DRONE AMERICA 

January 12, 2015 

Docket Management Facility US Department of Transportation 

1200 New Jersey Avenue, SE West 

Building Ground Floor Room W12-140 

Washington DC 20590-0001 

RE: Section 333 Petition for Exemption 

Dear FAA: 

Drone America, Inc. petitions for relief of specific regulations with regards to airworthiness certification 

under Section 333, 14 CFR 11.81. The proposed request for exemption would allow for the 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 necessary for unmanned aircraft 

operations. Drone America request that the FAA approve an exemption based on a specific 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, Chapter 5, 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 integration to support firefighting, disaster relief, 

search and rescue, law enforcement, crew training and to participate in research of various National 

Aeronautics and Space Administration {NASA) and National Oceanic and Atmospheric Administration 

{NOAA) environmental studies. In the interest of public safety and research, to date the FAA has already 

authorized emergency service agencies limited use of unmanned aircraft for critical 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 of issuance for 

an Emergency COA exemption is: 

• An emergency situation that is defined as a condition of distress or urgency; or 

• The proposed Unmanned Aircraft is operating under a current approved COA for a different 

purpose or location. 

OR; 

For non-emergency COA's is to request exemptions that fall outside of these parameters be considered for: 

• Crew training 

• Flights to test sensor capabilities 

• Flights over congested areas 

• Flights in Class C airspace 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 1 
The platform in consideration for Section 333 Exemption is the DAx8. This platform is an eight-blade 

rotorcraft designed to assess and evaluate critical situations prior to releasing emergency response 

teams into hazardous conditions. Other capabilities of the DAx8 are ISR/IR applications for search 

and rescue operations that provide lightweight mobility and the ability for rapid deployment in life 

threatening situations. 

Sincerely, 

__,a-c"vu.... v~·-~ --· v ~ 

Scott Lether - Operations Manager 

Drone America, Inc. 

3555 Airway Drive Suite 310 

Reno, NV 89511 

775-473-9998 1 775-624-3416 

www.DroneAmerica.com 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 

DAxB 

2 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

SECTION 333 PETITION FOR EXEMPTION 

Drone America request relief from the following regulations in part or whole thereof: 

PART 21 THAT DESCRIBES PROCEDURAL REQUIREMENTS FOR THE COMPLIANCE OF: 

• Subpart G; Production Certificates 

• Subpart H; Airworthiness Certificates 

• Subpart I; Provisional Airworthiness Certificates 

• Subpart K; Parts Manufacturer Approval 

• Subpart L; Export Airworthiness Approvals 

• Subpart N; Acceptance of Aircraft Engines, Propellers and articles for Import 

• Subpart 0; Technical Standard Order Approvals 

PART 45 THAT REQUIRES IDENTIFICATION AND REGISTRATION MARKINGS: 

Due to platform size and airframe configuration, 2" regulation markings will not fit 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 of the platform. 

The DAx8 is an unmanned aircraft and cannot meet the requirements for display of 

markings of this 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 of an aircraft that is 

carrying passenger or property for 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 to that business or employment; and 

2) The aircraft does not carry passengers or property for compensation or 

hire. 

Drone America's request for relief of requiring a private pilots license and limitations is 

that the aircraft size, weight, speed and limiting operational range are contributing 

factors for that do not necessarily require a private pilots license to operate. The UA 

weighs less than 20 lbs. and does not exceed a maximum speed of 28 mph. The 

aircraft will be operated within a horizontal visual line of sight (VLOS) from the surface 

not to exceed 400 feet AGL. Operations are conducted from a handheld tablet 

through touch commands and waypoints with auto takeoff and 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 1 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

PART 91.7 CIVIL AIRCRAFT AIRWORTHINESS: 

a) No person may operate a civil aircraft unless it is in airworthy condition. 

b) The pilot in command of a 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 aircraft vehicle operators (AVO's) are responsible for the 

inspection and safe operation of the aircraft. Aircraft will be inspected prior to 

each flight and maintenance performed as necessary to ensure flight safety. 

Should the condition of safe 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 aircraft without 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 of the county of registry. 

Request for relief is that the DAx8 is not capable of complying with Part 91.9, 

however, a flight manual with operating limitations and placards will be 

immediately accessible to the 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 of the 

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 relief for exemption of Part 91.203 in whole that the 

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 LOCATOR TRANSMITTERS: 

Drone America, Inc. 2015 

a) Except as provided in paragraphs (e) and (f) of this section, no person 

may operate a U.S. registered civil airplane unless -

Section 333 Exemption for UAS Operations 2 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

1) There is attached to the airplane an approved automatic type 

emergency locator transmitter that is in operable condition for 

the following operations, except that after June 21, 1995, an 

emergency locator transmitter that 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. In the event flight is non-recoverable the 

ballistic parachute is deployed and the operator may retrieve the aircraft if lost 

by listening for the alarm. 

