Capital_Aerial_Video,_LLC - Drone Laws Blog by Antonelli Law
Contents
1. 02012 DJI Innovations All Rights Reserved Tools Needed 2 0mm Hex Wrench Screw Glue Nylon Cable Tie Scissors Diagonal Cutting Pliers Foam Double Sided Adhesive Tape Soldering iron amp Wires ESC Wiring For frame and motors installation For fastening screws For binding devices and wires For fixing receiver controller and other modules For connecting ESCs power cables to bottom board Important Please solder ESCs to power pads bottom board as the figure shows Use any insulating method at all soldering spots Make sure there is no short or open circuit Make sure the side of power pads is upward e sure the rotation direction of each motor is the same as the way in the figure of Assembly shows If not switch any of two wire connections of the incorrect motor to change its rotation direction 02012 DJI Innovations All Rights Reserved Assembly SSE Step 3 Install motors ESCs Step 4 Step 5 install top board install propellers Please install propellers after autopilot system configuration procedure Make sure the rotation direction of propellers are the same as the figure shows When mounting the propellers do not use any thread locker just tighten the nuts to the end manually then use the wrench to tighten it about 50 Install autopil2. nennen nennen neret 7 6 EE 7 Product Usage Cautions When flying the fast rotating propellers of FlameWheel550 will cause serious damage and injury Therefore please fly with a high safety consciousness 1 Keep flying multi rotor away from objects such as obstacles children human beings high voltage lines and so on 2 Do not get close to or even touch the working motors and propellers which will cause serious injury Do not over load the multi rotor Check that the propellers and the motors are installed correctly and firmly before flight Make sure the rotation direction of each propeller is correct Check whether all parts of multi rotor are in good condition before flight Do not fly with old or broken parts 7 Use DJI parts as much as possible If you have any problem you cannot solve during installation please contact our customer service 02012 DJI Innovations All Rights Reserved 3 In Box Top Board 550FBT 1 Bottom Board 550FBB x1 Arms 55 x4 550FAW x2 10in Propeller Pairs 550P10x4 8in Propeller Pairs 550 08 4 C 7e 0075 ee Motors 550 x6 ESC 550 5 x6 Se Screws Screws 550 2 5 6 x36 Magic Strap 550MSX x1 Battery Band 550BBX x1 Power Line Pair 550PLP x1
3. All operations must utilize a visual observer VO The VO and PIC must be able to communicate by voice at all times during a flight operation d Operations will be restricted to flights over private property with the permission of the property owner e The PIC must have accumulated and logged in a manner consistent with 14 CFR 61 51 b a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type f All required permits will be obtained from state and local government prior to operation g The CAV System will not be operated over densely populated areas h The CAV System will not be operated at air shows i CAV System will not be operated over any open air assembly of people System will not be operated over heavily trafficked roads k The CAV System will not be operated within 5 NM of an airport or heliport D The CAV System will not be operated over properties smaller than two acres in size m Operations will be restricted to day only and weather conditions equivalent to VFR n The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location No flight may be made without a Pre Flight Inspection by the PIC before each operation to ascertain that the UA is in a condition safe for flight see Appendix A Page 2 of 3 The PIC and VO will meet the
4. requirements outlined in FAA Policy N 8900 227 Section 16 personnel Qualifications Additionally the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training We submit that the combination of the UA s light weight flight performance and ability fully qualified flight crew and strict operation under the guidelines established in 8900 227 and under all of the Restrictions a through listed above the FAA can have full confidence that the operation will have an equivalent or greater level of safety than manned aircraft performing the same mission The name and contact information of the applicant are Capital Aerial Video LLC Attn Alston Boyd Ph 512 925 9595 Fax 512 301 8382 Email alston boyd2 com The regulations from which the exemption is requested are listed below Beside each regulation number is the page of the attached Addendum upon which each may be found together with our proposed equivalent level of safety for each regulation STEGER Pare Addendum Page 1 91 203 555 e Rte Addendum Page 1 14 45 23 45 29 Addendum Page 2 SAR ONO Addendum Page 2 14 CFR 61 113 61 133 Addendum Page 2 14 CFR 91 109 91 119 91 121 Addendum Page 3 T4 CER 91 151 iii eite Addendum Page 4 14 Su
