# • 

# esrr

February 4, 2016

U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 Re: Petition for an ExemptionPursuantto Section 333 ofthe FAAModernization and Reform Act of2012 Dear Sir orMadam: Pursuantto Section 33 3 ofthe FAAModernization and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, Environmental Systems Research Institute, Inc. ("Esri") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified belowto allow commercial operation ofsmall unmanned aerial systems ("UAS") for the purpose ofconducting aerial imaging, videography, topographic mapping, photogrammetry and remote sensing. The operating conditions and limitations set forth below, whichEsri is willing to accept, are identical to those inthe exemption granted to other similarly situated UAS operators, including, but not limited to Aeryon Labs, Inc. The only difference inthis request is that Esri is proposing the 3DR Solo UAS; however, the FAA has also granted an exemptionrequest previously for use ofthe 3DR Solo for commercial purposes. Since the 3DR Solo specified inthis request is the same craft that the FAA has already approved, and because Esri will operate the 3DR Solo UAS fully in compliance with the conditions in exemption precedent, the FAA need not provide notice inthe Federal Register or ask for public comment. For these reasons, this petition for an exemptionmeets the requirements for summary processing. This petition for exemption is made based oninformation outlined in this Petition for Exemption, as well as the accompanying Esri document; specifically the Flight Operations Manual.

380 New York Street Redlands, California 92373-8100 USA 909 793 2853 info@esri.com esri.comPage2

For your convenience, this Petition is organized as follows: 

### I. Description ofPetitioner II. Description ofProposed Operations A. Aerial Imaging, Videography, Topographic Mapping, Photogrammetry and Remote Sensing 

### III. Relevant StatutoryAuthority IV. Esri's Proposed UAS Operations Meet the Requirements ofSection 333 of the ReformAct A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions Set Forthinthe Operations Manuals 

### V. Regulations from Which Exemption is Requested A. 14 C.F.R. Part 21, SubpartH -Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal CategoryRotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): AircraftMarking and Identification Requirements D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(1), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. § 91.7(a): CivilAircraftAirworthiness G. 14 C.F.R. § 91.9(b)(2): CivilAircraft Flight Manual intheAircraft and 14 C.F.R. § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration H. 14 C.F.R. § 91.103: PreflightAction I. 14 C.F.R. § 91.109(a): Flight Instruction J. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes 

### K. 14 C.F.R. 

### § 91.121: Altimeter Settings L. 14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight inVFR Conditions 

### Vl. Drug andAlcohol Program VII. Public Interest VIII. Privacy IX. FederalRegister Summary X. Conclusion

### Page 3



### I. DESCRIPTION OF PETITIONER Since 1969, Esri has helped organizations map and model our world. Our GIS technology allows users to effectively manage and analyze geographic information so they can make better decisions. We offer flexible, configurable, and easy-to-use geospatial solutions that let anyone access informative maps and location apps anywhere and on any platform or device. These solutions are supported by our experienced staffand extensive network ofbusiness partners and international distributors. Esri applications provide the backbone for the world's mapping and location analysis. Esri software is used in more than 350,000 organizations worldwide including each ofthe 200 largest cities inthe United States, more than two-thirds ofFortune 500 companies, more than 24,000 state and local governments worldwide, hundreds ofU.S. government organizations including DoD, IC, and federal civil agencies, and many others in dozens ofindustries. Private ownership, a zero-debt policy, and a firm commitmentto fulfilling the needs ofour customers all help Esri maintain its position as the world leader in GIS software. As a socially conscious business, we are proudthat ourtechnology is used by many organizations who apply location-based insights to solve problems and make our world a better place to live. We also actively support organizations involved in education, conservation, sustainable development, and humanitarian affairs. Esri seeks an exemption to allow for aerial imaging, videography, topographic mapping, photogrammetry, remote sensing, and related data collection. The contact information for Esri is as follows: ATTN: Lawrie E. Jordan, III Director ofImagery and Remote Sensing Environmental Systems Research Institute, Inc. 380 New York Street Redlands, CA92373 USA Phone: (909) 793-2853, Extension 1406 E-mail: ljordan@esri.com 

### II. DESCRIPTION OF PROPOSED OPERATION Esri seeks an exemptionpursuantto Section 33 3 ofthe ReformActto operate small, commercially-produced, consumerUnmanned Aircraft (UA) to collect imagery, video and mapping datato be used inthe development and testing ofEsri software. All UAS operations will occur under controlled conditions onwhere Esri has received documented permissionto operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance withthe conditions and limitations ofthis Petition for Exemption and Esri's Operations Manuals. As detailed inEsri's Operations Manuals, all UAS operations will be limited to daytime VFR conditions in accordance to an approved Certificate ofWaiver or Authorization (COA). Esri's Operational procedures incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geofencing" technologies.Page 4



### III. RELEvANT STATUTORYAUTHORITY This Petition for Exemption is submitted pursuantto Section 333(a) through (c) ofthe FAAModernization and ReformAct of2012 ("ReformAct"). Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 333 ofthe ReformAct, the FAAAdministrator is to permitUASs to operate inthe NationalAirspace Systems ("NAS") where it is safe to do so based onthe following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS withinthe visual line ofsight ofthe operator. Additionally, the FAAAdministrator has general authority to grant exemptions from the agency's safetyregulations and minimum standards whenthe Administrator decides a requested exemption is inthe public interest. See 49 U.S.C. § 106(f) (definingthe authority ofthe Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and §§ 44702

- 44716, et seq.). A partyrequesting an exemption must explain the reasons whythe exemption: (1) would benefitthe public as a whole, and (2) would not adversely affect safety (or how it would provide a level ofsafety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

### IV. ESRI 'S PRQPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OFTHE REFORMACT The small UAS operations proposed by Esri as noted above inthis Petition for Exemption qualify for expedited approval pursuantto Section 33 3 ofthe ReformAct as each ofthe statutory criteria and relevant factors are satisfied. 

### A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability A Grant ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• SimilarUAS to thatproposed byEsri have been approved for use inprior Section 333 Grants ofExemption from the FAA.

• The UAS weighs less than 55 pounds, including payload

• The UAS will notbe flown at a ground speed in excess of87 knots. The exemption holder mayuse either groundspeed or calibrated airspeed to determine compliance withthe 87 knot speed restriction.

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• Altitude information will be generated byequipment onboard the UAS as specified using GPS triangulation, digitally encodedbarometric altimeter, radio altimeter, or any combinationthereof. This information will be transmittedto the pilot viatelemetric datafeed.

• The UAS will have system redundancies and independent functionality to ensure the overall safety and predictability ofthe system. Ifconnectionto the remote control or ground control station is lost, failsafe systems will permitthe UASs to return to a predetermined location and safely land without injury or damage.

• The radio frequencies used for operations and control ofthe UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the UAS is 2.4 GHz frequency bands. Ifthe same operations were conducted using a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending on payload. The difference in weight betweenthe UAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surroundingproperty inthe event ofan unintended accident or incident. In 

### addition, the risk to the onboard pilot and camera operator is eliminated. 

### B. Approval is Warranted Based on the Operational Restrictions Set Forth in Esri's Operations Manuals Esri's Operations Manuals and the Manufacturer's Manual for the selected UAS will contain all the procedures and limitations necessaryto safely and successfullyperformthe operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Esri's proposed operations, below is a summary ofoperational limitations and conditions that Esri will adhere to, and which will ensure an equivalent orhigher level ofsafety to operations conducted under current regulatory guidelines: 1. 