PART 91.405 MAINTENANCE REQUIRED: 

Each owner or operator of an aircraft: 

a) 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. 

Drone America requests for relief of exemption of Part 91.405 (a) in part on the basis 

of the size, weight, speed and limited range of this unmanned aircraft. 

Drone America's aircraft vehicle operators (AVO's) will be responsible for the inspection 

and safe operation of the aircraft. The aircraft will be inspected prior to each flight 

and maintenance performed as necessary to ensure flight safety. If the condition 

cannot be resolved or repaired the flight will be terminated until discrepancies are 

corrected. 

PART 91.407 OPERATION AFTER MAINTENANCE, PREVENTIVE MAINTENANCE, 

REBUILDING, OR ALTERATION: 

a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless -

1) It has been approved for return to service by a person authorized under 

43.7 of this chapter; and 

Drone America requests for relief of exemption of Part 91.407 (1) in part on 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 calendar 

months2) It has had an inspection for the issuance of an airworthiness 

certificate in accordance with Part 21 of this chapter. 

Inspections and preventive maintenance is performed prior to each flight, therefore, 

Drone America requests for relief of exemption of Part 91.409 (a)(2). 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 3 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

PART 91.417 MAINTENANCE RECORDS: 

a) Each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 

Drone America, Inc. 2015 

1) Records of the maintenance, preventive maintenance, and alteration 

and records of the 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 of an aircraft. The records must include: 

i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

ii) The date of completion of the work performed; and 

iii) The signature, and certificate number of the person 

approving the aircraft for return to service. 

2) Records containing the following information: 

i) The total time in service of the airframe, each engine, 

each propeller and each rotor. 

ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor and appliance. 

iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a 

specified time basis. 

iv) The current inspection status of the aircraft, including the 

time since the last inspection required by the inspection 

program under which the aircraft and its appliances are 

maintained. 

v) The current status of applicable airworthiness directives 

(AD) and safety directives including, for each, the 

method of compliance, the AD or safety directive number 

and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action 

is required. 

vi) Copies of the forms prescribed by 43.9(d) of this 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) of this section shall be 

retained until the work is repeated or superseded by other work, 

or for 1 year after the work is performed. 

Section 333 Exemption for UAS Operations 4 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft 

is sold. 

3) A list of defects furnished to a registered owner, or operator 

under 43.11 of this 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 of a licensed aircraft mechanic to perform maintenance. The Aircraft Maintenance Manual 

(AMM) predicates the scope of maintenance to be performed by the AVO prior to each flight 

followed by a post flight inspection. The maintenance manual is a separately controlled document 

that describes and compiles the scope of detail and maintenance procedures recommended by the 

manufacture, Drone America, Inc. This program is developed to identify the 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 of safe 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 to that 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 by the aircraft 

manufacturer. The manufacturer's checklists and the Aircraft Maintenance Manual define 

inspection schedules and scope of details. 

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 of operations. 

The inspection program prescribed is to be performed by a person who is an authorized 

manufacture's technician. The authorized technician is required to inspect the aircraft, document 

the findings 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 5 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

UMANNANED AIRCRAFT SYSTEM OPERATIONS 

1. OPERATIONAL AND 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 to the system. The advance software and 

GPS guidance system provide the aircraft with 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 of the aircraft and electric motor 

analysis demonstrates that the airframe is capable of a thrust range of 19.9 to 

29.2 pounds of thrust. Through indoor flight testing the DAx8 will be evaluated in 

various flight maneuvers, and is not capable of fluttering throughout the flight 

envelope due to the lack of moving parts. 

Throughout flight test 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 per the resin manufacturer. 

Work is performed in accordance with AC 20-107B as guidance and in compliance 

with 14 CFR Part 23. 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 6 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

UAS Preflight Operations: 

Preflight planning is a multi-task process requiring weather briefing, mission planning, preflight safety 

checklist, and UAS walk-around inspections. 

Weather Briefings: 

Weather briefings may be obtained through various sources: 

• Flight Service Station (FSS) 

• Telephone Information Broadcast System (TIBS) 

• Transcribed Weather Broadcast System (TWEBS) 

• Direct User Access Terminal System (DUATS) 

Weather analysis must be recorded prior to each flight and logged on the following weather analysis 

tables denoting current and forecasted conditions within the time of the 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 for the development and the outcome of the operation. 

The initial scope of preflight planning objectives will be developed as part of the 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 establishes the objective of the 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 Manager to resolve the problem/s. 

At the time the Mission Commander is assigned the responsibility of the operation, he becomes the point of 

contact for all mission-related issues. The Mission Commander must discuss mission objectives, weather and 

address any requests in regards to the mission. The Mission Commander must keep record of all 

correspondence and documentation pertaining to the test operations. 