5. Capital Aerial Video 14607 Bear Creek Pass Austin TX 78737 8933 PH 512 925 9595 October 14 2014 FAX 512 301 8382 U S Dept of Transportation Docket Operations West Building Ground Floor Room w12 140 1200 New Jersey Avenue SE VIA FEDERAL EXPRESS Washington DC 20590 VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM Re Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Sir or Madam Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 the Reform Act and 14 C F R Part 11 Capital Aerial Video LLC CAV seeks an exemption from Federal Aviation Regulations FARs detailed below for the following described Unmanned Aerial System called in this application the CAV System which includes an Unmanned Aircraft UA and ground station based equipment and crew THE UNMANNED AIRCRAFT UA lightweight 5 3 16 gross weight with all on board equipment battery operated 6 motor rotorcraft in the form of a hexacopter that takes off and lands vertically manufactured by DJI Model F550 modified by the applicant to carry the following equipment in flight e An on board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground based transmitter controller e An on board camera capable of capturing imagery in the form of full color high definition still photos and video e An on boar
6. ategory and class in order to apply for a commercial pilot s license we propose to generate an equivalent level of safety by requiring our pilots to complete at a minimum FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements Since the aircraft cannot carry passengers or property we feel we meet the intent of 61 113 Subparagraph b even though the intent of this application is to conduct a business 14 CFR 91 109 Flight Instruction Simulated instrument flight and certain flight tests The regulation states that No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls The CAV System ground based control station consists of a small hand held radio transmitter and while it does not offer a second set of controls both the student and instructor can and will operate the single set of controls simultaneously With both student and instructor having hands on the controls during flight we feel that this technique meets the intent 91 109 and provides an equivalent level of safety 14 CFR 91 119 Minimum safe altitudes General The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person vessel vehicle or structure Since the aircraft will be operating at a maximum of 400 feet AGL we cannot comply with th
7. bpart E 91 401 91 417 Addendum Page 4 FAA Policy 8900 227 Paragraph 16 c 4 and Paragraph 16 e 1 Addendum Page 4 We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety Please contact us at any time if you require additional information or clarification We look forward to working with your office Sincerely Lh 6 9 Alston Boyd Partner Capital Aerial Video LLC Commercial Pilot Certif No 1689774 Addendum containing Exemption Requests and Equivalent Level of Safety Appendix A Flight Manual Appendix B Owner s Manual for UA Page 3 of 3 ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Capital Aerial Video LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the CAV System 14 CFR Part 21 Subpart H Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems we request an experimental certificate be issued for the CAV System under either or both of the following provisions 21 191 Experimental certificates Experimental certificates are issued for the following purposes a Research and development Testing new aircraft design concepts new aircraft equipment new aircraft installations new ai
8. cted to UA Sw E Down OPERATION WITH GPS LOCATOR ON Middle OPERATION WITHOUT GPS Up AEROBATIC NOT USED Sw F Up FAILSAFE RETURN HOME AUTONOMOUSLY Down NORMAL OPERATION Sw C Forward GEAR DOWN Sw B Forward NORMAL OPERATION Back GEAR UP Back THROTTLE SET AT 50 HOVER VR CAMERA GIMBAL CONTROL KNOB N BUILT IN ANTENNA 4 Futaba ANSMISSION DIVERSI T g i i x 4 Way Stick Left Power Switch 4 Way Stick Right Forward THROTTLE UP Up ON FORWARD Back THROTTLE DOWN Down OFF Back MOVE BACKWARD Left TURN LEFT Left MOVE LEFT Right TURN RIGHT Right MOVE RIGHT Appendix A Page 2 of 2 FlameWheel550 User Manual V 1 9 2013 03 13 Revision ciji FLAME WHEEL www dji innovations com 2012 DJI Innovations All Rights Reserved Disclaimer Read this disclaimer carefully before using FlameWheel550 By using this product you hereby agree to this disclaimer and signify that you have read them fully FlameWheel550 is an excellent multi rotor With a good autopilot it will even offer tremendous flight features for low altitude flight working in restricted space Despite the controller of autopilot operates in the safest manner when the main power battery is connected we strongly recommend customers to remove all propellers use power supply from R C system or flight pack battery and keep children away during system calibration and parameter setup Please respect the AMA s National Model Airc
