1

May 8, 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12
- 140 1200 New Jersey

Ave., SE Washington, DC 20590 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Madam or Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Marathon Petroleum Corporation LP (“MPC ”) , petitions for an exemption from the Federal Aviation Regulations (“FARs”) listed below:

 14 C.F.R. Part 21 Subpart H  Sections of 14 C.F.R. Part 45 (specifically §§45. 23 , 45.27 , and 45.29 )  Sections of 14 C.F.R. Part 61 (specifically §§61 .3 , 61. 2 3 )  Sections of 14 C.F.R. Part 91 (specifically § §91.7 (a) , 91.9 , 91.109 (a) , 91.119 , 91.121 , 91.151 (b) , 91 .203 (a) & (b) , 91.401 , 91.403 , 91.405 , 91.407 , 91.409 , and 91.417 ). The requested exemption would authorize MPC’s Ohio Refining Division (“ Canton, OH Refinery”) to operate the unmanned aircraft system (“UAS ”)

– DJI Phantom 2 Vision+ Quadcopter (“the Phantom”)

– to support emergency response efforts within the Canton refinery and surrounding Stark County, OH. These emergency response operations will be subject to strict safety requirements set forth by MPC to ensure an equivalent level of safety is met to align with current regulations governing the use of manned aircraft. A detailed overview of the exemption requests and equivalent safety initiatives can be found in Appendix A of this document. **Background on Marathon Petroleum Corporation LP**  MPC , headquartered in Findlay, OH , is one of the largest petroleum product refiners, marketers and transporters in the United States. MPC is the nation’s fourth
- largest refiner and the largest refiner in the Midwest. MPC’s refining, marketing and transportation operations are concentrated primarily in the Midwest, Southeast, Northeast and Gulf Coast regions of the U.S. MPC is a leader in the Health, Environment, Safety and Security (“HES&S”) field within the oil and gas industry
. The company has the highest regard for the health and safety of the employees, contractors and neighboring communities. In addition, MPC i s committed to Environmental S tewardship by c onducting business practices with the goal of minimizing the company’s environmental impact. MPC is an American Chemistry Council “Responsible Care”2

company. Responsible Care companies are committed to worker safety. They are nearly

s ix times safer than the average of the U.S. manufacturing sector as a whole, and three times as safe as the business of chemistry overall. Responsible Care companies have reduced process safety incidents by

55 percent over the past 19 ye ars. **Specifications of the DJI Phantom 2 Vision** **+ Quadcopter**  **( “**  **the Phantom ”** **)**

 Li ghtweight, multi
- functional integrated aircraft and camera (approximately 5 lbs
. )
 Electric Powered
 FPV HD Video Camera
 Camera remote
- control by DJIVI SION APP
 Firmware installed to prevent UAS from entering airport airspace and government buildings
 Range Extender increases Wi
-Fi distance to 300m
 Anti
-vibration camera platform with single axis stabilization
 Low
-voltage protection
 Virtual Radar aircraft locator on mobile device
 Range o f camera tilt options
 Multiple, continuous and timed capture options
 HD Video Recording
 Max Flight Speed 15m/s **Application of the Phantom for the Canton Refinery**  UAS is becoming a desirable tool to assist in emergency response efforts , and MPC’s Canton Refinery must leverage the new technology to the company and community ’s advantage
. The Canton Refinery

provides resources and is a major partner in the Stark County Incident Management Team. This team consists of several local Fire Chi efs and Emergency M anagers, including the Canton Refinery F ire Chief. The team responds to emergencies throughout the region to provide Incident Command System (ICS ) assistance to agencies as needed
. The Canton Refinery

F ire Department mobile Command Unit #3 responds with every Incident Management Assistance Team (IMAT) call and serves as the c ommand post for the team and other emergency

response government agencies. MPC will use the Phantom to provide an aerial image to assist in rapid mitigation of emergencies within the Canton Refinery and surrounding Stark County
. Emergency response activities include but are not limited to

– fire, rescue and hazardous materials (HAZMAT) incidents. The aerial camera will be operated from the mobile Command Unit #3.3