The Mission Commander must brief all personnel before the commencement of the test operations 

and allocate duties at this time. The briefing should take place before departure if operations are at a 

remote site. 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 7 
Drone 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 (if any) 

• Emergency procedures 

• Currency and training requirements 

• Flight Planning 

Flight planning shall be the responsibility of the 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 

of the operation. 

Payloads: 

The DAx8 payload is client specific and the DAx8 is capable of carrying a wide range of payloads 

weighing up to 4.4 pounds, including stabilized EO/IR gimbal, multi-spectral sensors, geo-imaging 

payload, etc. 

Due to the nature of UAS operations with a wide range of payloads, all internal and external 

payloads require the UA to have weight and balance calculation prior to every flight. The payload 

compartment is located in the center of the aircraft, directly over the desired CG, making this task 

straightforward. 

Flight: 

All commands during flight operations are directed and changed via the GCS software controls 

interface in real-time. 

i. During flight, the AVO monitors telemetry data and makes appropriate changes in altitude, 

speed, heading and waypoints using keyboard/touch screen inputs and/or mouse point and 

click commands. Additionally, the AVO can also control the UA using a stylus for point and 

touch to control the UA's direction. 

ii. The systems required for normal flight operations include the GCS, the ground side data link 

and associated antennas, the autopilot and 3D GPS, static air pressure sensor, and air data 

link. 

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Section 333 Exemption for UAS Operations 8 
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Federal Aviation Regulations for Exemption 

iii. Critical process points include: 

• Adequate number of GPS 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 the GCS 

• Batteries are fully charged prior to takeoff 

• 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 by the flight mode switch on the AVO Hand Held 

Controller, or by selecting the flight mode in the ground station user interface. The 

flight control modes available depend upon the hardware installed. The following 

three options for flight modes are available: 

1. Manual- Direct control via RC controller 

2. Attitude mode- Autopilot self-levels the aircraft, while still being guided by the 

AVO 

3. Autonomous- Fully controlled via the autopilot and uploaded waypoint set 

b. The control panel screen will display the control mode of the UA. 

c. In-Flight Plan Deviations: 

In-flight deviations are made through the autopilot system. The course is quickly 

changed through the Command Loops screen by setting a new waypoint and 

commanding the UAV to track to the new course. The autopilot will ask the AVO to 

confirm this command prior to making the deviation. The flight plan may also be 

changed through the EFIS by sliding, or clicking on the altitude, airspeed and heading 

bugs to set a new course. These methods also require a confirmation by the AVO prior 

to execution of the command. 

d. Lost Communications: 

Drone America, Inc. 2015 

A VHF communication radio allows for a communication link to ATC or the controlling 

agency. Additionally, there are also handheld air band radios in case of lost 

communication to ATC or controlling agency. If communication is lost with ATC, or the 

controlling agency the UA will maintain last flight plan, or return to base via predetermined/pre-planned routes until communication with ATC, or the controlling 

agency is re-established. 

Section 333 Exemption for UAS Operations 9 
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Federal Aviation Regulations for Exemption 

4. Landing and Recovery: 

Landing is performed in the same way as takeoff or launching in a hovered 

configuration. 

5. Post Flight: 

a. Systems required for safe post flight operations include aircraft retrieval, aircraft shut 

down, proprietary equipment properly stored and the aircraft secured. 

i. After each flight the UA will be plugged in so that its on board telemetry data 

can be downloaded and a visual inspection can be performed. 

ii. During post flight, prior to power off, the data from the autopilot must be 

downloaded for future replay in software in loop simulation. 

iii. Post flight inspection 

• Inspect for visible damage from hard landings/debris ingestion into 

propellers (bugs, rocks, sand etc). 

• Inspect all exposed fasteners and screws for security. 

• Inspect camera/payload/sensor for any damage. 

• Inspect batteries and wiring for excess heat generation which may 

suggest a pending failure. 

• Inspect all antennae and exposed equipment to ensure they are free 

of damage. 

b. Post flight inspection happens after the electric motors are shut down and the DAx8 

power is OFF. The Crew Chief will conduct a visual walk around inspection of the 

aircraft and connect the data terminal cable from the GCS to the aircraft to download 

the flight telemetry. 

6. Operating History: 

Currently the DAx8 is in production with a projected rollout in early December 

2014. Initial test flights have been conducted indoors at Drone America's 

production facility. Initial gain tuning has been completed and stable flight has 

been demonstrated. Initial flight testing will be performed in an indoor arena. 

Flight testing will continue indoors until authorization is approved for outdoor 

testing. 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 10 
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Federal Aviation Regulations for Exemption 

2. Maintenance, Inspection and Repairs: 

Refer to page 7 for the description of the 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 

Conditions for Return to Service 76 Original 17Sept2014 

2 UAS Aircraft Data 77 Original 17Sept2014 

3 Owner/Operator Attitude 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 Miscellaneous Airframe 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 Battery Systems 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 Weight and Balance Sheet 87 Original 17Sept2014 

22 Airworthiness Directive Sheet 88 Original 17Sept2014 

Appendix A 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 

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Section 333 Exemption for UAS Operations 11 
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Federal Aviation Regulations for Exemption 

REVISION PAGE CONTROL SHEET 

Removed Effected Page Date Inserted Effected Page Date Pages Description Pages Description 

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Section 333 Exemption for UAS Operations 12 
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Federal Aviation Regulations for Exemption 

Progressive Inspection Checklist 

Current date of issue: September 16, 2014 

Reference Data: 

FAA Order 8130.34C, 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. 