9. d telemetry system that delivers flight data from the on board flight computer to the on board radio transmitter including altitude AGL horizontal and vertical speed compass direction of flight and direction back to its launch site e A 600mW 5 8GHz on board radio transmitter that transmits live video from the on board camera plus all the flight data from the telemetry system described above THE GROUND STATION BASED PART OF THE SYSTEM e A Pilot in Command PIC in operational control of a flight operation from beginning to end and who controls the UA while in the air e A 100mW 2 4GHz radio transmitter controller operated by the PIC to control the UA while in flight e A radio receiver receiving live video and flight data from the on board camera and computer projects it all together onto a screen for the PIC to view during flight e A Visual Observer VO is a person who provides a second pair of eyes to visually track the UA while in flight The requested exemption would support an application for a commercial Certificate of Authorization to use the above described CAV System to support aerial photography video primarily of real property specifically individual properties of at least two acres in size equivalent to a square 295 feet side The UA powered by batteries is smaller lighter and more maneuverable than larger aircraft running on combustible fuel it operates at lower altitudes with no people on board and will ther
10. eby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury With a small payload and maximum flight time of only 15 minutes this is offers little or no risk to national security Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics of large complex properties with several buildings and large trees The applicants in the past have chartered 2 seat full sized helicopters for this purpose which has proven more costly than many potential clients have been able to afford The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property Additionally we request that we be allowed to use our system to benefit first responders nearby who might require assistance including fire fighters the police the sheriff et al while remaining subject to all limitations cited in this application as we do so The CAV System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900 227 Section 14 Operational Requirements for UAS and with the following Restrictions a No flight will be made with a UA Gross weight exceeding 55 pounds b All operations must occur in FAA Class G airspace at no more than 400 ft AGL at an airspeed of no more than 25 knots and no further than 3 4 NM from the PIC c
11. ee and avoid air traffic a licensed driver is medically qualified to operate a much larger vehicle Addendum Page 4 of 4 APPENDIX FLIGHT MANUAL FLIGHT RESTRICTIONS a No flight will be made with a UA Gross weight exceeding 55 pounds b All operations must occur in FAA Class G airspace at no more than 400 AGL at an airspeed of no more than 25 knots and no further than 3 4 NM from the PIC c All operations must utilize a visual observer VO The VO and PIC must be able to communicate verbally at all times during a flight operation d Operations will be restricted to flights over private property with the permission of the property owner PIC must have accumulated and logged in a manner consistent with 14 CFR 61 51 b a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type f All required permits will be obtained from state and local government prior to operation g The CAV System will not be operated over densely populated areas h The CAV System will not be operated at air shows i The CAV System will not be operated over any open air assembly of people CAV System will not be operated over heavily trafficked roads k The CAV System will not be operated within 5 NM of an airport or heliport D The CAV System will not be operated over properties smaller than two acres in size m Operations
12. flight Maintenance performed by the PIC is limited to repairing small cracks replacing a propeller checking electrical connections and updating software and firmware for the on board computer All other maintenance will be performed by the manufacturer or their designated repair facility The PIC will document work performed in accordance with 91 417 We feel that due to the size construction and simplicity of the aircraft the PIC can ensure an equivalent level of safety 8900 227 Paragraph 16 c 4 PIC Medical and Paragraph 16 e 1 Observer Medical This policy provides that both the PIC and VO must have a valid FAA second class medical certificate issued under part 67 in order to perform as a pilot or observer The UA maximum gross weight is 5 3 pounds it is constructed of carbon fiber and plastic and the PIC is not on board Both the PIC and the VO are required to be in VLOS Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight the UA will return autonomously to the site of launching and land without crew intervention Therefore requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20 20 and a valid state issued driver s license The 20 20 vision requirement will ensure that the PIC and VO can s