### The UAS weighs less than 55 pounds, withpayload. 2. All operations shall be conducted over property with documented permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UASs operated under the Grant ofExemption will comply with 14 CFRpart 48 pertaining to the registration and marking requirements for small unmanned aircraft. 4. Minimum crew for each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") of the UAS, and one or more Visual Observers ("VO") as necessary to safely conductthe mission.

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5. PICs will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC will also meet the flight reviewrequirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated onhis orher pilot certificate. 6. The UAS shall be operated within visual line ofsight ("VLOS") ofthe PIC and VO at all times. The PIC must use human vision unaided by any device otherthan corrective lenses, as specified onthe PIC's FAA-issued medical certificate. 7. The PIC and VO designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging ortexting will not be permitted during flight operations. 9. The additional requirements identified inthe Grant ofExemption and COA(s) shall be added to the Esri's Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request. Ifa discrepancy exists betweenthe conditions and limitations inthe Grant ofExemption and Esri's Operations Manuals, the conditions and limitations inthe Grant ofExemption shall take precedence and will be followed. Otherwise, Esri shall follow the procedures outlined intheir Operations Manuals. 10. Esri may update or revise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will beprovided to theAdministrator upon request. Esri will also present an updated and revised Operations Manuals ifitpetitions for extension or amendmentto its Grant ofExemption. Ifanupdate orrevision would affectthe basis upon which the FAA grants the exemption, Esri will seek an amendment to its Grant ofExemption. Esri will contactthe FAA's UAS Integration Office (AFS-80) ifquestions arise regarding updates orrevisions to the operating documents. 11. Esri Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime the UAS is operating. 12. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first intended point of landing, and assuming normal cruising speed with a 25% reserve. 13. Maximumtotal flight time for each operational flight using the UAS will be limited to 75% ofthe battery capacity leaving a 25% reserve 14. Flights will be operated at an altitude ofno more than 400 feet above groundlevel ("AGL") and will never enter navigable controlled airspace without authorization and approval from the FAA. 15. Flight operations will be conducted at least 500 feet from all nonparticipating persons. (persons otherthan the PIC, VO, operatortrainees or essential persons),

### Page 7 vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficientlyprotect nonparticipating persons from the UAS and/or debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UAS, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present anundue hazard, and;
c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 16. Esri intends to operate under the "blanket" COA and will not conduct UAS operations under the following conditions: a. Nighttime as defined in FAR 1.1; or b. During IFR conditions; or c. Within 5 nautical miles (NM) from an airport having an operational control tower; or d. Within 3 NM from an airport with a published instrument flight procedures, but not an operational tower; or e. Within 2 NM from an airport without a published instrument flight procedure or an operational tower; or f. 

### Within 2 NM from a heliport with a published instrument flight procedure; or g. At altitudes in excess of200 feet unless specifically authorized inthe exemption. 17. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, (e.g., inoperable components, items, or equipment), not already covered inthe relevant sections ofthe operating documents as well as equipmentupdates. The PIC will not operate any UAS ifthe inspectionreveals a conditionthat affects the safe operation ofthe UAS until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. The ground control station shall be included inthe preflight inspection. All maintenance and alternations will be properly documented inthe UAS's records as required by Esri's Operations Manuals. 18. Esri will timely carry out its maintenance, inspections, and record keeping requirements in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be fully noted inthe UAS records, including total time in service, description ofmaintenance accomplished, date completed and the signature ofthe person returning the UAS to service. 19. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement ofa flight critical component)Page 8

musttimely undergo a functional test flight in accordance with Esri'sOperations Manuals and manufacturer guidance. The PIC who conducts the functional test flight must make an entry inthe UAS aircraft records ofthe flight. The requirements and procedures for a functional test flight and UAS record entry shall be included inthe Esri's Operations Manuals. 20. The UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and productupdates. 21. Priorto the operation, a Mission Planwill be created in accordance with the requirements onEsri's Operations Manuals. 22. Esri will obtain Certificate ofWaiver orAuthorization, otherwise known as a "COA," priorto conducting any operations under this Grant ofExemption. 23. All required permissions and permits will be obtained from federal, state, and local jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 24. Ifthe UAS loses communication with the PIC, it will have the capabilityto safely return to a pre-determined location withinthe operational area and land safely. 25. Contingencyplans will be inplace to safelyterminate flight ifthere is a loss of communication betweenthe PIC and the VO. 26. PIC will also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. 27. Operations shall occur during daytime VFRMeteorological Conditions; flights under special visual flight rules ("SVFR") will notbe conducted. 28. The UAS shall remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 29. The UAS will notbe operated bythe PIC from any moving device or vehicle. 30. The radio frequency spectrum used for operation and control ofthe UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The Federal AviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, byits terms, includes exempting civil aircraft, as the term is defined under 

### §40101 of theAct, including UASs, from its safety regulations and minimum standards whenthe Administrator decides a requested exemption is inthe public interest.3 Esri seeks an exemption from several interrelated provisions ofTitle 14 ofthe Code ofFederalPage 9 Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconducting the requested operations using UAS platforms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and safeguards that Esri has established which will ensure a level ofsafety betterthan or equal to the rules from which exemption is sought.4 

### UNMANNEDAIRCRAFT SYSTEM A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §91.203(a)(l) The FAAhas stated that no exemption is needed from this section ifa finding is made underthe ReformActthatthe UAS selected provides an equivalent level ofsafety when compared to aircraft normally used for the same application. These criteria are met and inpoint offact exceeded, and therefore no exemption is needed. 5 If, however, the FAAdetermines thatthere are some characteristics ofthe chosenUAS that fail to meetthe requirements ofthe ReformAct, an exemption is requested. 

### EquivalentLevelof Safety Esri's use ofthe UAS is safe when taking into account its size, weight, speed, and operational capability. As set forth in the description ofproposed operations in Section IV(A), the UAS weighs less than 55 pounds, including payload and will notbe flown at a ground speed in excess of87 knots. Additionally, the UAS carries neither pilots norpassengers, carries no explosive materials or flammable liquid fuels, or other elements identified bythe Department ofHomeland Security as being prohibitive. Operations conducted underthis exemption will be closely controlled and monitored bythe PIC operator and will be conducted in compliance with local public safetyrequirements, to provide security for the area ofoperation. In all cases, operation ofthe UAS under the proposed conditions will be at least as safe as, or saferthan, conventional rotorcraft operating with an airworthiness certificate. Lastly, the UASs do not need a means 3 49 U.S.C. §44701(f) (authorizingthe grant ofexemptions from requirements ofregulations prescribedpursuantto Sections4470l(a) and (b) and Sections 44702- 44716). 4 14 C.F.R § 11.81(e), whichrequires a petition for exemptionto include: The reasons why grantingthe exemption would not adversely affect safety, orhowthe exemption would provide a level ofsafety at least equal to that providedbythe rule from which you seekexemption. 5 See Grant ofExemptionNo. 11062 toAstraeusAerial (FAA-2014-0352 atpgs. 13-14, 22).

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to communicate with other aircraft orATC, because those capabilities will be solelypossessed by the PIC and VO, who are not onboardthe UAS. 6 B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft 

### Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extentthat Esri's small UAS would otherwise require certification under Part 27, Esri seeks an exemption from Part 27's airworthiness standards for the same reasons identified inthe request for exemption from 14 C.F.R. R. Part 21, Subpart H, 

### supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements 

### Esri seeks an exemption from the aircraft marking and identificationrequirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).
• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No personmay operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthis chapter.

• 14 C.F.R. 

### § 45.23(b), Markings oftheAircraft, states: 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 onthat 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.

• 14 C.F.R. 