Emergency

Response Incident Command can use the Phantom to gain better situational awareness during an emergency. F irefighters could use the Phantom to scout fires, including looking for hotspots in structure fires. The Phantom video capabilities could also assist in hazmat release response by

giving emergency

responders a better idea of the source or the release, and the extent and magnitude of a spill. By monitoring hazardous incidents remotely, emergency response personnel are less likely to be exposed to unseen dangers. Once the Phantom is in the air, it can provide real
-time data back to emergency response personnel. This data can assist the incident commander in making decisions by detailing the current status of the incident, where potential hazard expansion may o ccur, and risks to personnel and property. As a result, the intelligence gathered from the Phantom will ensure cost effective mitigation options are assessed. The nearest major airport, Akron

– Canton Regional Airport, is located in Green, OH within Summit County. The airport is approximately 12 miles from the Canton Refinery
. Maps of the Canton Refinery and Stark County

are provided in Appendix C. **Standard Operating Procedures and Safety Programs**  MPC’s Canton Refinery

requires any potential users to obtain initial safe operations training and require annual refresher training. The Canton Refinery requires training on all operation systems as well as safe operation of the unit based on the manufacturer’s recommendations and FAA regulations prior to anyone operating the unit. Additional requirements include a detailed safety review of hazards while operating over an emergency scene. A pre
- flight checklist and standard operating procedures are included in Appendix D. **Conclusion** MPC is a leader in the HES&S field within the oil and gas industry. By allowing MPC’s Canton, OH Refinery

to utilize the DJIPhantom 2 Vision+ for emergency response purposes, this will improve safety

within the refinery

and the surrounding Stark County. The Phantom will enhance hazard mitigation efforts by providing better situational awareness during an incident. In addition, the Phantom will be utilized to support the Stark County Incident Management Team, adding another resource to help improve safety in the community
. To ensure an equivalent level of safety is maintained during operation of the Phantom, MPC will require employees to be t rained before deploying the unit. In addition Standard Operating Procedures will be developed and reviewed on an annual basis. As UAS technology

continues to evolve, it will be essential for MPC to adapt and utilize these innovations to support HES&S e fforts across the company. By developing robust operating4

procedures and comprehensive training programs, combined with the overall benefit derived from deplo ying the UAS for emergency response, MPC can adequately justify the request for exemptions from the FAA pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11
. Regards,

**Keith Robson Corporate Safety, Security and Emergency Preparedness Manager**  **Marathon Petroleum Corporation LP**  **539 S. Main Street**  **Findlay, OH 45840 Office: 419** **- 421**  **- 2148**  **Mobile: 419 -** **619 -** **4866 kcrobson@marathonpetroleum.com** 5



### Appendix A: **Exemption Requests and Equivalent Level of Safety Initiatives**  **14 C.F.R Part 21, Subpart H: Airworthiness Certificates**  **14 C .**  **F .**  **R .**  **§ 91.203(a)(1)** Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 14 C.F.R. § 91.203(a)
. Given the size of the Phantom, being very

light weight (approximately 5 p ounds) , and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act 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 UAS involved. An analysis of these different criteria demonstrates that the Phantom, operating without an airworthiness certificate under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate
. MPC has developed safety procedures that will be enforced before bringing the Phantom into service. The Phantom will be operated in the presence of private and local municipality emergency responders, including police officers
. MPC has develop ed safety procedures , including pre- flight checklist that will be followed before operating the Phantom. **14 C.F.R.**  **§ §**  **45.23, 45.27, and**  **45.29 :**  **Display of M arks;**  **Location of Marks; Nonfixed -** **Wing A** **ircraft ;**  **Size of M arks**  These regulations provide that each aircraft must display an "N" (denoting U.S. registration) and the aircraft's registration number in letters at least 12 inches high for rotorcraft
. Itisalso required that e ach operator of a rotorcraft must display markings on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. Given the size of the Phantom ( 13.7 inches diagonal) , and small size of the airframe and components , this requirement is imposs ible to match
. The equivalent level of safety will be achieved by having the markings of the MPC Canton Refinery F ire Department on the aircraft. In addition, the aircraft will not be operated at altitudes that exceed 400 feet, and the aircraft will stay in visual line of sight by all personnel operating the aircraft, therefore being identifiable at all times. **14 C .**  **F .**  **R .**  **§ 61.3**  **: Requirements for Certificates, Ratings and A uthorizations** 6

