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Matthew Tilden Moschetti, Esq.

24211 Burbank Blvd

Woodland Hills, CA 91367

tilden.moschetti@svn.com

September 24, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);

91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) 

(2);91.417 (a) & (b). 

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, Matthew Tilden Moschetti (Applicant), operator of Small Unmanned Aircraft Systems (“sUASs”) 

equipped to conduct aerial photography for the real estate industry for the creation of marketing 

materials for properties, hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned 

and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 

3) controlled as to access and 4) with the knowledge and permission of the property owner. Approval of 

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act. 

Applicant

The name and address of the applicant is: 

Matthew Tilden Moschetti

Ph: 818-570-0590

Email: tilden.moschetti@svn.com

Address: 24211 Burbank Blvd, Woodland Hills, CA 91367

The applicant holds a Private Pilot Airman Certificate with over 100 hours of flight time on commercially 

available sUASs. He is also a licensed attorney and real estate broker and has a command of the laws and 

regulations that govern the use applied for herein.
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Regulations from which the exemption is requested

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)

14 CFR 91.409 (a) (1) & (2) 

14 CFR 91.417 (a) & (b)

Basis for Request

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion 

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

Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the 

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

• The UAS’s size, weight, speed, and operational capability; 

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

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

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the 

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

in the national airspace system.” Id. §333(c) (emphasis added)1

. 

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

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203 (a) (1). 

 1 Applicant interprets this provision to place the duty on the Administrator to not only process applications 

for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of 

the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory 

requirements for approval.
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The sUASs operated by the Applicant are rotorcraft, weighting 55 or fewer lbs. including payload. They 

are all commercially available. They operate, under normal conditions at a speed of no more than 50 knots 

and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will 

operate only in line of sight, in areas that are safe, and not within the close proximity of any person. The 

subject matter for the photography are large buildings. Such operations will insure that the sUAS will “not 

create a hazard to users of the national airspace system or the public.”2

Given the small size of the sUASs involved and the subject matter for the photographic operations, the 

applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence 

immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will 

operate, approval of the application presents no national security issue. Given the clear direction in 

Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations, and the significant public benefit, 

including enhanced safety, reduction in environmental impacts, including reduced emissions associated 

with allowing UASs for movie and television operations, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

Aircraft and Equivalent Level of Safety

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. 

These limitations and conditions to which Applicant agrees to be bound when conducting commercial 

operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated 

at 25% battery power reserve should that occur prior to the 30 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet 

above an elevated platform from which filming is planned. 

5. sUAS Pilot will be an FAA licensed airman with at least a private pilot’s certificate with a current 

driver’s license to establish basic medical fitness.

6. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, 

who possess the necessary PIC qualifications, is also present, that person can also be designated 

as PIC. 

7. Pilot will have been trained in operation of UAS generally and received up-to-date information on 

the particular UAS to be operated. 

8. If an Observer is present, Pilot will at all times be able to communicate by voice and/or text to 

Observer. 

9. Written and/or oral permission from the relevant property holders will be obtained. 

10. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

 2 Reform Act Section 333 (b).
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11. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to 

a pre-determined location and land. 

12. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

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

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator and under the requirements and 

in compliance with local public safety requirements, to provide security for the area of operation. These 

safety enhancements provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport," "experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will 

have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. 

Given the size of the sUAV, two-inch lettering will be impossible. The word “Experimental” will be placed 

on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the 

UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions 

Nos. 10700, 8738, 10167 and 10167A. 
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14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry 

a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a 

commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot 

and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is 

controlled, and all flights are planned and coordinated in advance. The level of safety provided by the 

requirements exceeds that provided by a single individual holding a commercial pilot’s certificate 

operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished 

from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that 

allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of 

safety achieved by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

adherence to maintenance and use of safety check lists prior to each flight an equivalent level of safety 

will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry 

such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground control point 

where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. An equivalent level of safety will be provided by adhering to a detailed maintenance schedule 

and preflight checklist. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. 
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sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption 

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers 

will be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform, an exemption may be needed to allow such 

operations. As set forth herein, the UAS will never operate at higher than 400 AGL. It will however be 

operated in a controlled area, where buildings and people will not be exposed to operations without their 

pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the property owner in the filming activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or 

rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, 

any risk associated with these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small-UAS operations and the operations of conventional aircraft that must 

comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

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

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 

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

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes 

in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions 

is reasonable. 
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Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners 

or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the 

utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 

25% of battery power whichever happens first. This restriction would be more than adequate to return 

the sUAS to its planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 

10808. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there 

is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to 

the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

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

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight 

manual and operating handbook of the commercially available sUAS. An equivalent level of safety will be 

achieved because these small UASs are very limited in size and will carry a small payload and operate only 

in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working 

order prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 
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Privacy 

All flights will occur over property with the property owner’s prior consent and knowledge. Filming will be 

of people who have also consented to being filmed or otherwise have agreed to be in the area where 

filming will take place. 

Aircraft Operation Manuals

Please see Appendix 2.

Procedures to Ensure Safe Operation

Please see Appendix 3.

Radio Frequencies

Each aircraft to be operated would be a commercially available sUAS. Please see Appendix 2 where the 

manuals will contain the RF spectrum that will be used.

Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security – provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant’s UAS in the real estate industry.

Please do not hesitate to contact me at the phone number or via the e-mail address provided above should 

you have any questions or concerns.

Respectfully Submitted,

Matthew Tilden Moschetti
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Appendix A - Summary for Federal Register Publication

Petitioner: Matthew Tilden Moschetti

Sections of 14 CFR Affected:

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)

14 CFR 91.409 (a) (1) & (2) 

14 CFR 91.417 (a) & (b)

Description of Relief Sought:

Applicant seeks relief from the requirements of 333 Aircraft Exemption Status to operate commercially a 

small unmanned vehicle (55lbs or less).

