could be damaged are within the central compartment ofthe DAx8, and must be inspected each landingfor signs ofcracking and wear. Any damage in the landing gear or motorarm mountingareas is considered out of limits ofsafe operations and must be repaired. 2. Hard landing inspection: Gear Struts- 

### Perform the following inspection: I. 

### Inspect landing gear screw location holes for elongation. II. Inspect airframe structureforstructural cracks, delamination orsplintering around gear attach points. Ill. Inspect each gear strutto ensure they are not bent, or cracked IV. Ifstruts are bent, elongated bolts holes or cracked, Remove and Replace. 3. Overweight landings. 

### the DAx8 cannot land overweight as its weight does not change duringflight. Maximum takeoffweight is significantly less than the maximum landing load expected during normal operation.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 

### Inspection Immediately

Immediately



## N/A

22Drone America, Inc. Federal Aviation Regulations for Exemption
4. Lightning strike damage. (Airframe 

### & Electronics Inspection) 

### Upon landing In the event oflightningstrike damage, inspect structure for burns, blisters and delamination. Consult theAMM forstructural repairs. All electronics must be returned to Drone America for inspection. 5. Severe turbulence inspection. 

### The DAx8 is not intended tofly in areas ofsevere turbulence. Its configuration however is nottypically susceptible to overload due toturbulence. Controllability may be affected, but structural damage is highly unlikely. Condition of Inspection Statement: 

### No person may sign-offany repair, alteration, or modification tothis aircraft unless theyare a qualified mechanic that has been authorized bythe manufacture as a MaintenanceTechnician. The MaintenanceTechnician must provide astatement ofrelease priorto returningthe aircraftto service. 

### Icertifythatthisaircrafthasbeeninspectedon 20
__in accordancewiththescope anddetailof 14CFR43,AppendixDandDroneAmerica'sAircraftMaintenanceManual{AMM), andhave foundtobein aconditionforsafeoperationin compliance with FAA'sacceptable maintenanceand100-HourInspection Program. Aircrafttotaltime:
__ _ A 

### & P:
_________ _ 

### Print -----------Lie.#
_________ _ Signature Maintenance Technician:
_________ _ Print

_________Auth. #
______ _ 

### Signature

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 23Drone America, Inc. Federal Aviation Regulations for Exemption 

## WEIGHT and BALANCE SHEET Date: __________ _ Aircraft Make/Model:______ _ Serial Number:---------- Removed Weight Arm Moment Equipment



### Total Installed Weight Arm Moment Equipment



### Total
Forward Limit Check (Limit?) 

### A/C Empty Weight Arm Moment Payload Total

Performed By: ________ _ Signature: ___________ _ Mechanics License#:



## -------

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 24Drone America, Inc. Federal Aviation Regulations for Exemption 

### 3. Communication and Frequencies: 1. The MicroHard control system architecture is described below: The primary data and pilot link is a 902 - 928MHz spread spectrum frequency band with 400 kHz increment and an approximate 175kpbs data rate. The data link is configurable between 1Hz, 10Hz and 25Hz telemetry data update rate. 2. Communication data links used on Drone America's DAx8

Drone America, Inc. 2015 a. Data link descriptions: The 2.4Ghz spectrum will be used for command and control, as well as, potentiallyvideo downlinkforthe DAx8. The Microhard 2.4Ghz Nano series n2420 will be used. Spectrum approval is not needed as 2.4Ghz is open tothe public under FCC Part 15.247, IC RSS210, CE. b. The Microhard Nano series radio is notencrypted as standard, but has the abilityto support both 128bitand 256bitAES encryption in the USA, and with permitfor use outside the US and Canada.
c. The primary command and control 2.4GHz data link has range up to 10 miles with the Omni antenna, and up to 40 miles with Vagi directional tracker antenna. The range was determined by the autopilot manufacturer through extensive testing. The DAx8 is not expected or intendedtooperate at adistance greaterthan 3 miles from home base. Primary flight telemetry data such as airspeed, altitude, attitude, and position have precedent over all other telemetry. Telemetry update rate is selectable between 1Hz, 10Hz and 25Hz. d. The radio signal strength indication is displayed on the system window and the value is measured by the GCS software and displayed on the Radio Signal Strength Indicator (RSSI) with typical operational range of-71 to -115. e. The DAx8 is not currently equipped with redundant control links. At the intended operating range, the single Microhard data link is very robust. In the event a lost link situation should occur, the lost link procedures pre-programmed into the autopilot are executed. This includes a return to home command. Should link be lost, the UAV will automatically head home, therefore reducing range, and typically the link will be reestablished. f. The DAx8 does not use satellite communications for command and control. g. Due to the sparsely populated location of operations there are no foreseen interferences from any outside influences that would affect UA operations. Areas of operations are unlikely to have inference with other communication sources due to the UA operating on an assigned frequency.