### §45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display onthat rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, or tail the marks required by 

### § 45.23.

6 See Grant ofExemptionNo. 11062 to Astraeus Aerial (FAA-2014-0352 atpg. 13).

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In 

### a previous Grant ofExemption, the FAA determined that exemption from these requirements was warranted providedthatthe aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 7 

### EquivalentLevelof Safety All UAS operated by Esri will comply with 14 CFRpart 48, "Registration and Marking Requirements for Small Unmanned Aircraft." 

### D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections Esri seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards inreference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. 

### § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections
...have discrepancies repaired as prescribed in part 43 ofthis chapter"). An exemption from these regulations is needed because Part 43 andthese sections only apply to aircraft with an airworthiness certificate, which the UASplatforms to be operated under this grant of exemption will nothave. (Emphasis added) 

### EquivalentLevelof Safety An equivalent level ofsafety will be achieved or exceeded because maintenance and inspections will be timelyperformed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required byEsri's Operations Manuals, the PIC will conduct a pre-flight inspection ofthe UAS and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe UASs and no flights will occur unless, and until, all flight critical components ofthe UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required byEsri's Operations Manuals, the PIC who conducts the functional test flight will make an entry inthe UAS aircraft records ofthe flight. Esri's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (includingbatteries), ground control station, hazard accessories, and spare parts. Further, Esri's Operations Manuals also include procedures to document and maintain a record ofthe UAS's maintenance, preventative maintenance, alterations, status ofreplacement /overhaul componentparts, and the total time in service ofthe UAS used under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in

7 FAADocketNo. FAA-2014-0352.

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Esri's Operations Manuals ensure that an equivalent or higher level ofsafety will be achieved. 

### PILOT-IN-COMMAND OFTHE UAS E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations Esri seeks exemption from 14 CFR § 61.113, whichrestricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure thatthe skill and competency ofany PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. In this case, while the UAS will be operated as part ofa commercial operation, they carry neither passengers nor cargo. In 

### the Grant ofExemption to Astraeus Aerial, the FAAdetermined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate.8 

### The fulfillment ofthe additional requirements for a private pilotto become qualified as a commercial pilot would not lead to any additional safety benefits for the type ofUAS operations requested inthis petition. 

### EquivalentLevelof Safety The restrictions Esri has placed on its UAS operations meet or exceedthe restrictions similarly imposed onAstraeusAerial. Esri will operate onprivate property away from persons and property not involved inthe operation. All operations will be conducted in accordance with the conditions ofthis waiver and airspace limitations specified inthe COA. In 

### addition to these flight restrictions, Esri will further ensure safe operationbyrequiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also inthe unique aspects ofUAS flight. The pilot qualification, training, and currencyrequirements inthe Operations Manuals ensure that Esri pilots are competent and proficient in the UAS they are operating. Esri'straining and qualification requirements are consistent withthose contained inprior FAA Section 333 Grants ofExemption, and will provide a higher level ofcompetency andproficiency for its pilots and will ensure at least an equivalent level ofsafety to the public.

8 ExemptionNo. 11062 (FAADocketNo. FAA-2014-0352).

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OPERATINGPARAMETERS OFTHE UAS F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness Inasmuch as there will be no airworthiness certificate issued for the UASs, Esri seeks an exemption from 14 C.P.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAAhas stated that no exemption is required for 14 C.P.R.§ 91.7(a) to the extentthat the requirements ofPart 21 are waived or found inapplicable.9

### Accordingly, Esri requests that the requirements for§ 91.7(a) be treated in accordance with SectionV(A), supra. G. 14 C.F.R. 

### § 91.9(b)(2): CivilAircraft Flight Manual in theAircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration Title 14 C.P.R.§ 91.9(b) (2) and§ 91.203(a) and (b) require the operator to carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuantto 14 C.P.R.§ 91.9(b) (2): (b) No person may operate a U.S.-registered civil aircraft- (2) For which anAirplane or Rotorcraft Flight Manual is required by § 21.5 ofthis chapter, unless there is available inthe aircraft a current approvedAirplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuantto 14 C.P.R.§**91~203(a)** 

### and (b): (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless ithas 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) ofthis 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. Given the small size and configuration ofthe UAS, itwouldbe impractical to keep airworthiness documents and other aircraft manuals on boardthe UAS because there is simplyno room and the UAS has no cabin or cockpit. As a wayto comply with the code Esri will maintain the documents withthe PIC and make them available for inspection. 

### EquivalentLevelof Safety In an FAA Office ofChiefCounsel's Opinion datedAugust 8, 2014, and prepared byDean E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircraft has access to the UAS flight
9 See Id. at 13-14,22.

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manual, registration certificate, and otherrequired documents from the ground control station from which he or she is operating the aircraft. 10 

### As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring that the pilothas access to the documents at the ground control station from whichhe or she is piloting the UAS. H. 14 C.F.R. 

### § 91.103: PreflightAction 

### Esri seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific informationbefore each flight, including information contained inthe FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extent that an FAAapproved Flight Manual is required. EquivalentLevelof Safety An 

### equivalent level ofsafety will be provided byfollowing the Esri's Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance withthe Esri's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flightprocedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoffdistance, UAperformance data, and contingency landing areas-before initiation offlight. Esri's Operations Manuals and the Manufacturer's Manual will be kept atthe ground control station and will be accessible to the PIC at all times while operatingthe UAS. I. 14 C.F.R. § 91.109(a): Flight Instruction 

### Esri seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o personmay operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, bytheir design, do not have functional dual controls. Instead, flight control is accomplished through the use ofa device that communicates with the aircraft viaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 

### C.F.R. § 91.109(a). EquivalentLevelof Safety 

### Given the size and speed ofthe UASs that Esri intends to use, an equivalent level ofsafe training can still be performed without dual controls because no pilot orpassengers are aboard the UAS, and as required bythe Esri's Operations Manuals, all persons will be a safe distance away inthe event that the UAS experiences any difficulties during flight instruction. Moreover, as required bythe Esri's Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures provided for in Esri's Operations Manuals ensure thatthe proposed UAS operations provide an equivalent or higher level ofsafety

10 Memorandum from MarkBury, FAAAssistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAAFlight Standards Service (Aug. 8, 2014); see also DocketNo. FAA-2014-0352 at 16-18.

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than that provided bythe flight instruction regulations. J. 14 C.F.R. 

### § 91.119(c): Minimum SafeAltitudes 

### Esri requests an exemption from the minimum safe altitude requirements of 14 C.F.R. §91.119(c). 11 

### Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons orproperty onthe surface," providedthat "eachperson operatingthe helicopter complies with any routes or altitudes specifically prescribed for helicopters bythe FAA." An exemption is required because the proposed UAS operation will normally need to occur below400 feet AGL. Additionally, due the nature ofthe proposed operations, the PIC and/or VO(s) mayneed to be less than 500 feet away from the UAS. EquivalentLevelof Safety Comparedto flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and giventhe lack offlammable fuel withthe above noted UASs, any risk associated with these operations is far less than those which presently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UASs, as well as the controlled location where the operations will occur. As set forth in the Operations Manuals, the UAS will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless thatperson is in a position where he or she is shielded from the UAS and any possible debris resulting from its failure. As required bythe Operations Manuals, flights will be terminated ifa nonparticipating person within 500 feet ofthe UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controllertimely has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and, operations near the PIC or VO will not present an undue hazard per § 91.119(a). Adherence to these restrictions in

11 Relieffrom§ 91.ll9(a) will not be necessary because Esri will be able to perform an emergency landing without undue hazardto persons orproperty onthe ground inthe event ofa failure. Petitioner'sproposedUAS operations will not occur over congested areas, and therefore an exemption from§ 91.119(b) will notbe necessary. See e.g., Grant ofExemptionNo. 11157 to Slugwear, Inc., dba Like on a treeAerial (FAA-2014-0534 at 15).Page 16

Esri's Operations Manuals will ensure operations canbe conducted without compromising public safety. 12 K. 14 C.F.R. § 91.121: Altimeter Settings Esri seeks an exemption from 14 C.P.R. 