Conditions for Return to Service 

1) The unmanned aircraft system (UAS) must be returned to service in condition for 

safe operation. Inspection is to ensure that the aircraft is not subject to unusual 

wear, structural damage and/or system malfunctions. 

2) Aircraft configuration and components installed must be consistent with 

manufacturer's drawings, specifications and other data that are part of the 

equipment list. 

NOTE: 

NOTE: 

If either of these conditions are not met, the unmanned aircraft would not be 

considered safe for operation and cannot be returned to service. 

This is a manufactures reference guide for a Progressive Condition inspection 

checklist specific to Drone America's experimental Unmanned Aircraft. This 

checklist has not been approved by the FAA at the time of publishing this original 

document. Reference to the manufacturer's maintenance manual is not 

exhaustive and consideration to CFR 43 Appendix D should be consulted. 

Inspection checklists are updated periodically and personnel performing safety 

inspections should reference www.droneamerica.com maintenance for update 

revisions prior to inspections. 

The owner/operator is responsible for maintaining the UAS in a safe condition, including 

compliance with all manufacturer's directives and operating limitations. The owner/operator is 

also responsible for the inspection of the UAS system to insure that the aircraft is in compliance 

with CFR 23 Airworthiness Standards, and CFR 43 Aircraft Maintenance. 

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Section 333 Exemption for UAS Operations 13 
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Federal Aviation Regulations for Exemption 

UAS Aircraft Data: 

UAS Model:--------

N-Number: ________ _ 

Serial Number: _______ _ 

Year: ---

Owner/Operator Attitude: 

Does Owner/Operator have a constructive attitude toward Compliance? 

Order 2150.3A Par. 205 Yes D No D N/ AD 

Verify Maintenance Technicians 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. Instructions for 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 

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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: ---

14 
Drone 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 Maintenance Technician# _______ _ 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 if applicable 

CFR 91.417 

Yes D NoD N/AD 

5. Verify status of life limited parts. Go to: www.droneamerica.com maintenance for Effective 

Date: ___ _ 

CFR 43.10 

6. Verify current Aircraft Flight Manual (AFM) is available 

CFR 91.9 

7. Verify current weight and balance sheets are available 

Verify signature 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. Verify ATC Transponder/w ADS-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 per CFR 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 

15 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

12. Verify autopilot-pitot/static system has been tested within the 

Past 24 calendar months per CFR 43 Appendix F 

13. Record deferred items per Part 91 for daytime VFR 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 lower airframe hatches 

b. Remove optical payloads 

c. LOCK OUT- Install 1fT" pin in ballistic recovery parachute 

General Cleanliness: 

1. Wash/Clean exterior of aircraft 

2. Clean aircraft interior 

3. Clean all motors and propellers 

Portable Ground Control Station Inspection: 

1. Verify placards are correct and readable per the AFM. 

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. Verify current equipment list. 

c. Verify maintenance records entries are updated. 

d. Verify Weight 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 

16 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

3. Verify compass is correct in the primary flight display as shown in 

Electronic Flight Instrument System (EFIS). Yes 0 No 0 N/AO 

4. Verify clock is set to the correct time 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. Verify Transponder Part Number: 

a. P/N 

7. Verify there are no unusual odors (Such burning electrical smells). 

8. Verify Portable Ground Control Station registration concurs with 

Data plate. 

9. Verify fire extinguisher is charged, properly rated and accessible. 

10. Verify speed controllers are operational. 

11. Verify throttle travel is not restrictive and consistent with RPM, 

figures (If applicable) 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, back to 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. Verify there are NO loose electrical connections. 

15. Verify electrical wires are secure. 

16. Instruments: Airware Autopilot System 

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 per Airware Systems. Yes 0 No D N/ AD 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 17 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

d. Verify the operations of the following flight instruments 

have been inspected per Airware's inspection program: 

1. Airspeed Indicator 

2. Altimeter 

Aircraft Electrical System: 

1. Verify condition of aircraft switch. 

Yes D NoD N/AD 

Yes D NoD N/AD 

Yes D NoD N/AD 

2. Verify voltage 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 or frayed 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 or exposed wires Yes D NoD N/AD 

e. Evidence of overheating Yes D NoD N/AD 

f. Evidence of arcing Yes D NoD N/AD 

g. Evidence of chemical contamination Yes D NoD N/AD 

4. Verify aircraft wires are properly labeled. Yes D NoD N/AD 

5. Verify aircraft wires are marked by gage size. Yes D NoD N/AD 

6. Inspect bus bar for burned or tripped conditions. Yes D NoD N/AD 

7. Verify grounding point nuts are tight and free of corrosion. Yes D NoD N/AD 

8. Verify wires are properly clamped and secure. Yes D NoD N/AD 

Aircraft Equipment/Furnishings: 

