This is a representative sample of an approved waiver 

application for 14 CFR § 107.35 

Small UAS #1 Details 

Make: 123 UAS 

Model: Octocopter 

Small UAS #2 Details 

Make: 123 UAS 

Model: Octocopter 

Small UAS #3 Details 

Make: 123 UAS 

Model: Octocopter 

Small UAS #4 Details 

Make: 123 UAS 

Model: Octocopter 

Waiver Application: 

What regulation(s) do you want waived? 

107.35: Operation of multiple small unmanned aircraft 

Start date: 20XX-11-XX 
End date: 20XX-11-XX 

Waiver safety explanation: 

ABC Drone Services is requesting a waiver to §107.35 in order to operate 4 123 UAS’s 

small unmanned aircraft (sUA) simultaneously for the purpose of monitoring a privately 

owned 40 acre, fenced in Vineyard measuring XXX feet wide and XXXX feet long, 

located approximately 5 miles South East of XXXX. All operations will be conducted in 

Class G airspace, below 400 feet AGL, during daylight hours, and with at least 3 miles 

visibility. A private non-public use airport is the nearest airport located 4 miles west of 

the propose operations area. There are no other airports within 5 miles of the proposed 

operations area. Our operations area consists of flat terrain with no obstructions such as 

trees or structures. Our proposed operation will require 4 123 UAS’s sUA fly 

simultaneously down the length of the vineyard, these sUAs will be lined up side by side 

with 50 feet separation between each sUA. Our remote pilot in command (RPIC) will be 

positioned halfway down the length of the field, with a visual observer (VO) at each end 

of the field. Our RPIC and VOs will be on a 5 foot high platforms which will enable them 

to see over the crops, allowing our RPIC and VOs to maintain visual line of sight with 

each of the sUA. Each small unmanned aircraft utilizes geo fencing to keep the sUA’s 

within the property boundaries of the vineyard, the sUA’s will fly a pre-programed flight 

path down the length of the operational area. At the opposite end of the field the sUA’s 

are programmed to enter a hover until the RPIC takes manual control of each sUA 

individually. The RPIC will land each sUA in a pre-designated location. We have 

included an operations manual with our application. 

Specific Operation Details: 

1. Where do you plan to operate? XXXXX, XXXXXX at Latitude XX.003572 

Longitude -XXX.275184 - See Section 1.5.3 

2. How high will you fly your aircraft? 400 feet Above Ground Level (AGL) – See 

Section 1.4.4 

3. Do you want to fly in controlled airspace (Class B, C, D, surface E)? No – all 

flights will be in Class G airspace. – See Section 1.4.8 

4. Are there any other kinds of airspace within 5 miles of any planned flight area? 

No – all airspace within 5 miles is Class G airspace. – See Section 1.4.8 

5. What kind of area(s) will you fly over? Unpopulated privately owned, fenced 

agricultural land – See Section 1.5.3 
 

Small UAS Details: 

1. What kind of UAS will you use to fly the operations requested in this application? 

123 UAS Octocopter – See Section 1.4.9 

2. What is your UAS’s power or energy source in flight? lithium polymer battery – 

See Section 1.4.9 

3. What is your UAS’s maximum flight time (in minutes), range (in feet), and speed 

(in miles per hour)? Flight time with payload – 35 minutes, Range – 10032 feet, 

Maximum Speed – 32 mph – See Section 1.4.9 

4. How big is the aircraft? a. Length – 48” b. Width – 48” c. Height – 18” – See 

Section 1.4.9 

5. How do you ensure the aircraft only flies where it is directed (i.e. ensure 

containment)? “Geo Fencing” – See Section 1.4.4 

6. What kind of termination system, if any, does the UAS have? Each sUA is 

equipped with an immediate flight termination switch – See Section 1.4.4 

7. How much will the aircraft and its payload weigh when flying? 6.3lbs (aircraft) + 

1.lbs (payload) = 7.4lbs (total weight) – See Section 1.4.4 

8. If the aircraft carries any external or internal load (or object), how is the load 

secured? The payload has 2 pegs that fit into slots in the payload bay under the 

aircraft, and a latch that secures the payload. The only payloads that will be used 

are designed/manufactured by 123 UAS and are standard to the 123 UAS 

Octocopter system. – See Section 1.4.4 

9. What, if any, external or internal load (or object) could be dropped from the 

aircraft when flying, and how will you assure the safety of people, or other 

people’s property, if it is dropped or detached when flying? a. The Sensor payload 

could theoretically fall off the aircraft in the event the securing latch fails. 