### § 91.121, whichrequires a person operating an aircraft to maintain cruising altitude or flight level byreference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extentthatthe UASs do not have a barometric altimeter, butrather a GPS altitude read out. 

### EquivalentLevelof Safety The FAAhas statedthat an equivalent level ofsafety to the requirements of 14 C.P.R. §91.121 can be achieved in circumstances where: (1) the UASs will be operated below400 feet AGLor below13, (2) withinVLOS, (3) where GPS based altitude information is relayed inreal time to the operator at a ground-based on-screen display and, (4) where priorto each flight, a zero altitude initiationpoint is established for the PIC to confirm accuracy ofthe onboard GPS. 14 The UAS that Esri intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required byEsri's Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass priorto each flight operation. Like prior FAA Section 333 Grants ofExemption, the UAS Esri intends to use, and the safety mitigation procedures contained inthe Operations Manuals, both ensure that an equivalent level ofsafety or greater level will be achieved, and a Grant ofExemptionto the requirements of 

### § 191.121 is therefore appropriate. L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Esri requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states:

12 See e.g., Grant ofExemptionNo. 11138 to DouglasTrudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are presentthat can sufficientlyprotectnonparticipatingpersons from the UAor debris inthe event ofan accident, then the UAmay operate closerthan 500 feet to persons afforded such protection. The operatormust also ensure that nonparticipatingpersons remain under suchprotection. Ifa situation arises where nonparticipatingpersons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When consideringhow to immediately cease operations, the primary concern is the safety ofthose nonparticipatingpersons. In addition, the FAAfmds that operations may be conducted closer than 500 feet to vessels, vehicles and structures whenthe owner/controller ofany such vessels, vehicles or structures grants permission for the operation andthe PIC makes a safety assessment ofthe risk ofoperating closerto those objects and determines that it does notpresent anundue hazard."
13 Ifthe height ofthe structure being inspected exceeds 400 feetAGL, the UAS will notbe operated more than 100 feet above the highestpointon the structure.
14 See GrantofExemptionNo. 11062 toAstraeusAerial (FAA-20 14-0352 at 21).

### Page 17
(a) No person maybegin 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 ofintended landing and, assuming normal cruising speed

- (1) Duringthe day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. Here, the technological limitations onUAS battery power means that no meaningful flight , operations can be conducted while still maintaining a 30-minute batteryreserve. An exemption from the fuel requirements of 14 C.F.R. 

### § 91.151(a) is therefore required. Moreover, it is not Esri's intentionto fly the UASs at night. EquivalentLevelof Safety In 

### the Grant ofExemption to VDOS (ExemptionNo. 11112), the FAAdetermined that an equivalent level ofsafetyto the fuel requirements for flight inVFR conditions could be achieved by prohibitingthe PIC from beginning a UAS flight unless (considering wind and forecast weather conditions) there was enoughpowerto fly to the first intended point oflanding and, assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that the UAS batteries for the UAS provide approximately 50 minutes ofpowered flight (withpayload) and provided battery level and batterytime remaining in minutes and seconds to the PIC. 15 

### The FAA also considered the fact the UAS operating manual states: "start every flight with a fully charged battery inthe aerial vehicle", and that in the eventthat the UAS shouldrun low on power, the PIC will be alerted and can safely land theUAS as soon as possible. Like the VDOS Grant ofExemption, Esri's use ofthe UAS, combined withthe requirements ofPetitioner's Operations Manuals, ensure that an equivalent level of safety canbe achieved and in fact exceeded. Similarly, inthe Grant ofExemptionto Alan Purwin (ExemptionNo. 11161), the FAA determined that an equivalent level ofsafetyto the fuel requirements for flight in VFR conditions could be achieved byprohibitingthe PIC from beginning a flight with the UAunless (considering wind and forecast weather conditions), there was enough powerto safely fly at normal cruising speedto the intended landing point and land the UAwith 25% batterypower remaining. Esri will adhere to this limitation for its UAS flights. The UAS includes a low battery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the UAS to a ground-based-on-screen display. 16 

### As required byEsri's Operations Manuals, the PIC will promptly fly the UAS backto the home launch location or pre- determined abort location where it may safely land, while still maintaining a minimum of25%

15 Grant ofExemptionNo. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).
16 The UAS ground control station displays, the UASs position, navigationroute, tail number, altitude, heading, north seeking arrow, range to targets, calculatedtargetposition, date/time, and sensorheading and orientation relative to the UAS.

### Page 18

reserve batterypower. Esri submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined withthe requirement that flights onlybe conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and within VLOS ofthe PIC and VO(s), ensure that the proposed operation will provide an equivalent or higher level ofsafety to the public to that provided bythe regulations from which exemption is sought. 

### VI. DRUGANDALCOHOLPROGRAM 

### Esri has policies in place to ensure that no person may participate in UASs flight operations if they are under the influence ofalcohol or any drug per 14 C.F.R §91.17. 

### VII. PUBLIC INTEREST 

### The public interest will be served by granting Esri's Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed inthis Petition. Granting this Petition for Exemption helps fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act-the FAAAdministrator's assessment ofwhether certain UAS may operate safely inthe NAS before completion ofthe statutorily required rulemaking. The proposed UAS operations inthis Petition for Exemption significantly improves the safety and reduces risk ofharm, physical injury and property damage to the public at large, the property owners from whompermission was granted for use byEsri and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who maybe inthe local vicinity. Traditional methods ofinspecting and monitoring potential locations and relevant sites and facilities requires locationpersonnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neither trained nor equipped to perform, which exposes them to unnecessary risk ofseriousphysical injury from dangerous falls or otherphysical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposedto hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with identifying specific locations for potential recording sites to be used inthe end product. The use ofsmall UASs can eliminate these hazards and ultimately create a much safer method ofperforming these types of inspections creating a safer environment for the public as well as Esri employees. The use ofsmall UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in addition to flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, in the unlikely event of an accident, Esri's small batterypowered UAS presents significantly less danger to persons on the ground when compared to operations by conventional manned aircraft. 17 

### As

17 See Grant ofExemptionNo. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Mannedhelicopters conducting aerial filming can weigh 6,000pounds or more and are operatedby an onboardpilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAS will weigh less than 55 pounds with no onboardpilot or crew. The pilot and crew will beremotely located from the aircraft. The limited weight significantlyreduces the potential for harmtoparticipating and nonparticipating individuals orproperty in the event ofan incident oraccident. Risk to an on boardpilot and crew during an incident or accident is eliminated withthe use ofa UA for the aerial filmingPage 19

Esri's UAS are batterypowered, the public will also benefit from a reduction inharmful petroleum based emissions associated with conventional aircraft performing inthe same functions proposed herein. Air qualitywill naturally be improved withthe reduction offuel powered vehicles. 

### VIII. PRIVACY All UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overpropertywithpermission from the land owner/controller or authorized representative. Permission from land owner/controller orauthorized representative will be obtained for each flight to be conducted. 

### IX. FEDERALREGISTER SUMMARY Pursuantto 14 C.F.R. Part 11, the following summaryis provided for publication inthe FEDERAL REGISTER, should itbe determined thatpublication is needed: Esri seeks an exemption from the following rules inTitle 14 ofthe Code ofFederal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b). The exemptionwill enhance safetybyreducing riskto the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated withperforming equivalent survey work and aerial video productionwith conventional fixed-wing aircraft, rotorcraft, orothermethods. 