1. Verify installed equipment functions 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 properly secured. Yes D NoD N/AD 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 18 
Drone 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 autopilot for security and no adverse conditions. Yes D NoD N/AD 

Miscellaneous Airframe Inspection: 

1. Verify antenna connections. 

2. Inspect for corrosion on, or around antenna connections. 

3. Inspect hatch seals for cleanliness, cuts, or abrasions. 

4. Inspect lower hatch fastener blind nuts and hardware. 

Aircraft Exterior Inspection: 

1. Inspect airframe for delamination, pin holes, cracks, 

blisters and chipped paint. See manufactures AMM for 

acceptable limits. 

2. Inspect registration markings. (Replace or repair if required) 

CFR 45.22(b) 

3. Inspect beacon. 

4. Inspect condition of navigation lights. 

Landing Gear Inspection: 

1. Lift aircraft and turn over to inspect landing gear 

for bent, fatigued or cracked struts. 

2. Inspect for overweight 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 

19 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

Electric Motor Inspection: 

1. Perform a motor inspection by visually checking for debris 

in the windings or bearings. Physically turn the propellers 

to ensure smoothness of operation. Yes D No D N/ AD 

CFR 43.15 

2. Inspect motor control arms for cracks or delamination's. Yes D NoD N/AD 

3. Inspect condition of motor wires. Yes D NoD N/AD 

4. Inspect overall condition of motors Yes D NoD N/AD 

Battery Systems: 

1. Inspect condition of battery cells. 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 

propeller should alternate from CW to CCW to CW as inspected in a clockwise fashion around the 

perimeter of the DAx8. Each propeller should be inspected as follows: 

1. Verify correct propeller rotation direction and orientation (thrust direction) 

2. Inspect propellers for physical signs of damage or abuse 

3. Check that propeller bolts are tight 

Propeller type: Fixed 

Propeller Material: Composite 

1. Is the propeller maintenance record logbook available? Yes D NoD N/AD 

2. If there is no propeller maintenance logbook, sign 

inspection off in 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 

20 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

4. In the event of propeller damage, remove and replace propeller. Yes D NoD N/AD 

Special Inspection: In the event of propeller damage, 

DO NOT attempt to repair. 

5. Verify proper propeller screws are used per manufacturer's 

recommendations. 

Ground Control Station Equipment/Furnishings: 

1. Panasonic Tough Pad 

2. COMMS 1 & 2- Garmin/GTR 225 

3. Airware Autopilot Systems 

4. Sage Tech XPS-TR ModeS with ADS-BOut Transponder 

5. Video Receiver6. Video and Voice Recorder7. Ground Data Terminal GDT 2100- TECOM Industries. 

8. Spectrum Analyzer9. Range Attenuator10. 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. Verify Aircraft Flight Manual (AFM) is applicable to 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 

21 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

Special Inspections: 

Occurrence 

1. Structural Damage Inspection: 

Visible damage to the skin of the DAx8 less than a 

quarter of an inch in diameter is not considered 

structural damage. Damage exceeding more than a 

quarter of an inch in diameter, consult the AMM for 

engineered fix. If aircraft has experience hail 

damage, consult engineering prior flight. 

The structural components which could be 

damaged are within the central compartment of the 

DAx8, and must be inspected each landing for signs 

of cracking and wear. Any damage in the landing 

gear or motor arm mounting areas is considered out 

of limits of safe 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 structure for structural 

cracks, delamination or splintering around 

gear attach points. 

Ill. Inspect each gear strut to ensure they are 

not bent, or cracked 

IV. If struts are bent, elongated bolts holes or 

cracked, Remove and Replace. 

3. Overweight landings. 

the DAx8 cannot land overweight as its 

weight does not change during flight. 

Maximum takeoff weight 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 

22 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

4. Lightning strike damage. (Airframe & Electronics Inspection) Upon landing 

In the event of lightning strike damage, inspect structure 

for burns, blisters and delamination. Consult the AMM 

for structural repairs. All electronics must be returned to 

Drone America for inspection. 

5. Severe turbulence inspection. 

The DAx8 is not intended to fly in areas of severe 

turbulence. Its configuration however is not typically 

susceptible to overload due to turbulence. Controllability 

may be affected, but structural damage is highly unlikely. 

Condition of Inspection Statement: 

No person may sign-off any repair, alteration, or modification to this aircraft unless they are a 

qualified mechanic that has been authorized by the manufacture as a Maintenance Technician. 

The Maintenance Technician must provide a statement of release prior to returning the aircraft to 

service. 