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions below, will 

provide an equivalent level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters operating in close 

proximity to the ground and people. 

Flights will be operated within line of sight of a pilot and/or observer. The maximum total flight time for 

each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should 

that occur prior to the 30 minute limit. Flights will be operated at an altitude of no more than 400 feet 

AGL or, not more than 200 feet above an elevated platform from which filming is planned. sUAS Pilot will 

be an FAA licensed airman with at least a private pilot’s certificate with a current driver’s license to 

establish basic medical fitness. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess the necessary PIC qualifications, is also present, that person can also be 

designated as PIC. Pilot will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated. If an Observer is present, Pilot will at all times be able 

to communicate by voice and/or text to Observer. Written and/or oral permission from the relevant 

property holders will be obtained. All required permissions and permits will be obtained from territorial, 

state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return 

to a pre-determined location and land. The sUAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies.
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Appendix B – Specific type(s), make, and model

#1 – YUNEEC Q500

See attached Q500 Typhoon Instruction Manual
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#2 – DJI Phantom 3

See attached Phantom 3 Advanced User Manual
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#3 – DJI Inspire

See attached Inspire 1 User Manual
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Appendix C

Responsibilities and Pre-Flight/Post-Flight Actions

I. Responsibilities

A. Pilot In Command (PIC)

1. The PIC is directly responsible for, and is the final authority over the actual

operation of the sUAS.

2. PICs have absolute authority to reject a flight based on personnel safety or 

violation of FAA regulations. No PIC may make a flight when, in the opinion of the PIC, it 

poses a risk to persons or property or is in violation of FAA regulations.

3. PICs are responsible for compliance with these Responsibilities local and federal 

laws and regulations, and FAA regulations.

4. The PIC’s main duty during the deployment of the sUAS is to operate the UAS 

safely while accomplishing the goals of the deployment.

5. PICs shall see-and-avoid any obstacle that will lessen safety during the mission.

6. PICs shall be responsible for documentation for mission training and updating of

flight books.

B. Observer (if one is present – and it is advisable to have one present)

1. Observers shall see-and-avoid any obstacle that will lessen safety during the 

mission.

2. Observers shall operate any attachments to the UAS, allowing the PIC to 

maintain complete focus on the operation of the UAS.

3. Observers shall assist the PIC in the main objective of safe operations of the 

UAS.

4. Observers shall be responsible for documentation for mission training and 

updating of flight books.

C. Personal Equipment

1. PICs/Observers will take into consideration the current weather conditions 

when planning to deploy, and wear appropriate clothing to deploy comfortably.

2. There are no documented issues with the use of the radio or cellular phones 

during the deployment of the sUAS, but the PIC/observer should at all time take into 

consideration safe operation of the UAS when using the radio or another device. (Use of 

the radio or cell phones is strictly prohibited by the PIC during flight.)

II. Pre-Flight/Post-Flight Actions

A. Inspections

1. PICs/Observers are both responsible for a thorough preflight inspection of the 

UAS.

2. Before and after each deployment (whether an incident or training), the PIC and 

observer shall conduct a thorough inspection of the UAS in accordance with the 

instructions contained in the manufactures user's manual.
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3. Any issues found that will put in jeopardy the safe operation of the UAS shall be 

documented and resolved immediately prior to flight.

4. It has been recognized that the use of a checklist is a significant method to 

combat UAS accidents. A pre-flight and post-flight checklist is contained with each sUAS

and will be utilized prior to each flight.

5. Any physical equipment that cannot be resolved on-site, and which have an 

impact on safety or the mission, will override the deployment. These issues will be 

resolved before flight.

B. Weather

1. Before each deployment the PIC/observer will ensure that he/she gathers 

enough information to make themselves familiar with the weather situation existing 

throughout the area of deployment. The PIC shall utilize FAA approved weather 

resources to obtain the latest and most current weather conditions.

2. An anemometer should be utilized in order to better estimate the wind speed 

and determine if it is within the capabilities of the airframe being flown.

3. PICs/Observers should use the Beaufort Scale when making deployment 

decisions in regards to wind conditions. This scale can be located in the manufacture's 

user's manual.

4. The weather conditions reported for the operation shall be recorded in the 

flight log.

5. The PIC shall ensure that the flight will occur within FAA VFR weather 

requirements.

C. Documentation and Evidence

1. Inspection and weather will be documented prior to flight within the log book.

2. After each flight, the PIC will complete a statement documenting the UAS 

operations.

D. Planning

1. The PIC/observer shall familiarize themselves with all available information 

concerning the deployment including, but not limited to, the weather conditions, 

hazards, description of the incident, deployment goals, etc.

2. PICs will ensure that the location for take-off and emergency landing is 

adequate for a safe deployment.

3. At least one emergency landing area should be identified per deployment.

4. PICs will ensure that they are aware of their surroundings in the event that an 

emergency landing is necessary. This includes the ability to recover the UAS.

E. Checklists

1. PICs shall utilize the checklists to ensure the highest level of safety for 

deployment.

2. Prior to flight, the flight log shall be initiated.

F. Maintenance
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1. Although there are few parts on the UAS that need servicing, it is necessary that 

the manufacturer's maintenance schedule is followed and properly documented.

2. Any issues that arise during maintenance that cannot be resolved by routine 

methods shall be forwarded to the manufacturer for further technical support.

G. Other

1. PICs/Observers will ensure that no items are attached to the UAS prior to flight 

that are not required for safe operation and to complete the mission goal.