### X. CONCLUSION Esri's Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximityto airports and populated areas; operationwithin VLOS and national security. The proposed UAS operations will benefitthe public as a whole byimproving safety and reducing risk by alleviating human exposure to danger while lowering the attendant related costs for data collection. In consideration ofthe foregoing, this Petition for Exemptionprovides the FAAwithmore than adequatejustificationfor granting the requested exemptions allowing Esri to use small UASs inthe recorded production ofits product. We thank you for your prompt consideration ofour requested exemptions. Respectfully Submitted,

# ~~ Director ofOperations Attachment: Flight Operations ManualVerson 1.5 

# Unmanned Aircraft 

# Operations Manual

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Contents

Preface
..................................................................................................................................................3 2 Definitions
.............................................................................................................................................3 3 Philosophy
............................................................................................................................................4 4 Protection of Rights and Privacy
.........................................................................................................4 5 Operations
............................................................................................................................................4 5.1 Organization
.................................................................................................................................5 5.2 Safety
............................................................................................................................................7 5·3 Training
........................................................................................................................................ 8 5·4 Flight Planning
............................................................................................................................. 9 5·5 Flight Operations
.........................................................................................................................11 5.6 Logbook Entries
......................................................................................................................... 13 5·7 Maintenance
............................................................................................................................... 13 5.8 Other
........................................................................................................................................... 14 5·9 Record Keeping
.......................................................................................................................... 14 6 Checklists
............................................................................................................................................ 14 6.1 Flight Planning Checklist
............................................................................................................ 15 6.2 Pre-flight Checklist
..................................................................................................................... 16 6.3 3DR Solo Flight Operations Checklist
........................................................................................ 16 6.4 3DR Solo Emergency Checklist
.................................................................................................. 19 6.5 Post-flight Checklist
....................................................................................................................2o 7 Logbooks
............................................................................................................................................ 21 7.1 Pilot 

### IVO Logbook
...................................................................................................................... 21 7.2 Aircraft Maintenance Logbook
................................................................................................. 21 7.3 Squawk Log
................................................................................................................................ 21 8 Other Documents

...............................................................................................................................21 8.1 Property Overflight Release
...................................................................................................... 21 8.2 Vessel/vehicle/structure Release Form
..................................................................................... 21

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1 

# Preface The following procedures are intended to promote safe, efficient and lawful operation of unmanned aerial systems (UAS). Safety above all else is the primary concern for every operation, regardless of the nature ofthe flight. 

### 2 

# Definitions COA Certificate ofWaiver orAuthorization. An FAA-issued authorization to operate in a particular airspace. Contains limitations and restraints. Flight Director Designated individual with oversight responsibilities forflight operations Flight Operation A flight operation consists ofone or more flights at a single location on a single day. Non-essential Any individual without assigned duties during a UA flight. observers Operators All Esri employees involved in UAS flight operations. Includes the PIC, YO and any otheressential personnel. Operating Operating documents collectively represent Esri's UA Flight program. Documents These documents include, but are not limited to, FAA Exemption Letter, COA, Flight Operations Manual, Training Manual, UA Owner/Operators Manual and any flight operation orsafety checklists. Part 333 Waiver Authorization from the Federal Aviation Administration (Director, Flight Standards Service) to operate an unmanned aircraft. Section 333 refers to the section of Public Law 112-95 that directs the FAA Administratorto authorize UAS operations. PIC Pilot-in-Command (PIC) is a current FAA-license pilot (airline transport, commercial, private, recreational, orsport pilot). Program Designated senior Esri manager who is the business sponsor offlight Director operations Required Flight Individuals who have assigned functional orsafety responsibility for a Crew specific flight. UA Unmanned Aircraft. Pertains to any remote controlled flying platform regardless ofsize or complexity. UAS Unmanned Aircraft System. VFR Visual Flight Rules. VFR is a set of FAA defined rules regarding visibility and clearance from clouds. YFR conditions vary based on airspace. All Esri UA operations will be conducted in VFR conditions. 

### vo Visual Observers (YO) are part ofthe required flight crewfor UA operations. They serve as visual spotters to ensure that the UA avoids all hazards and operates in the area and flight path intended.

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# . esrr 3 Philosophy Esri may use Unmanned Aircraft (UA)from time-to-time to collect aerial imagery and sensor data to help improve and test Esri's software products and processes. Esri will comply with all federal, state and local laws and regulations at all times. 

# 4 Protection of Rights and Privacy UA operators will make every reasonable effortto notviolate any individual's personal privacy or invade any person's expectation of privacy when operating a UAS in all situations. Where practical, UA operators will obtain written permission before collecting imagery orvideo ofany individual. UA operators will assure thatthe protection ofcitizen's civil rights and reasonable expectations of privacy is a key component of any decision made in operatingthe UAS. PICs and VOs will be accountable for ensuring that operations of UAS have minimal intrusion upon citizens. To accomplish this primary goal, Esri will provide training for avariety of scenarios:
• When practical, the onboard camera(s) will be turned away from occupied structures to minimize inadvertent video or still images of uninvolved persons. • All video and still images will be used for Esri business only. All employees and UA operators are prohibited from sharing or releasing images publically without the written authorization the Program Director. • Operation of Esri-owned and loaned equipmentfor personal use is strictly prohibited. The use of UAS will be tightly controlled and regulated. 

# 5 Operations The policies and procedures contained in this manual are issued by authority ofthe Program Director. As such, it is an official document of Esri and is not intended to be all-inclusive, but is to be used as a supplement to Federal Aviation Regulations, Aircraft Manufacturers' manuals, directives and approved flight manual guides. This manual addresses Esri's available UAS safety and operations information as ofthe date published. Technology advancement in aerial equipment, personnel and operations changes overtime, and this establishes a requirementfor Esri's managementto systematically monitor, edit, organize and change critical parts ofthe manual and other safety and operations manuals and systems to reduce UAS flight and operations risk ofaircraftfailures or loss ofoperations. This manual will be updated as required. This manual will be reviewed, at a minimum, annually to assure it provides current and correct information. A copy ofthe manual (electronic and/or paper) will be provided to all Esri personnel having UAS flight operations responsibilities.

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## Scope This manual applies to thefollowing operations: 

### 5.1.1 U.S. Operations. The FAA regulates all UAS operations in the U.S. and its territories. All outdoorflights conducted in the U.S. or its territories will follow the limitations and policies ofthis manual. 

### 5.1.2 International Operations The policies and procedures outlined in this manual covers flights in the United States that are regulated by the Federal Aviation Administration (FAA). UAS laws and regulations vary widelyfrom country-to-country and may have local restrictions. No flights will be performed by Esri employees outside ofthe U.S. without athorough review and written flight plan approved by the Program Director. 

### 5.1.3 Indoor Flights The FAA does not regulate airspace inside ofa building. Indoorflights are exemptfrom the conditions and policies in this manual. 

## 5.2 Organization Flight crew shall be comprised ofthose personnel approved in part by the Federal Aviation Administration and Esri. Esri's UAS personnel include UAS PICs, VOs and other personnel assigned to UAS flight operations.


### 5.2.1 Personnel
5.2.1.1 Program Director. The Program Director is a senior Esri managerandbusiness sponsor offlight operations. The Program Director is responsible to provide oversight ofallflight operations andsafety programs. 5.2.1.2 FlightDirector. The Fight Directorhas overall responsiblefor flight safetypolicyand training. The Flight Directorprovides oversight ofallflight operations andapproves all flight plans. The Flight Directormust meet all ofthe requirements ofPIC below.
The UAS Flight Director is responsible forthe day-to-day supervision and management of Esri flight operations and flight personnel. The Flight Director responsibilities include:

• Maintainingall training, flight and maintenance records for each UAS, PIC, and VO as well as individual airframes. • Maintain afile for each PIC and VO which shall include copies of FAA certifications, training records, etc.