Section 333 Exemption for UAS Operations 25Drone America, Inc. Federal Aviation Regulations for Exemption
3. Design characteristics and proceduresto prevent lost communication: a. In regards to RF interference - Careful design and integration of antennas and antenna locations are positioned to ensure minimal RF interference between different RF sources, and between different potential sources ofRF interference. b. Pilots are trained extensively with an in depth knowledge of RF and aircraft limitation to prevent inadvertent flight beyond communication range. This requires careful flight planning with consideration for altitude and terrain masking. The flight control system also warns the pilot when the RSSI quality is below the threshold. A robust communication link capable of up to 40 miles with proper antennas is implemented on the DAx8, which is notexpected to operate fartherthan 3 milesfrom home. c. Antenna mounting locations are carefully calculated and tested to ensure that maximum communication is obtained. Exposure to each antenna is independent of the aircraft orientation. d. In the event of loss of GCS communication and functionality, the UA will automatically execute a preprogramed lost communication flight plan which can include auto-return home and auto-land. e. Loss of UA functionality will activate flight termination which includes motortermination and deploymentofthe parachute, and/oraerodynamictermination ifrequired. f. Atmospheric attenuation including precipitation condition may cause degradation ofthe communication link quality. Careful flight planning must be performed while taking into accountforatmospheric conditionsthat may decrease operational range. 

### 4. Pilot/CrewQualifications/Training Reference: 1. Drone America's FlightTraining Syllabus has been established to provide a progressive curriculum to maintain pilot proficiencies in accordance with CFR 14 Part 61.3, 63 and CFR 14 Part 91.3 that is in compliance with 8130.34C, AppendixA. Course instructors are qualified ATP with a Designated examiners (DE) endorsement, CFII, Multi-engine instructors. Instructors are qualified in UAS mission planning, flight planning and field deployment. a. PilotTraining: Each UA pilotapplicant currently holding an FAA pilot certificate and fulfills Drone America'straining requirements, will receive upon completion ofsatisfactorily passingthe Practical Test Standards, aCertificate thatqualifies him or her as a UA pilot.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 26Drone America, Inc. Federal Aviation Regulations for Exemption b. Formal Pilot Curriculum: Atraining curriculum has been developedthatfollows the FlightTraining Syllabus and instructed by a licensed FAA Flight instructorto maintain proficienciesfor all UA pilots.
c. Observers: i. Pilot Certificate- Typically observers will not be required to hold a pilot certificate. However, observer applicants are required toattend and satisfactorily pass the practical test. Referto Drone America's 3-day Observer training course on page 65. Pilots who have observertraining may have to hold an observer position attimeswhen notacting as an AVO or PIC. ii. Medical Certificate- Observers are required to hold aClass 2 medical priorto acceptance intothe ObserverTraining Program and to meetcompliance with 8130.34C, AppendixA; and DroneAmerica's policies. iii. See and Avoid -Observers will be trained and familiar with Far Part 91 and tested to be in compliancewith see and avoid procedures, cloud clearances and right of way rules. iv. Training Curriculum- Observertraining curriculum shall involve an overview of Drone America's policies, operations and procedures. Observer applicants shall be knowledgeable in crew duties, crew resource management and familiarwith the appropriate sections ofthe Aeronautical Information Manual. Applicant qualifications require an individual to have 20/20vision, speak, read and write English and demonstratethe ability ofposition awareness. As referenced ObserverTraining is a 3 day course, in which applicants shall be trained in thefollowingtechniques to identifyand avoid potential ground and airborne hazards: v. ObserverTraining- As described in sub-section (iv) all observers must pass the curriculum testingto be aqualified observer. d. Observer Knowledge and Understanding: The observer shall be knowledgeable and have understanding in:

i. Proper communication and phraseology ii. Propervisual scan techniques iii. Standard flight operations at non-towered airports iv. Containment areas and howto determine UA range within the operating area