However, all tests are flown over privately owned, unpopulated, agricultural land 

so there is no danger of injuring a person or other people’s property. 

Pilot/Personnel Details: 

1. What minimum level of experience will the Remote Pilot in Command (RPIC) 

have to fly under this waiver? 

RPIC will hold a Part 107 Remote Pilot certificated and have a minimum of 10 

hours of flight time on the 123 UAS Octocopter system. RPIC will log 5 hours of 

operating multi-sUAs flight simulation time on the 123 UAS Mission Control 

Station (MCS) Simulator prior to actual multi- sUA operations 
 

2. How many personnel (including the Remote PIC) will you use for operations 

under this waiver (minimum needed)? 3 – A minimum of 1 RPIC and 2 VOs will 

be used for all operations. – See Section 1.5.1 

3. What kind of training, if any, will personnel (e.g. visual observer(s)) have prior to 

flying under this waiver and how will personnel be trained? 

Prior to commencement of operations, each RPIC and VO will receive training on 

the regulation contained in Part 107, the limitations of this waiver and proper 

scanning techniques as described on page 17-23 of the Pilots Handbook of 

Aeronautical Knowledge (FAA-H-8083-25B). Each RPIC and VO must 

complete a 20 question test on the above subject matter. This test will be signed, 

dated and retained on file. Prior to each operation, the RPIC will brief the visual 

observers on the, location, airspace restrictions, flight plans and discuss each crew 

members responsibilities. 

How will the Responsible Person know the other personnel are competent and 

have operational knowledge to safely fly the UAS under the waiver conditions? 

Each RPIC will hold a Part 107 Remote Pilot certificate and an up-to-date flight 

log. Each RPIC and VO will have taken the test described above, with that test on 

file. If personnel will be tested, what kind of testing will be performed, and how 

will evaluations be conducted and documented? Each RPIC and VO will be 

require to take a 20 question written test, incorrect answers will be reviewed and 

discussed until each test can be corrected to 100%. This test will be signed and 

dated by the student and retained on file. 

How will personnel maintain the knowledge/skill to fly under this waiver? Will 

recurrent training or testing be required? Prior to performing any multi-sUA 

operation the RPIC will have logged a minimum of 30 minutes of single-sUAS 

flight time in the last 60 days and 30 minutes of multi-sUAS simulation time via 

123 UAS MCS Simulation in the last 60 days. 

Guiding Questions 

1. How does the system simultaneously control multiple participating aircraft and 

avoid collisions between those aircraft? 123 UAS Mission Control Station (MCS) 

natively supports One-to-Many control – See Section 1.4.3 

2. How will the system ensure individual participating aircraft remain contained in 

the pre-determined operational area? a. A combination of a pre-programed flight 

path and Geo Fencing will be used – See Section 1.4.4 

3. How will the RPIC see and avoid, or detect and avoid, all other aircraft when 

operation multiple aircraft? Will the proposed operations use a VO(s)? Yes, VOs 
will visually scan the operation area and adjacent airspace for unexpected air and 

ground traffic – See Section 1.5.1 

4. How will the RPIC safely stop/terminate all participating aircraft in the event of a 

hazard? 123 UAS Mission Control Station (MCS) allows the pilot to individually 

select an aircraft and adjust altitude, command an immediate land, or terminate 

flight – See Section 1.4.4 

5. How will the RPIC know when a single aircraft has failed, and how will the RPIC 

respond? How will the RPIC respond to multiple aircraft failing at the same time? 

123 UAS Mission Control Station (MCS) has a combination of safety features to 

reduce the risk of both single-aircraft error situations and multi-aircraft error 

situations. See Section 1.4.3 

6. What additional pre-flight safety procedures would the RPIC undergo to ensure 

safe operation? As described above the RPIC will conduct a preflight safety 

briefing RPIC on the, location, airspace restrictions, flight plans and discuss each 

crew members responsibilities. See Section 1.4.8 

7. How many command and control links and methods are used in the system? Each 

aircraft will have their own base-station for command and control. Do the aircraft 

communicate with each other? If so, what path do the communications follow? 

No, the aircraft do not communicate with each other. How do the system and/or 

individual aircraft respond when communications fail? The default behavior is 

for the aircraft to enter static hover until the C2 link can be reestablished – See 

Section 1.4.4 

8. How will the RPIC maintain a stand-off distance (buffer zone) from nonparticipating people or property a. A combination of geo fencing and operating 

over privately owned property will be used. See Section 1.4.4 

Other Certificates of Waiver or Authorization 

Is there a pending or approved waiver or authorization associated with this proposed 

operation? No