I certify that this aircraft has been inspected on 20 __ in accordance with the scope 

and detail of 14 CFR 43, Appendix D and Drone America's Aircraft Maintenance Manual {AMM), 

and have found to be in a condition for safe operation in compliance with FAA's acceptable 

maintenance and 100-Hour Inspection Program. 

Aircraft total time: __ _ 

A & P: _________ _ 

Print 

-----------Lie.# _________ _ 

Signature 

Maintenance Technician: _________ _ 

Print 

_________ Auth. # ______ _ 

Signature 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 23 
Drone 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 24 
Drone 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, potentially video 

downlink for the DAx8. The Microhard 2.4Ghz Nano series n2420 will be used. Spectrum 

approval is not needed as 2.4Ghz is open to the public under FCC Part 15.247, IC RSS210, 

CE. 

b. The Microhard Nano series radio is not encrypted as standard, but has the ability to 

support both 128bit and 256bit AES encryption in the USA, and with permit for 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 intended to operate at a distance greater than 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 25 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

3. Design characteristics and procedures to 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 of RF 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 not expected to operate farther than 3 miles from 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 motor termination 

and deployment of the parachute, and/or aerodynamic termination if required. 

f. Atmospheric attenuation including precipitation condition may cause degradation of the 

communication link quality. Careful flight planning must be performed while taking into 

account for atmospheric conditions that may decrease operational range. 

4. Pilot/Crew Qualifications/Training Reference: 

1. Drone America's Flight Training 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, Appendix A. 

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. Pilot Training: 

Each UA pilot applicant currently holding an FAA pilot certificate and fulfills Drone 

America's training requirements, will receive upon completion of satisfactorily 

passing the Practical Test Standards, a Certificate that qualifies him or her as a UA 

pilot. 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 26 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

b. Formal Pilot Curriculum: 

A training curriculum has been developed that follows the Flight Training Syllabus and 

instructed by a licensed FAA Flight instructor to maintain proficiencies for all UA 

pilots. 

c. Observers: 

i. Pilot Certificate- Typically observers will not be required to hold a pilot 

certificate. However, observer applicants are required to attend and 

satisfactorily pass the practical test. Refer to Drone America's 3-day Observer 

training course on page 65. Pilots who have observer training may have to hold 

an observer position at times when not acting as an AVO or PIC. 

ii. Medical Certificate- Observers are required to hold a Class 2 medical prior to 

acceptance into the Observer Training Program and to meet compliance with 

8130.34C, Appendix A; and Drone America's policies. 

iii. See and Avoid -Observers will be trained and familiar with Far Part 91 and tested 

to be in compliance with see and avoid procedures, cloud clearances and right of 

way rules. 

iv. Training Curriculum- Observer training 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 familiar with 

the appropriate sections of the Aeronautical Information Manual. Applicant 

qualifications require an individual to have 20/20 vision, speak, read and write 

English and demonstrate the ability of position awareness. 

As referenced Observer Training is a 3 day course, in which applicants shall be 

trained in the following techniques to identify and avoid potential ground and 

airborne hazards: 

v. Observer Training- As described in sub-section (iv) all observers must pass the 

curriculum testing to be a qualified observer. 

d. Observer Knowledge and Understanding: 

The observer shall be knowledgeable and have understanding in: 

i. Proper communication and phraseology 

ii. Proper visual scan techniques 

iii. Standard flight operations at non-towered airports 

iv. Containment areas and how to determine UA range within the operating area 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 27 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

5. Pilot Type Ratings and Medical Standards: 

The chief pilot/instructor is qualified to fly DAx8 per FAR Part 61 and in accordance 

with 8130.34C Appendix A. 

Additionally qualified pilots: 

Multi Engine, CFII, 16,790 700 1st Class 

ATP,ADP 

Private 478 10 2nd Class 

Private 51 1878 Pending 

Total Time: 17,319 2583 

Pilot Certifications, Flight Experience and Medicals 

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 of the flight configuration file for each 

airframe. This includes all of the data such as IMU orientation, ESC calibration, airframe 

weight and CG location relative to the IMU. These parameters are configured per airframe 

type. The autopilot configuration, including gains and all the flight parameters, can be 

copied to multiple vehicles with the exact same setup. In testing, it has been verified that 

the autopilot is robust to small changes in vehicle weight and balance, but it still needs to be 

quantify how large the changes need to be before it is necessary to re-tune the vehicle. 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 28 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

c. Flight: 

When performing the initial setup, it is necessary to know what PWM range the ESC's are 

calibrated to, and what PWM values correspond to min and max throttle parameters. 

These are entered as parameters into the Airware configuration utility. These values are 

not available for most off-the-shelf speed controllers; therefore, each ESC will have to be 

calibrated externally to the same known PWM range. 

The configuration files are stored in the Airware cloud. Once created, they are stored in the 

data base for easy access to new or existing vehicles as information is needed or 

required. Version control is provided on the Airware cloud. 