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 27Drone America, Inc. Federal Aviation Regulations for Exemption 

### 5. PilotType Ratings and Medical Standards: The chief pilot/instructor is qualified tofly DAx8 per FAR Part 61 and in accordance with 8130.34C Appendix A. Additionally qualified pilots:

Multi Engine, CFII, 16,790 700 1stClass ATP,ADP

Private 478 10 2nd Class Private 51 1878 Pending Total Time: 17,319 2583 PilotCertifications, FlightExperience andMedicals


### 6. Operations a. UA Operational Visibility: The DAx8 is unique and is easily identified by its enclosed eight-rotor configuration and spheroidal design and by the bright red and/or orange paint scheme on the airframe. The DAx8 is equipped with red and green LED navigation lights. In the event the anticollision lights are inoperative the flight shall be terminated until the condition is corrected. 

### b. Critical system process points include: The most critical system process is the setup oftheflight configuration filefor each airframe. This includes all ofthe data such as IMU orientation, ESC calibration, airframe weight and CG location relative tothe IMU. These parameters are configured per airframe type. The autopilot configuration, includinggains and all the flight parameters, can be copied to multiplevehicles with the exact same setup. In testing, it has been verified that the autopilot is robusttosmall changes in vehicle weight and balance, but itstill needs to be quantify how large the changes need to be before itis necessaryto re-tune thevehicle.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 28Drone America, Inc. Federal Aviation Regulations for Exemption



## c. Flight: When performingthe initial setup, itis necessary to know what PWM range the ESC's are calibrated to, and what PWM values correspond to min and maxthrottle parameters. These are entered as parameters intotheAirware configuration utility. These values are notavailable for most off-the-shelfspeed controllers; therefore, each ESC will have to be calibrated externallytothe same known PWM range. The configuration files are stored in theAirware cloud. Once created, they are stored in the data base foreasy access to new orexistingvehicles as information is needed or required. Version control is provided on theAirware cloud. The Mapping Updates are derived from Terra Server Google and Bing. Maptiles are cached and gee-referenced automatically. For elevation data, we use SRTM (Shuttle Radar Topography Mission) data thatcan be downloaded from the USGS. All maps are updated in real timevia the internet. Engine Start Ground Procedures forthe 0Ax8 has a built in software algorithm for motor start. Theflightcontroller must receive asignal fromtheground control station in orderto turn onthe motors, which is executed bytheAVO. This start and takeoffcommand requires asecondary confirmation from theAVO before being senttothe DAx8, thus preventing any chance ofan accidental start. All ground personnel are cleared and required to stand back 35 feetfromthetakeoffarea priorto motorstart.

All commands duringflight operations are directed and changed via the GCS software control interface in real-time. Duringflight, theAVO monitorstelemetry data and makes appropriate changes in altitude, speed, heading and waypoints using keyboard/touch screen inputs and/or mouse pointand click commands. Additionally, theAVO can also controlthe UA using astylus for pointand touch to control the UA's direction. The systems required for normal flight operations includethe GCS, the ground side data link and associated antennas, the autopilotand 3D GPS, static air pressure sensor, and air data link. Critical process points include: • Adequate numberofGPS satellites acquired to provide 30solution • Functional primary communication data link • Functional autopilot Flight Core and IMU • Current maps and weather data are loaded on the GCS

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 29Drone America, Inc. Federal Aviation Re;gulations for Exemption

• Batteries are fully charged priortotakeoff • Motors are inspected for proper rotation direction and correct propeller orientation is verified. • Sensor/payload is installed correctly and securely. The DAx8 control mode is selected bytheflight mode switch on theAVO Hand Held Controller, orby selectingtheflight mode intheground station user interface. The flight control modes available depend upon the hardware installed. The following threeoptionsforflight modes are available: 1. Manual - Direct controlvia RC controller 2. Attitude mode -Autopilotself-levels the aircraft, whilestill being guided by theAVO 3. Autonomous - Fully controlled via the autopilotand uploaded waypoint set 