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• Maintain contactwith the FAA and be familiar with currentregulations. • Evaluate flight personnel based on flight type and need. Pilot-in-Command (PIC). All PICs must hold eitheran airline transport, commercial, private, recreational, orsport pilot certificate. The PIC must holda current FAA airman medical certificate ora valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR §61.56 in an aircraft in which the PIC is ratedon his or herpilot certificate. The PIC is responsible to understand and comply with all conditions, restraints and constraints associated with the FAA grantedWaiver and Certificate ofWaiver or Authorization. UAS PICs interacting with Air Traffic Control (ATC) shall be proficient in airtraffic communications. UAS PICs must have an understanding ofand comply with FAA and Military Regulations applicable to the airspace where the UAS will operate. The UAS PIC primary duty is to ensure the safe and effective operation ofUAS in accordance with the manufacturers' approved flight manual and FAA regulations policies and procedures. UAS PICs must remain knowledgeable ofall FAA regulations; UAS manufacturer'sflight manual and bulletins and City and State UAS policy. UAS Flight Directormaytemporarilyremove any employees and personnel or UAS PIC from flight status at anytime for any reasons including, safetyconcerns, performance, proficiency, physical condition, etc. Should removal become necessary, the person will be notified verbally and in writing ofthe reason(s) and any required corrective actions. PICs are responsible for the safety ofall personnel duringflight operations. The PIC shall terminate flight operations immediately if anyone orproperty is atrisk orifany Esri employee calls forflight operationsto stop. UAS Visual Observers (VO). VOs must hold a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a U.S. territory, a U.S. possession, orthe Federal government. VOs will communicate clearlyto the PIC any instructions required to stay clear ofconflicting traffic. VOs will receive training on rules and responsibilities described in 14 CFR §91.111, Operating Near OtherAircraft, 14 CFR §91.13, Right-of-Way Rules, cloud clearance, and inflight visibility. Visual Observers must complete communications training before communicatingwith any control tower orair traffic controller. The YO's primary responsibility is to see and avoid all other aircrafttraffic, stayclearof people, buildings, structures and obstacles. YO's may operate the UAS's equipment including the UA, cameras, sensors, and radio communications underthe direct supervision ofthe PIC.

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# esrr 5·3 Safety Esri is committed to promoting a safe and healthy workplace, including:
• Personnel will at all times protect and preventdamage to equipment, the environment and property. • Company culture ofopen reporting of all safety hazards orincidents. • The personnel will support all UAS safetytraining and awareness programs. • The Flight Directorwill conduct regular reviews ofsafety policies, procedures and practices with all personnel. • The Flight Director continuously monitors the UAS community at large to ensure that best safety practices are incorporated into the Esri UAS flight operations. • It is the duty ofevery person to contribute to the goal ofcontinued safe operations. This contribution may come in many forms and always includes operating in the safest mannerpractical and nevertaking unnecessary extreme risks. • Any safety hazards whetherprocedural, operational ormaintenance related should be identified ifpossible before an incident occurs. Any suggestions in the interestofsafety should be made directly to the Flight Director as soon as known. • Ifany UAS PICs, VOs orotherpersonnel have knowledge ofunsafe ordangerous acts committed by anyone, the UAS Flight Director is to be notified immediately so that corrective action(s) may be taken. Hazards requiring immediate attention will be brought to the attention ofthe Flight Directorverbally and without delay. • Electronic Messaging ortexting is prohibited during all flight operations. • The PIC andVO mustmaintain verbal communications at all times.

5.3.1 Alcohol and Drug Policy All flight crewmembers will comply with 14 CFR §91.17 regarding the use ofAlcohol and Drugs. No person may act as a crewmemberofa UA operation:
• Within 8 hours afterthe consumption of any alcoholic beverage; • While underthe influence of alcohol; • While using any drug that affects the person'sfaculties in any way contraryto safety; or • While having an alcohol concentration of 0.04 orgreaterin a blood or breath specimen. Alcohol concentration means grams of alcohol perdeciliter ofblood or grams ofalcohol per 210 liters ofbreath. 5.3.2 Personal Safety Equipment Flight crewmembers will dress appropriatelyfor weather and conditions for each flight. All crewmembers mustwearthefollowing duringflight operations:
• Protective eyewearthat meets ANSI Z87.1+ standards • Reflective safetyvest • Use ofsafety hat (hard hat) is encouraged, but not required

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• Use of non-flight radios orcellular phones during missions are prohibited during any flight operation unless being used as backup communications resources. 5·3·3 Operational Hazard and Incident Reports (OHIR) are unplanned safety related events, including accidents and incidents that could affect safety or become a hazard that may cause harm.

The OHOR concept provides a mechanism to report hazards and occurrences, real and perceived, to those responsible for Esri UAS operations. There is no specific formatforthe OHIR as the information provided is what is important, notthe format and should be used without hesitation to report any anticipated, current, or experienced safety hazards, oroccurrence. Reports may be submitted anonymously to the Flight Director.
• Every hazard and/or occurrence that involves UAS will be investigated with the results and corrective action taken communicated to flight personnel. The Flight Director and associated personnel will conduct the investigation underthe direction ofthe Program Director. • UAS operational hazards requiring immediate attention will be broughtto the attention ofthe PIC or Flight Director immediately. • All Esri personnel are authorized to take immediate action to correct any possible hazard or hazardous condition where an opinion or delay may result in an accident, injury or death. • All Esri employees involved in the flight crew mayterminate flight operations. The PIC will terminate flight operations immediately upon notification.


## 5·4 Training
5-4.1 The key to continued safe operations is by maintaining a professional level of competency. The first step in this process is establishing minimum qualifications and the second step involves training personnel to acceptable levels offlight operations competency.


### 5-4.2 Training Plans

Version 1.5 • All employees will have a UAS training plan on file that outlines training objectives. This training plan will be part ofan employee's training file. • Training plans will be approved by the Program Manager and Flight Director. • All UA operations will be documented and count toward an employee's personal time in operations training. • It is the employee's personal responsibility to verify theirtraining file contains all pertinent information.

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SA·3 Initial Training The PIC and VO must have completed sufficienttrainingto communicate to alerts, directives or instructions required to remain clear ofconflicting traffic. This training ata minimum shall include knowledge ofthe rules and responsibilities described in 14 CFR 91.111, Operating Near OtherAircraft; 14 CFR 91.113, Right-of-Way Rules: ExceptWaterOperations; and 14 CFR 91.155, Bask VFR WeatherMinimums; knowledge of air traffic and radio communications, including the use ofapproved ATC/pilot phraseology; and knowledge ofappropriate sections ofthe Aeronautical Information Manual.
SAA Recurrent Training Flight crew who do not have any documented training orflight time within a span of 180 days are required to perform a proficiency review by a current PIC or Flight Director. Recurrenttraining is not limited to UAS flight skills but also includes knowledge ofall pertinent UAS operations and aviation matters.