13. igned to the aircraft and a registration certificate must be aboard the aircraft Additionally subparagraph b provides that the airworthiness certificate be displayed at the cabin or cockpit entrance so that it is legible to passengers or crew At a maximum gross weight of 5 3 pounds the UA is too small to carry documentation does not have an entrance and is not capable of carrying passengers or crew To obtain an equivalent level of safety and meet the intent of 91 203 we propose that documents deemed appropriate for this aircraft by the FAA will be co located with the crew at the ground control station and available for inspection upon request In order to identify the aircraft we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word EXPERIMENTAL to Addendum Page 1 of 4 satisfy the requirement of 14 45 23 which follows immediately after the proposed placard description below EXPERIMENTAL Manufacturer DJI Innovations Inc 950 E Baseline Ave Ste 210 Apache Junction AZ 85119 Model F550 Serial Number DJ13 00937 If found please contact 512 925 9595 14 CFR 45 23 Display of marks general and 45 29 Size of marks These regulations provide that each aircraft must display N and the aircraft s registration number in letters at least 3 inches high Additionally the aircraft must di
14. in an airplane under day VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing The UA is battery operated and the maximum duration of flight from a single battery charge is 12 minutes with a 20 reserve Since the aircraft will never fly more than 3 4 NM from the point of intended landing a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph We request an exemption to the word fuel and ask for an equivalent interpretation with the word energy 14 CFR Subpart E 91 401 91 417 Maintenance Preventive Maintenance Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition including compliance with part 39 and 43 Paragraphs 91 407 and 91 409 require that the aircraft be approved for return to service by a person authorized under 43 7 after maintenance and inspection It is our intention that the PIC perform maintenance and inspection of the aircraft and be authorized to approve the aircraft for return to service As provided in the Pre Flight Checklist in Appendix A the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of
15. is requirement In order to provide an equivalent level of safety we will only fly over private property with a size of at least two acres with the permission of the owner of the property flown over The aircraft will not be operated over congested areas or over any open air assembly of persons The property owner will be briefed on the expected route of flight and the associated risks to persons and property on the ground The aircraft will be operated at a low altitude allowing if a power unit fails an emergency landing without undue hazard to persons or property on the surface Therefore we maintain that due to the small size of the UA the hazard to persons vehicles and structures is minimal compared to manned aircraft which should be considered in granting the exemption 14 CFR 91 121 Altimeter settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft The will always fly below 400 feet AGL and will not need to maintain cruising altitudes order to prevent conflict with other aircraft An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA on board computer to the display screen held by the PIC providing a constantly updated AGL readout Addendum Page 3 of 4 14 91 151 Fuel requirements for flight in VFR conditions The regulation provides that no person may begin a flight
16. ot system Install screws by appropriate force to prevent breaking threads Use adequate screw glue for installing screws e Please wire neatly Make sure wires will not be cut by frame boards and propellers e Smooth out the boards edge if necessary In up figure arms front of craft arms are back of craft See from top motors on arms rotate counter clock wise use propellers 1038 motors on arms rotate clock wise use propellers 1038R 2012 DJI Innovations All Rights Reserved 6 ESC Sound Introduction ESC State Sound Ready 71234567 Throttle stick is not at bottom BBBBBB Input signal abnormal B Input voltage abnormal BB BB BB BB Tips DJI ESCs are specially designed for multi rotors When use with DJI autopilot systems you do not have to setup any parameters or calibrate travel range Specifications Frame Diagonal Wheelbase 550mm Frame Weight 478g Takeoff Weight 1200g 2400g ESC Current 30A OPTO Signal Frequency 30Hz 450Hz Battery 3S 4S LiPo Motor Stator size 22x12mm KV 920rpm V Propeller 10 x 3 8in 3S Optional 8 x 4 4S 2012 Dul Innovations All Rights Reserved
17. raft Safety Code DJI Innovations assumes no liability for damage s or injuries incurred directly or indirectly from the use of this product DJI FLAME WHEEL is registered trademark of DJI Innovations Names of product brand etc appearing in this manual are trademarks or registered trademarks of their respective owner companies This product and manual are copyrighted by DJI Innovations with all rights reserved No part of this product or manual shall be reproduced in any form without the prior written consent or authorization of DJI Innovations No patent liability is assumed with respect to the use of the product or information contained herein F550 Profile FlameWheel550 F550 is a multi rotor designed for all pilots for fun or AP With DJI WKM or NAZA autopilot system it can achieve hovering cruising even rolling and other flight elements It can be applied for entertainment aerial photography FPV and other aero modeling activities 02012 DJI Innovations All Rights Reserved 2 Contents Dite o etina 2 F550 Profile 2 Contents is PTT 3 Product Usage pee 3 MBOX A 4 Tools Needed 5 ESC Wir 5 ASSEMDl yrn ue t deo et oes 6 ESC Sound Introduction