### d. Flight envelope: Initialflighttestwill bedone indoorswithinthe productionfacility. Flightwill continue indoors until authorization is approvedforoutdooroperations. Outdoor operationswill consist ofline sight notexceeding Visual Line ofSight (VLOS) and nottoexceed

### 400' AGL. Operationswill be performed in asafe manorand in accordance with 

### 14 CFR Part 61 and Part 91. All outdoorflightswill be contained within a preplannedflight envelopethat is determined bythe mission commanderand approved bythe Flight Safety Officer. 

### 7. OPERATING SPECIFICATIONS: a. DAx8 operating specifications are: 

### Airtraft.

## Specifications. Aircraft Perforrnanee Airframe Diameter 4.0ft. Max speed 28mph Height 8.0in. Max rate ofclimb 500 ft./min Gross Weight 19.71bs. Max rate ofdescent 1,000ft./min Empty Weight 8.01bs. MaxService Ceiling *3,000ft. Max Range (LOS) .88Mi Max angle ofbank 40° Max Payload 4.41bs.
* Priortoflight, the AVO can set altitude limitationsfrom the Ground Control Station to

preventthe UAfrom exceeding specified altitudes.

DroneAmerica, Inc. 2015 Section 333 Exemption for UAS Operations 30DroneAmerica, Inc. Federal Aviation Regulations for Exemption 

### b. Minimum Flight Visibility and Distance From Clouds: Flight operations will be conducted in compliance with 14 CFR Part 91.155 Basic VFR Weather Minimums. Operations are generally

### 400' AGL and will be performed as stated in the Basic VFR Weather Minimum table. 

### c. Hazards: Outdoor Operations will be conducted in day-light hours in VFR conditions at

### 400'AGL, or less and withinvisual line ofsight. These flight parameters present a minimal meteorological hazard tothe operations and will not be operated in icingconditions. 

### d. Safety Mitigations: Prior toflight it is the responsibility oftheAVO, Mission Commander and the Flight Safety Officertoverifyand monitorcurrent and forecasted weather conditions. In the eventthe weather deteriorates,the flight will be terminated until adequate VFR conditions can be met per 14CFR Part 91.155.

Less than 

### 10,000 feet MSL
At or above 

### 10 000 feet MSL 

### 1,200 feet or less above the surface (regardless of MSL 

### a

than 

### 1,200feet above the surface but less than 

### 10,000 MSL

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 31Drone America, Inc. Federal Aviation Regulationsfor Exemption 

### 8. 

### OPERATIONS AREA: The areas ofoperations are within Washoe County and the FAA approved Reno-Stead Airport UAS Test Site. Each ofthese areas range from rural unpopulated desertto sparely populated areas to demonstrate emergency service proofofconcept. Each area is unique in that it provides differenttypes of research and development, as well as, implementation oftrainingvarious first responder teams in UA systems. The criteria for each area provides specificfield training relative to local emergencies and disaster relief mitigation. The following areas are depicted in red boxes on thefollowing charts:

Drone America, Inc. 2015 Reno-SteadAirport(UAS Nevada TestSite)



### Reno - Stead UAS Test 

### 500' Interior Buffer Reno-SteadAirportCoordinates

Section 333 Exemption for UAS Operations 32DroneAmerica, Inc. Federal Aviation Regulations for Exemption 

# ji:::::J Regional EOC; 72acres

2 0 0.75 1.5 3 I I Miles Nautical Miles Washoe CountyEmergencyOperations CenterandHomelandSecurity Trainingfacility

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 33Drone America, Inc. Federal Aviation Regulations for Exemotion 

# I

# c::J Verdi, 

### 5.sq. mi.

0_75 1.5 3 Miles () 0.5 I I I Nautical

**M~es** 2 I
VerdiMountain Training Center

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 34DroneAmerica, Inc. Federal Aviation Regulations for Exemption 

# I

# I:::::J BlackRock. Desert; 100sq. mi;

2 Miles 

### a 0 I 11i 3 I I Nautical Miles 6 I
Washoe CountyDesert Training Center

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 35DroneAmerica, Inc. Federal Aviation Regulations for Exemption