The regulation provides that no person may s erve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person: (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot license issued by that country

may be used
. Given the safety

f eatures of the Phantom, including the firmware installed that prevents the Phantom from entering airport airspace or near government buildings , MPC proposes that operators of the Phantom should not be required to hold a commercial or private pilot certification. Instead, operators will be required to adhere to the Phantom safety standards set by MPC, and keep the Phantom in visual line of sight (VLOS) at all times. **14 C .**  **F .**  **R .**  **§61.23 Medical C**  **ertifi cates: Requirement and D**  **uration** The regulation referenced above provide s that a person: (1) Must hold a first
- class medical certificate:  When exercising the pilot
- in
- command privileges of an airline transport pilot certificate;  When exercising the second
-in
- command privileges of an airline transport pilot certificate in a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or  When serving as a required pilot flight crew member in an operation conducted under part 121 of this chapter if the pilot has reached his or her 60th birthday
. (2) Must hold at least a second class medical certificate when exercising:  Second
-in
- command privileges of an airline transport pilot certificate in part 121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or  Privileges of a commercial pilot certificate The lightweight Phantom will not carry a p ilot or passengers. The operator on the ground in control of the Phantom will be a member of an emergency response team. The unmanned flights support emergency response operations
. These flights provide safety b enefits while reducing health and safety risk to humans
. Emergency response team members have their own medical surveillance requirements to ensure they are fit for duty (see 29 C.F.R 1910.120(f))
. Operation of the Phantom by

a ground opera

tor without the medical certificate described above does not pose any s afety risk to the operator or to the public. MPC will allow operation of the Phantom only by emergency

response team members who have valid driver’s license to provide a level of safety equivalent to the requirements of the Federal Aviation Administration in 14 C.F.R. 61.23
. **14 C.F.R.**  **§ 91.7(a):**  **Civil A** **ircraft A** **irworthiness** This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing operation of the Phantom without an airworthiness certificate, no standard will exist for airworthiness of the Phantom
. MPC will ensure that the Phantom operators are emergency responders also trained to use and adhere to the user manual provided by the manufacturer of the Phantom. An equivalent level of safety will be7

achieved by

insuring compliance with the Phantom user manual for flight operations
. Please note that this is not the first company to seek and obtain an exemption from the FAA to operate the same UAS model
. The FAA has previously granted the following company an exemption to operate the Phantom:

 Saratoga Aerial Video and Photo , Exemption No. 11218 , Regulatory Docket No. FAA−2014−0953 **14 C.F.R.**  **§ 91.**  **9: Civil A** **ircraft F** **light M** **anual, M** **arking, and P** **lacard R** **equirements.** This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. MPC assume s that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. MPC requests an exemption to this requirement since the aircraft is not only too small to carry documentation, but the documentation would not be available to the crew, as there is no flight crew on board. MPC will achieve an equivalent level of safety by keeping a hard copy of the Phantom user manual with the operator during all flights, and with the Phantom when not in flight. **14 C.F.R.**  **§ 91.109**  **(a) :**  **Flight Instruction** The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." Flight instruction will be accomplished through a training program as required by MPC’s safety procedures. The Phantom does not have dual controls, but has a trainer port on the remote control that can be connected to the computer to simulate flight and practice skills. Through safety procedures, on- ground training and flight simulation, MPC will achieve an equivalent level of safety for operator flight instruction
. **14 C**  **. F**  **. R** **. §**  **91.119: Minimum Safe**  **Altitudes** The regulation provides that over sparsely populated areas , the aircraft cannot be operated closer than 500 feet to any

p erson, vessel, vehicle, or structure. The Phantom will be utilized for emergency

response purposes around MPC’s refineries, terminals, pipelines, and other structures . Start County emergency response incident command may use it near other structures, but only during closely

supervised training and actual emergency response operations. Therefore, MPC cannot comply