The Mapping Updates are derived from Terra Server Google and Bing. Map tiles are cached 

and gee-referenced automatically. For elevation data, we use SRTM (Shuttle Radar 

Topography Mission) data that can be downloaded from the USGS. All maps are updated in 

real time via the internet. 

Engine Start Ground Procedures for the 0Ax8 has a built in software algorithm for motor 

start. The flight controller must receive a signal from the ground control station in order to 

turn on the motors, which is executed by the AVO. This start and takeoff command requires 

a secondary confirmation from the AVO before being sent to the DAx8, thus preventing any 

chance of an accidental start. All ground personnel are cleared and required to stand back 

35 feet from the takeoff area prior to motor start. 

All commands during flight operations are directed and changed via the GCS software 

control interface in real-time. 

During flight, the AVO monitors telemetry data and makes appropriate changes in altitude, 

speed, heading and waypoints using keyboard/touch screen inputs and/or mouse point and 

click commands. Additionally, the AVO can also control the UA using a stylus for point and 

touch to control the UA's direction. 

The systems required for normal flight operations include the GCS, the ground side data link 

and associated antennas, the autopilot and 3D GPS, static air pressure sensor, and air data 

link. 

Critical process points include: 

• Adequate number of GPS satellites acquired to provide 30 solution 

• 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 29 
Drone America, Inc. 

Federal Aviation Re;gulations for Exemption 

• Batteries are fully charged prior to takeoff 

• 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 by the flight mode switch on the AVO Hand Held 

Controller, or by selecting the flight mode in the ground station user interface. The 

flight control modes available depend upon the hardware installed. The following 

three options for flight modes are available: 

1. Manual - Direct control via RC controller 

2. Attitude mode -Autopilot self-levels the aircraft, while still being guided by 

the AVO 

3. Autonomous - Fully controlled via the autopilot and uploaded waypoint set 

d. Flight envelope: 

Initial flight test will be done indoors within the production facility. Flight will 

continue indoors until authorization is approved for outdoor operations. Outdoor 

operations will consist of line sight not exceeding Visual Line of Sight (VLOS) and 

not to exceed 400' AGL. 

Operations will be performed in a safe manor and in accordance with 14 CFR Part 

61 and Part 91. All outdoor flights will be contained within a preplan ned flight 

envelope that is determined by the mission commander and approved by the 

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 of climb 500 ft./min 

Gross Weight 19.71bs. Max rate of descent 1,000 ft./min 

Empty Weight 8.01bs. Max Service Ceiling *3,000ft. 

Max Range (LOS) .88Mi Max angle of bank 40° 

Max Payload 4.41bs. 

* Prior to flight, the AVO can set altitude limitations from the Ground Control Station to 

prevent the UA from exceeding specified altitudes. 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 30 
Drone America, 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 within visual line of sight. These flight parameters present a minimal 

meteorological hazard to the operations and will not be operated in icing conditions. 

d. Safety Mitigations: 

Prior to flight it is the responsibility ofthe AVO, Mission Commander and the Flight 

Safety Officer to verify and monitor current and forecasted weather conditions. In the 

event the weather deteriorates, the flight will be terminated until adequate VFR 

conditions can be met per 14 CFR 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 1,200 feet above the surface but less than 10,000 

MSL 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 31 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

8. OPERATIONS AREA: 

The areas of operations are within Washoe County and the FAA approved Reno-Stead 

Airport UAS Test Site. Each of these areas range from rural unpopulated desert to sparely 

populated areas to demonstrate emergency service proof of concept. Each area is unique 

in that it provides different types of research and development, as well as, 

implementation of training various first responder teams in UA systems. The criteria for 

each area provides specific field training relative to local emergencies and disaster relief 

mitigation. The following areas are depicted in red boxes on the following charts: 

Drone America, Inc. 2015 

Reno-Stead Airport (UAS Nevada Test Site) 

Reno - Stead UAS Test 

500' Interior Buffer 

Reno-Stead Airport Coordinates 

Section 333 Exemption for UAS Operations 32 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

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

2 0 0.75 1.5 3 

I I 

Miles Nautical Miles 

Washoe County Emergency Operations Center and Homeland Security 

Training facility 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 33 
Drone 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 

Verdi Mountain Training Center 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 34 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

I I:::::J Black Rock. Desert; 100 sq. mi; 

2 

Miles 

a 0 

I 

11i 3 

I I 

Nautical Miles 

6 

I 

Washoe County Desert Training Center 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 35 
Drone America, Inc. 