### San 

### Francisco SEC

### 93 VFRmap 0 1.2§ 2.5 5 0 I 2 I I Nautical Miles 4 I
Washoe County Urban Training Center (MockbuildingsforFire Crew Training Center)

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 36Drone America, Inc. Federal Aviation Regulations for Exemption 

### A. OPERATIONS AREA DESCRIPTION:
1. 

### Reno/Stead Airport- The Reno-Stead Airport has been designated by the FAA as a UAS test site range. As proposed, the initial outdoorflighttesting is to be performed in Class Gairspace within an FAA designated test area at Reno/Stead Airport. The testfacility area is 812 acres 2.2 miles north ofthe main active runways 8/26. Runways 14/32does have the capabilityto be closed bythe airport authority duringflighttest operations. The airport authoritywill post an AWOS and a NOT AM notice broadcastingthe date and times of Unmanned Aircrafttesting and air operations forthe Reno/Stead Airport. The Reno/Stead Airport is secured by perimeterfencing and therefore, restricts unauthorized activities ofpublic access and/or events. The test area is in a remote location 1.8 miles northeastofa housing subdivision. 

### 2. Washoe County Emergency Operations Centerand Homeland Security Training facility-The regional Emergency Operations Center (EOC) is a 72 acre training facility that provides disastertraining for HAZMAT and environmental containment, and natural disaster remediation. The operation area is located 5 

### V2 miles northwest ofthe Reno/Tahoe International Airport under Class C airspace. The Class Cairspace extends from 7,200' MSL to 8,400' MSL. Whereas, flight operations within the EOC facility will not exceed 5,550' MSL, it is contained within a small canyon. This facility is 

### V2 mile from a sparely populated area and does not pose a flight risk or noise nuisance to surrounding structures due to the speed and weight ofthe UA. 

### 3. Verdi Mountain Training Center - Is located in the Mount Rose Wilderness Area at an elevation of 7,500' MSL. This operation area is 5 square miles with no structures or population within 6 miles ofa population center. The purpose forthis location provides UAS search and rescue training and implementation. 

### 4. Washoe County DesertTraining Center -This location is an isolated part of Northern Nevada in Washoe County. The operations area is 10 miles square and 10 miles from the nearest establishment. Operations will be conducted from Black Rock Airport (3,904' MSL), which is a private airstrip that has no structures in the middle ofthe Black Rock Playa. The purpose of location is to provide UAS emergency service training to law enforcement in the Northern Nevada and medical relief exercises. The operations area underlies the Reno Military Operation Area (MOA). The Reno MOA's floor is 13,000' MSL. Emergency operations training will not exceed 4,500' MSL and will be conducted in day light hours under VFR conditions. De-confliction ofthe airspace does not present a problem since the DAx8 power supply will be depleted priorto UA reaching altitudes of 13,000'; therefore this alleviates potential cause of hazardous situations. 

### 5. Washoe County Urban Training Center- Is an area that will demonstrate UAS capabilities in and around vacant structures. Emergency services will train with several environmental sensors to detect air quality, IRand heat imagery sensors to assess safe conditions prior to entering a structure. The area is sparely populated and does not pose a hazard to persons or airtraffic. Operations are low level flight around the vacant structures for emergency training and urban assessment. 

### 9. AIRPORT OPERATIONS: Airport operations have been described in Section 8 under Operations Area Reno/Stead Airport and Washoe County DesertTraining Center. The airports selected for operations have been either deemed as a UAS test site and Black Rock City Airport is a private field in which authorization has been sought and approved for UAS emergencytrainingexercises. Black Rock CityAirport isjusta dirtstrip runway and does not have any structures oraircraft parked on the ramp. All safety mitigations have been taken into consideration, including radio communications and lost link procedures.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 37Drone America, Inc. Federal Aviation Regulations for Exemption 

### 10. VISUAL LINE OF SIGHT (VLOS): The DAx8 will remain within visual line ofsight (VLOS) bythe use ofobservers. Through two-waycommunicationswiththe operator, observes shall provide critical information pertainingtoflight safety, obstructions and airspace encroachment. Observers will also clearthe area of people to keep asafe perimeterofoperations. 