## 5·5 

## Flight Planning The PIC, VO and flight and ground personnel shall familiarize themselves with all available information concerningthe UAS flight including, butnot limited to, the weatherconditions, flight zone or area, hazards, and theflight goals. Esri voluntarily choosesto fly overpropertywith written permission from the property owneror authorized official, butmay fly overother areas when necessary. For routine operations, written approval to overfly is required. Ifwritten approval is notpractical or possible, written authorization from the Program Director is required. The PIC is responsible for ensuringthatthe flight complies with the constraints and restraints of Esri's COA. The PIC shall reviewthe airspace and becomefamiliar with any Special Use Airspace and Temporary Flight Restrictions (TFRs) in effectfor the planned flight area. Flights will not be conducted less than:
• 5 nautical miles (NM) from an airport having an operational control tower; or • 3 NM from an airportwith a published instrumentflight procedure, but not an operational tower; or • 2 NM from an airport without a published instrumentflight procedure or an operational tower; or • 2 NM from a heliportwith a published instrumentflight procedure The PIC is also responsible for ensuringthat all additional crewmembers have received the propertraining and meetthe currency requirements identified in this manual.

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PIC will ensure thatthe location for take-offand emergency landing is adequate for safe UAS flight and recovery. The take-off/landing location should be clearly marked and identifiable with electric lights, brightly colored short cones orby other appropriate methods. The PIC will identify and mark at least one alternate/emergency landing area before flight and make all crewmembers aware ofits location. PICs will ensure thatthey are aware oftheir surroundings in the eventthat an emergency landing is necessary. This includes the ability to recoverthe UAS in encumbered areas. Prior to any flight operations, theflight crewwill thoroughlyreview the plannedflight to include:
• Identification and review ofthe airspace; • Review ofTemporary Flight Restrictions (TFRs); • Detailed weatherforecast; • Review ofpotential hazards; • Review ofroles and responsibilities; • Review ofcommunication protocols; • Review ofemergency procedures; • Thorough equipment inspection; • Thorough test ofcommunications equipment; • Review ofthe flight to be conducted; The PIC will make an on location determination ofthe UAS, equipment and personnel required to perform the requested flight safely within Esri's and the FAA policies and procedures. Ifthe PIC determinesthatthe use ofthe UAS would violate safety measures, Esri policy or federal, state or local laws ordirectives then the PIC has the authority to modify the flight parameters as needed to conform. Ifthe flight is unsafe orviolates policy, theflight will be cancelled. Upon completion oftheflight, the PIC will make a full report ofthe modified flight circumstances and theirconcerns and issues associated with theflight to the Flight Director. PICs have the final decision regarding safety, Esri policy orflight rules. 5.5.1 Weather Before eachflight the Flight Director, PIC and orVO will ensurethat he/she gathers enough information to make themselvesfamiliar with the weatherconditions existing throughout the area offlight for the Flight Duration oftheflight.

Version 1.5 • The PIC shall utilize FAA approved weatherresources to obtain the latest and most currentweatherconditions.

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• When necessary, use a hand-held anemometerto better estimate the wind speed and determine if it is within the flight performance envelope ofthe UAS before flight. • Flight operations will not be conducted ifgusts exceed 75% ofthe UA rated wind limitation. • The weather conditions reported forthe operation shall be recorded in theflight log pre and postflight. • The PIC shall ensure that the flights will occurwithin VFR weather requirements. 

## 5.6 Flight Operations 5.6.1 Flight Boundaries Flights will not be conducted outside ofthe COA. No person at Esri has the authorityto authorizeflights outside ofthe COA. Information regarding flight boundaries can be found in Esri's FAA- COA and regulations regarding the use ofthe National Airspace System (NAS). Maximum flight altitude will not exceed the maximum altitude permitted by the FAA COA (400' AGL).

5.6.2 Minimum Personnel Requirements The minimum personnel required for any flight will be the UAS PIC and VO. 5.6.3 Personnel Responsibilities for Flights 5.6.3.1 The UAS PIC • The PIC is directly responsible for safety and is the final authority overthe actual flight operations ofthe UAS. • UAS PICs have final authorityto reject any flight based on personnel safety orviolation of Esri policy or FAA regulations. • No one has the authority, regardless oftheir position, to ordera PIC to conduct aflight of any type when, in the opinion ofthe PIC, the flight poses risk to personnel or is in violation of Esri Policy or FAA regulations. • PICs are responsible for compliance with this manual, Esri policy and procedures and FAA regulations. • The PIC's primary duty during aflight is to operate the UAS safely and protect all ground personnel while accomplishing the goals oftheflight. • PICs will maintain visual contactwith the UA at all times. • PICs shall avoid all obstacles that will lessen flight safety duringthe flight. • PICs shall be responsive to the requests ofthe VO in orderto accomplish the flight. • PICs shall be responsible for documentation of each flight updatingflight logs and notating postflight UAS or equipment issues.

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5.6.3.2 The UAS VO • AVOs primary duty during aflight is to have continuous eyes-on the UAS during all modes of operation allowing the PIC to maintain complete focus on the operation ofthe UAS. • VOs shall see-and-avoid any obstacle that will lessen safety during all missions. • VOs are responsible for ground safety procedures before, during and afterthe flight. • When necessary, VOs shall operate any attached systems and accessories to the UAS such as cameras orsensor arrays. • VOs shall remain alert of suspicious persons or activities on the ground and coordinate response by informingthe PIC and other security and or operations ground personnel. • VOs shall provide verbal commands and monitor UAS flight position delivering radio flight safety updates as needed. • VOs shall update and assist the PIC with safe operation alerts ofthe UAS flight as directed by the PIC. • VOs shall be responsible for assisting the PIC with completing all documentation of each flight and the updating offlight logs and other notations. 5.6.4 Use of Checklists Checklists helps to ensure effective communication and confirmation among crewmembers and to ensure that critical tasks and factors are not missed. The use of checklists is a proven method of reducing aviation accidents. Checklists do not provide complete instructions, but serve as a reminder. PICs and VOs will always use checklists for pre-flight, flight, emergency, and post-flight operations. PICs, VOs and othercrewmembers are responsible forthe safe operation of UA regardless whether atask orfactor is on the checklist. Crewmembers are encouraged to provide feedback to the Flight Director for checklist improvements. PICs and VOs will use written checklists for all flights. The completed checklist will become part ofthe flight record. 5.6.5 Pre-Flight Actions 5.6.5.1 Pre-Flight Inspection • PICs/VOs are both responsible for athorough preflight inspection ofthe UAS and other important inspection operations with regards to UAS equipment to ensure it is in an airworthy condition. • Before and after each flight the PIC, VO and flight operations personnel shall conduct a thorough inspection ofthe UAS in accordance with UAS instructions contained in the manufacturers user manual. • PIC, YO and flight operations personnel shall perform all pre-flight operations needed such as UAS to radio calibration and of bench testing processes to help insure a safe flight when deployed. • Any issues found that could place the flight or ground personnel, the UAS orsystems and equipment in jeopardy of safe operations, shall be documented and resolved prior to flight. • A pre-flight checklist will be utilized priorto each flight.
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• Any system and or physical equipment issues that cannot be resolved through additional inspection and on-site testing may change the UAS's airworthy and ready status. • Any system and or physical equipment issues that may have an impact on safety ofthe flight will change the UAS's airworthy and ready status to "Not Ready for Fight." All flight and pre-flight issues with personnel orequipment will be resolved before flight. 5.6.6 Post-Flight Actions The primary tasks following aflight are to documentthe flight and prepare forthe nextflight. Maintaining accurate records is important as part ofan overall risk-reduction effort. Following every flight, flight crews will:
• Complete the post-Flight checklist • Complete the flight log. • Log flight crew hours. • Update squawk log if required. See section 5.8.1 

## 5·7 Logbook Entries The PIC and VOs will log each flight following the flight. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). PIC and VO logbooks must include, but are not limited to:
• Date/time offlight, • Flight duration, • Location, • Weather conditions, • Purpose offlight, and • Names ofother required crewmembers. 