Federal Aviation Regulations for Exemption 

San Francisco SEC 93 VFR map 

0 1.2§ 2.5 5 0 

I 

2 

I I 

Nautical Miles 

4 

I 

Washoe County Urban Training Center 

(Mock buildings for Fire Crew Training Center) 

Drone America, Inc. 2015 

Section 333 Exemption for UAS Operations 36 
Drone 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 outdoor flight testing is to be performed in Class G airspace within an FAA 

designated test area at Reno/Stead Airport. The test facility area is 812 acres 2.2 miles north of the main active 

runways 8/26. Runways 14/32 does have the capability to be closed by the airport authority during flight test 

operations. The airport authority will post an AWOS and a NOT AM notice broadcasting the date and times of 

Unmanned Aircraft testing and air operations for the Reno/Stead Airport. The Reno/Stead Airport is secured by 

perimeter fencing and therefore, restricts unauthorized activities of public access and/or events. The test area is in 

a remote location 1.8 miles northeast of a housing subdivision. 

2. Washoe County Emergency Operations Center and Homeland Security 

Training facility- The regional Emergency Operations Center (EOC) is a 72 acre training facility that 

provides disaster training for HAZMAT and environmental containment, and natural disaster remediation. 

The operation area is located 5 V2 miles northwest of the Reno/Tahoe International Airport under Class C 

airspace. The Class C airspace 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 of the 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 of a 

population center. The purpose for this location provides UAS search and rescue training and 

implementation. 

4. Washoe County Desert Training 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 of the 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 of the airspace does not present a problem since the DAx8 power supply 

will be depleted prior to 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, IR and 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 air traffic. 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 Desert Training 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 emergency training exercises. Black Rock City Airport is just a dirt strip runway and does not have any 

structures or aircraft parked on the ramp. All safety mitigations have been taken into consideration, 

including radio communications and lost link procedures. 

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10. VISUAL LINE OF SIGHT (VLOS): 

The DAx8 will remain within visual line of sight (VLOS) by the use of observers. 

Through two-way communications with the operator, observes shall provide critical 

information pertaining to flight safety, obstructions and airspace encroachment. 

Observers will also clear the area of people to keep a safe perimeter of operations. 

11. DAX8 PREFLIGHT: 

i. The preflight process of Drone America's DAx8 consists of: 

• Preflight check of the DAx8 

• Preflight check of the 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 of checklists. 

The technicians are responsible for performing the preflight inspection of the 

UA, which will include checking of all eight electric motors, the battery system, 

electrical systems and physical inspection of the 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 of gravity 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 of the portable GCS using associated 

checklists to ensure the GCS is programmed for flight. This preflight process 

consists of procedural inspections of the ground data terminal (GDT), antennas 

and cabling and all electrical connectors. 

GCS preflight includes system power up of the 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 of Tough Pad systems. 

As part of the GCS preflight, the ground station software and the UA software 

are updated to the latest version approved for flight operations. 

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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 of the startup checklist, the AVO will verify that the GCS and autopilot 

software are updated to the correct and approved version. 

Preflight of electrical 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 of throttle 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. 

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iii. Walk-Around Inspection: 

Inspect all 8 motors for security 

2. Inspect all 8 Propellers for cracks, chips and 1. 

delamination's and screws for security 

3. Inspect all 8 motor arms for security 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 

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ILLUSTRATION 2 - DAX8 SIDE 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 to the bus bar for all 8 motors 

4. Inspect all wires for cuts or abrasions 

5. Inspect propellers for nicks or cracks 

6. Inspect motors for smoothness of operation and cleanliness 

ELECTRIC MOTOR PREFLIGHT SAFETY CHECKLIST 

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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 

BATTERY PREFLIGHT CHECKLIST 

Avionics Preflight Checklist: 

Flight Operation: Date: 

Aircraft S/N: 

1. Inspect avionics compartment for debris 

2. Inspect bus harness connections 

3. Verify avionics are secure and properly mounted 

4. Verify analog connectors are connected and inspect for damage 

5. Verify power cable is connected and inspect for damage 

6. Inspect GPS antenna and verify connection 

AVIONICS SAFETY CHECKLIST 

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Airframe Preflight Checklist: 

Aircraft S/N: N-Number: Date: 

1. Verify fuselage serial number 

2. Turn power ON 

3. Inspect fuselage for defects 

4. Inspect navigation lights 

6. Inspect transponder/transponder antenna and verify connection (if installed) 

7. Inspect sensor/payload for damage 

8. Remove camera cover and clean lenses 

AIRFRAME PREFLIGHT CHECKLIST 

v. Center of Gravity Preflight Checklist: 

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Due to the configuration of the 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 not to exceed 85% of its maximum thrust. 

The thrust output for the DAx8 is expected to be a maximum of 13.5kg, or 

29.75lbs at sea level. This yields a maximum possible takeoff weight 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 takeoff weight for a given situation based upon weather and location. 

These statistics are subject to change during testing, and upon completion of flight 

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 

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Empty 

weight: 

WEIGHT /LBS. 

WEIGHT AND BALANCE SHEET 

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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 of war, or terror). One of the 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 of the 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 for first 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 of Authorization 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 of exemption. 

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