### 11. DAX8 PREFLIGHT: i. The preflight process of Drone America's DAx8 consists of: • Preflight check ofthe DAx8 • Preflight check ofthe Portable Ground Control Station (GCS) All preflight processes for the UA and portable GCS, as well as all other flight critical equipment requires the use ofchecklists. The technicians are responsible for performing the preflight inspection of the UA, which will include checking ofall eight electric motors, the battery system, electrical systems and physical inspection ofthe airframe. The technicians will recharge the batteries and assure that backup batteries are available and ready for replacement. All defects and repairs are noted in the UA maintenance logbook and signed off by the certified technician. The technicians shall also perform weight and balance checks for the UA at empty weight and takeoff weight to ensure proper center ofgravity calculation for each UA payload configuration. Upon receiving the UA from the crew chief, the AVO will review the UA logbook and sign off to receive all maintenance items and the weight and balance, as well as reviewing the airframe, electric motors and autopilot total flight time. The AVO will then perform a final walk-around to visually inspect the UA, and remove any safety pins/flags from the UA in preparation for flight. The AVO shall also perform the preflight ofthe portable GCS using associated checklists to ensure the GCS is programmed for flight. This preflight process consists of procedural inspections ofthe ground data terminal (GDT), antennas and cabling and all electrical connectors. GCS preflight includes system power up ofthe Tough Pad screens, and verify payload control and communication panel. The AVO shall perform communication checks for all radio equipment, as well as, crew radio squawk checks. The AVO must cycle the speed controller throttle and respective autopilot flight controls to verify control accuracy and operations ofTough Pad systems. As part ofthe GCS preflight, the ground station software and the UA software are updated to the latestversion approved forflight operations.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 38Drone America, Inc. Federal Aviation Regulations for Exemption



### ii. System criteria require system preparation for flight that includes software, electrical systems, control systems and electric motors. Each system is required to be checked and tested prior to every mission during the preflight operation. As part ofthe startup checklist, the AVO will verify thatthe GCS and autopilot software are updated tothe correct and approved version.

Preflight ofelectrical systems includes: • Aircraft batteries are fully charged • Verify the onboard power management units (PMU) are powered up and regulated to the correct voltage- 14.8V • Ensure power is on and connected to the portable GCS main and USB transmitter /receiver • Check backup batteries are charged/charging • The inverters are turned on and have correct voltage output Control systems preflight includes: • AVO verifies flight autopilot and speed controls are operational • Verification ofthrottle control is responsive • The AVO will also perform an Inertial Navigation System (INS) check to verify that pitch, yaw and roll gyros/accelerometers are oriented correctly • Verify electric motors are functioning normally
• Verify electric motors are responsive in correlation with the portable GCS interface Preflight Safety Check/Walk-Around Inspection: Preflight Safety Checklist shall be performed by trained ground personnel to inspect the UAS prior to each flight utilizing the checklist referenced below.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 39Drone America, Inc. Federal Aviation Regulations for Exemption 

## iii. Walk-Around Inspection: Inspect all 8 motorsforsecurity 

### 2. Inspect all 8 Propellers for cracks, chips and 

### 1. delamination's and screws forsecurity 

### 3. Inspect all 8 motorarmsforsecurity 4. LED Navigation Light Inspection 

### 5. Fuselage Inspection for abrasions, cracking or 

### 6. Antenna Inspections: delamination's GPS, Transponder/Receiver 7. Lower hatch secure 8. Camera Inspection and Cleaning

DAxB Top View

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 40Drone America, Inc. Federal Aviation Regulations for Exemption

ILLUSTRATION2 - DAX8SIDE VIEW 

### iv. Preflight Checklist:

1. Verify system is off 2. Verify motors are secure (Check by twisting, pushing/pulling) 3. Verify speed controllers cables are connected tothe bus barforall 8 motors 4. Inspect all wiresfor cuts orabrasions 5. Inspect propellersfor nicks or cracks 6. Inspect motorsfor smoothness ofoperation and cleanliness
ELECTRIC MOTOR PREFLIGHTSAFETYCHECKLIST