## 5.8 Maintenance Although there are few parts on the UAthat need servicing, it is necessary thatthe manufacturer's maintenance schedule is followed and documented. This includes the replacement ofdamaged parts or software/firmware upgrades. Software and firmware updates will be retained as part ofthe permanent maintenance record. Any issues that arise during maintenance that cannot be resolved by routine methods shall be forwarded to the manufacturerforfurthertechnical support and repair. Any repairs performed by the manufactureror othercompany will also be noted in the maintenance log. 

### 5.8.1 Squawk Log The Squawk Log contains a running list ofany discrepancies or problems with a UA or associated communications equipment. It is used to familiarize the flight crew with

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problems that have occurred in the past so thattheywill be better prepared to deal with the problem should it reoccur. The log will contain:
• Date/time discovered, • Name ofthe person who discovered the problem, • Description ofthe problem • Conditions underwhich the problem occurred, and • Resolution, ifany. Examples might include unusual vibrations, controller issues, or radio problems. 

## 5·9 Other UAS PICs/VOs will ensure that no items are attached to the UAS priorto flight thatare not required for safe operation and to complete the flight goal. 

## 5.1

# o Record Keeping Maintain all aircraftflight and maintenance recordsfor a minimum oftwo years after Esri disposes ofthe aircraft. Retain flight, maintenance and crewtraining records indefinitely for any aircraft involved in an accidentthatcauses personal orpropertydamage otherthan damage to the UA itself. Destruction ofany logbooks orflight records requires the written approval ofthe Program Director. 

# 6 Checklists

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6.1 Flight Planning Checklist (conducted before departingforflight area) 

## 0 Written permission from property owner or authorized official 

## 0 Current published airspace charts 

## 0 Verify operational area on phone/tablet, applicable 

## D Cache maps, ifapplicable 

## 0 No plannedTemporary Flight Restrictions (TFRs) 

## 0 PIC ("Pilot in Command") is current 

## 0 VOs ("Visual Observers") are current 

## 0 Weatherforecast is within limits 

## 0 Review communications plan 

## 0 Review safety procedures 

## 0 Written flight plan 

## 0 >5 miles from airports with a control tower 

## 0 > 2 miles from airports with a published IFR procedure 

## 0 > 2 miles from any Class Bairspace 

## 0 >2 miles from any restricted airspace orTFR 

## 0 Batteries are charged 

## D UA 

## 0 Camera 

## 0 Tablet/phone/display 

## 0 Inspect UA 

## 0 Damage 

### ILoose Components 

## 0 Cracks in UA orprops 

## 0 Verify controllerfunction 

## 0 Inspectcommunications equipment 

## 0 Batteries charged with spares 

## 0 Verify operation 

## 0 Headsets, if applicable 

## 0 Avionics Radio check, ifapplicable 

## 0 Inspect First Aid Kit

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## 0 Tampering/use 

## D Expiration dates 

## 0 Missing items

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6.2 Pre-flight Checklist 

## 0 Weather is within limits 

## 0 Launch time is after sunrise and a minimum of30 minutes before sunset 

## D Inspectflight area for hazards 

## 0 People, animals, power lines, trees, buildings, towers, antennas 

## 0 No people within approx. 500' ofany part ofthe planned flight 

## 0 Assess RF interference 

## 0 WI-FI Networks 

## D GPS Signal Strength • Minimum of4 satellites acquired 

## D Conduct pre-flight briefing 

## D All flight crew present 

## D Review planned flight 

## 0 Review contingency 

### Itermination plan 

## 0 Review emergency procedures 

## 0 Conduct UA inspection 

## 0 Ensure rotors are firmly attached and move freely 

## 0 Verify geo-fencing limits and maximum altitude are set 

## 0 Identify level and safe take offsurface 

## 0 Place orange safety cones approx. 15' from takeoff/landing spot • Minimum of4 cones • Clear of Field of Debris 

## 0 Battery 

## D Charged 

## 0 Installed 

## D Communications Equipment 

## 0 Antenna down and away at 20° angle • Perpendicular with solo in flight 

## 0 Crew radios on • Radio check with each VO and PIC 

## 0 Aviation radio on, ifapplicable • Radio check 

## 0 Camera checklist 

## 0 Lens clean 

## 0 Mount is secure 

## D Wi-Fioff 

## 0 Control wire connected to UA 

## 0 UAPowerOn 

## 0 Calibrate Sensors 

## 0 Minimum of 5 Satellites acquired • Coned safety area clear ofall crew 

## 0 Camera On

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## D Controller On 

## D App Connected 

## D Reassess for hazards

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6.3 3DR Solo Flight Operations Checklist (conducted immediatelybeforeTakeoff) 

## 0 PIC: Yell "Clear" 

## D PIC: Ensure takeoff path is clear 

## 0 Controller: Hold "Fly"to start rotors 

## 0 All: Observe forvibrations 

## 0 Controller: Verify data receptions, check for anomalies 

## 0 Controller: Hold "Fly" to take off 

## 0 All: Reassess forvibrations In Flight 

## 0 Controller: hands on controller 

## 0 All: Eyes on UA at all times 

## 0 Climb to safe altitude 

## 0 Maintain safe distance ( est. 500') from people 

## D Yield to all other a/c o Maintain watch for police, fire/rescue, and med-evac helicopters 

## D Remain below400' at all times 

## D Land NOT LESS THAN 25% remaining battery Landing 

## D Ensure LZ is clear 

## D Verify "Flyto home" flight path is clear 

## D On final approach o Hoverfor 5seconds at 10feet o Confirm LZ is clear o Slowly descentto land 

## D Shutdown rotors (pause or hold A+B+Pause) Shutdown 

## D AC Power offand remove battery 

## D Controller off 

## D Disconnect camera 

## D CameraOff

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6.4 3DR Solo Emergency Checklist

Loss oforientation 

## D Climb to safe altitude 

## D Reestablish orientation 

## D If unable to regain orientation, Fly-to-home and land.
Loss ofWiFi Signal 

## D UAwill return to home 

## D When signal is re-established, press 11Fiy" to regain control Loss ofControl 

## D Press Pause 

## D Switch to Manual 

## D Press Return to Home 

## D Hold 11Fiy" to land Emergency Termination 

## D Press A+B+PAUSE (motors will stop, UAwill fall to ground) Crash 

## D Do not approach UA until rotors have stopped 

## D Priorities: Life/safety, property, environment 

## D Call 911 if needed

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6.5 Post-flight Checklist (Completed following each flight) 

## 0 Ifanotherflight is planned: o Replace Battery o Restart Pre-flight checklist 

## 0 Remove battery 

## 0 Remove rotors before handling UA 

## 0 Wipe down UA 

## 0 Contact tower, ifneeded 

## 0 Debriefwith VOs 

## 0 Complete flight log 

## D PackupUA o All equipment present and secured o Case closed and locked o Remove any trash ordebris 

## 0 Recharge batteries 

## 0 Ifanotherflight is planned: o Replace Battery o Restart Pre-flight checklist 

## 0 Remove battery 

## 0 Remove rotors before handling UA 

## 0 Wipe down UA 

## 0 Contact tower, ifneeded 

## 0 Debriefwith VOs 

## D Complete flight log 

## 0 Pack up UA o All equipment present and secured o Case closed and locked o Remove any trash ordebris 

## 0 Recharge batteries

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# 7 Logbooks 7.1 Pilot

# IVO Logbook TBD 

### 7.2 

## Aircraft Maintenance Logbook TBD 

## 7·3 Squawk Log TBD 

# 8 Other Documents 8.1 

## Property Overflight Release TBD 

## 8.2 Vessel/vehicle/structure Release Form TBD

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