18. rcraft operating techniques or new uses for aircraft b Showing compliance with regulations Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates flights to substantiate major design changes and flights to show compliance with the function and reliability requirements of the regulations Since the experimental certificate can be used for commercial purposes such as market surveys sales demonstrations and customer crew training we would expect that an experimental certificate would permit our commercial purpose as well The aircraft will not carry persons or property will not carry fuel and will only fly under strict operational requirements Combined with the UA s light weight being constructed primarily of carbon fiber and plastic we propose that the UA will be at least as safe if not safer than a conventionally certificated aircraft performing the same mission If an experimental airworthiness certificate is not appropriate for this application then we request an exemption of 14 CFR Part 21 Subpart H and the requirement for an airworthiness certificate in general citing the equivalent level of safety outlined in the previous paragraph 14 CFR 91 203 a amp b Civil aircraft Certifications required The regulation provides that an airworthiness certificate with the registration number ass
19. splay the word EXPERIMENTAL in letters at least 2 inches high near the entrance to the cabin cockpit or pilot station The UA does not have an entrance in which the word EXPERIMENTAL can be placed and may not have a registration number assigned to it by the FAA We propose to achieve an equivalent level of safety by including the word EXPERIMENTAL in the placard on the top of the aircraft as shown above where the PIC VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation Additionally we feel that the permanent placard discussed in the previous paragraph will provide the aircraft s registration information at the ground station Finally we will display at the ground station a high contrast flag or banner that contains the words Unmanned Aircraft Ground Station in letters 3 inches high or greater Since the aircraft will operate within 3 4 NM of the ground station the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin 14 CFR 91 9 Civil aircraft flight manual marking and placard requirements This regulation provides that no person may operate an aircraft unless a current approved flight manual is in the aircraft We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft We request an exemption to this requirement since the aircraf
20. t is not only too small to carry documentation the documentation would not be available to the crew during flight operations To obtain an equivalent level of safety and meet the intent of 91 9 we propose that a current approved UA Flight Manual Appendix A must be available to the crew at the ground station anytime the aircraft is in or preparing for flight 14 CFR 61 113 Private pilot privileges and limitations Pilot in Command and 61 133 Commercial pilot privileges and limitations The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire Subparagraph b allows a private pilot to act as pilot in command of an 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 Addendum Page 2 of 4 Our proposed operations require that the PIC must either 1 Hold a Commercial Pilot Certificate issued by the FAA and have logged 25 hours of flight experience in this type of UA or 2 Meet the requirements of 8900 227 para 16 c 2 c Operations without a pilot certificate in which the PIC is required to complete FAA private pilot ground instruction and pass the FAA Private Pilot written examination Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent c
21. will be restricted to day only and weather conditions equivalent to VFR n The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location No flight may be made without a successful Pre Flight Inspection by the PIC before each operation to ascertain that the UA is in a condition safe for flight PRE FLIGHT CHECKLIST 1 Use voltmeter to determine that UA battery is fully charged in order to prevent unexpected premature descent 2 Check all wiring connections are tight 3 Check all propellers are undamaged and no cracks exist in any structural members of the UA 5 Turn on radio controller check for adequate voltage set it to connect to the UA move all control switches to forward or down position and throttle control stick full back position 6 Connect UA main battery check for radio contact with UA s radio receiver 7 At a location different from previous flight re set GPS and compass to current location 8 Turn on transmitter gimbal and camera TO REGAIN CONTROL AFTER LOST RADIO CONTACT 1 Failsafe ON If radio contact is not restored the UA 2 Throttle 50 will automatically continue at 60 ft 3 Mode ATTI above its last elevation before losing 4 Failsafe OFF contact toward its takeoff point then 5 Mode GPS descend and land there autonomously Appendix A Page 1 of 2 DIAGRAM OF UA FLIGHT CONTROLS Excludes controls not used or not conne
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