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations Tech lnt./Stamp

41Drone America, Inc. Federal Aviation Regulations for Exemption Battery System Preflight Checklist:

Aircraft S/N: 

### 1. Verify proper batteries are installed 

### (USE ONLY MANUFACTURER RECOMMENDED BATTERIES) 

### 2. Verify batteries are secure 

### 3. Verify batteries are charged 4. Verify backup batteries are charged and on standby BATTERYPREFLIGHTCHECKLIST Avionics Preflight Checklist:
Flight Operation: Date: Aircraft S/N:

1. Inspect avionics compartmentfor debris 2. Inspect bus harness connections 3. Verify avionics are secure and properly mounted 4. Verify analog connectors are connected and inspectfor damage 5. Verify powercable is connected and inspectfor damage 6. Inspect GPS antenna and verify connection
AVIONICS SAFETYCHECKLIST

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations Tech lnt./Stamp

Tech lnt./Stamp

42Drone America, Inc. Federal Aviation Regulations for Exemption Airframe Preflight Checklist:

Aircraft S/N: N-Number: Date: 

### 1. Verifyfuselage serial number 2. Turn powerON 3. Inspectfuselage for defects 4. Inspect navigation lights 6. Inspecttransponder/transponderantenna and verify connection (ifinstalled) 7. Inspect sensor/payload fordamage 8. Remove camera cover and clean lenses AIRFRAME PREFLIGHTCHECKLIST 

### v. Center ofGravity Preflight Checklist: Tech lnt./Stamp



### Due to the configuration ofthe DAx8, CG is fixed within a small range in the center of its circular perimeter. Weight is the only driving factor in stability. The DAx8 is designed to fly at a max weight notto exceed 85% of its maximum thrust. The thrust outputfor the DAx8 is expected to be a maximum of 13.5kg, or 29.75lbs at sea level. This yields a maximum possible takeoffweight of roughly 25 lbs. Depending upon the location and base elevation this weight will decrease. 

### It is up to the AVO to calculate the approximate density altitude and determine the maximum takeoffweight for a given situation based upon weather and location. These statistics are subjectto change during testing, and upon completion offlight trials, a detailed weight table will be presented as a guideline for safe operations.

Prepared by: Max weight: COMPONENTS: Payload Aux. Payloads USEFUL LOAD REMAINING

Drone America, Inc. 2015 Empty weight: WEIGHT /LBS.

WEIGHTAND BALANCESHEET Section 333 Exemption for UAS Operations 43DroneAmerica, Inc. Federal Aviation Regulations for Exemption 

### 12. 

### PURPOSE FOR UAS EXEMPTION: The purpose for exemption is to enhance the situational awareness capabilities of emergency service agencies and first responders by employing unmanned aircraft systems (UAS), with high-resolution sensing and imaging capabilities for disaster remediation. Emergency service agencies and first responders face significant challenges during an emergency event such as, a natural or anthropogenic disaster (earthquake, tsunami, fire, hurricane, tornado, floods, power or nuclear accident, act ofwar, orterror). One ofthe major challenges is acting decisively based on available information with consideration of human factors. In addition to, providing high-quality real-time situational awareness that is critical to effectively manage and safeguard civilians and field personnel. This project focuses on creating a smart emergency-response service system utilizing UA and ground-based systems. These systems are equipped with state ofthe art imaging, sensing and communications to provide first responders with high-quality, real time information to act decisively and effectively via human machine interactions. 

### The objectives include: (1) Develop and integrate UAS platforms, sensors, imaging, communication systems and control and path planning algorithms to create a UAS based smart service system forfirst response. (2) Model the state of human and structural infrastructure during and/or post a disaster that identifies the scene, and creates mapping access paths to safety. (3) Test prototypes and pursue commercialization opportunities. (4) Educate the public and train first responders on the technology. 

### 13. 

### CERTIFICATE OF AUTHORIZATION - COA: A certificate ofAuthorization is currently pending approval through the Reno Regional Emergency Operations Center. The COA identifies Platform, Performance and Procedures, in which are identified within this request for relief ofexemption.

Drone America, Inc. 2015 Section 333 Exemption for UAS Operations 44Drone America, Inc. Federal Aviation Regulations for Exemption



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