with this requirement. MPC seeks an exemption to this requirement to allow t he Phantom to be flown closer than 500 feet to a person, vessel, vehicle, or structure during emergency

response training and actual emergency response incidents . The equivalent level of safety will be achieved because the Phantom will only f ly over are as outside MPC’s property by obtaining the proper permits
. Before every flight within MPC airspace , an MPC operator or official will assess the working area, and advise the emergency response team regarding safety hazards in the area. Where Stark County emergency response8

officials request MPC to use the Phantom outside of MPC’s property, the emergency responders will ensure that landowners and the persons who may b e on the ground in the flight area are briefed of the expected route of flight and the associated risks to persons and property on the ground. Due to the small size of the Phantom, the material with which the Phantom is built and its specific safety

procedures (firmware) , the hazard to persons, vessels, vehicles, and structures is small and not c omparable to hazards to persons or property p osed by larger manned aircraft
. In addition, t

he Phantom will most likely not be operated over congested areas as the general population will be evacuated during major incidents. **14 C .**  **F .**  **R .**  **91.121**

**– Altimeter S**  **ettings** This section requires that e ach person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may b e, by reference to an altimeter that is set, when operating below 18,000 feet MSL to:  The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;  If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an a ppropriate availa

ble station;  Inthe case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. To provide an equivalent level of safety, MPC will need to keep the Phantom in VLOS at all times. In addition, MPC can utilize the radar function provided with the Phantom to help restrict the aircraft altitude during operation
. Keeping the Phantom air operations to less than 400 feet in altitude greatly

reduc es the risk as compared to other larger aircraft operating at higher altitudes. **14 C.F.R.**  **§ 91.151(** **b ):**  **Fuel Requirements**  **for Flight**  **in Visual Flight Rules (** **VFR )**  **Conditions** The regulation provides that no person may b egin a flight in a rotorcraft 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, to fly after that for at least 20 minutes. Given the area of operation for the Phantom, MPC believes that an equivalent level of safety i s already achieved due to the fact that MPC will ensure the battery i s properly charged before each use. In addition, the Phantom has a max flight time of 25 minutes, and this time limit and battery life will be monitored by

the pilot in command and other ground personnel. **14 C.F.R. § 91.203 (a) & (b)**  **: Carrying Civil Aircraft Certification and Registration**  This regulation provides as follows:

 No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate.  No person may operate a civil aircraft unless the airworthiness certificate required by9

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 Phantom is too small, has insufficient payload capacity, and no place to carry certification and registration documents or to display them on the aircraft
. In addition, there is no pilot on board the aircraft. To obtain an equivalent level of safety and meet the intent of 91.203, MPC proposes that documents deemed appropriate for this aircraft by the FAA (e.g. the operating manual) will be co
located with the operator and available for insp ection upon request. In order to identify the aircraft, the Canton Refinery Fire Department can place a logo on the Phantom in order to identify the aircraft and its owner
. **14 C .**  **F .**  **R .**  **Subpart E (91.401 -**  **91.417) -**  **Maintenance, Preventive Maintenance, and Alterations**  The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy c ondition, including compliance with P arts 39 and 43. P aragraphs 91.407 and 91.409 require the aircraft to be "approved for return to service by a p erson authorized under 43.7" after maintenance and inspection. Section 91.409 requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417 requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43
. MPC proposes that the maintenance of the Phantom will be accomplished by the Canton Refinery Fire Department according to the Phantom user manual. An equivalent level of safety will be achieved because the Phantom is small in size, it is not a complex mechanical device and does not carry any external payload other than the camera . Moreover, the Canton Refinery F ire Department will be most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition to ensure an equivalent level of safety is met . Inaddition, maintenance could also be performed by

experienced professionals at a Remote C ontrol Vehicle repair shop (or similar) that are trained to perform maintenance. Emergency response team members or other qualified persons authorized by MPC will inspect the Phantom to ensure it is capable of operations before returning it to service after maintenance. These measures provide an equivalent level of safety as the FAA regulations specified above
.10



### Appendix B: Summary to **publish in the Federal Register**  Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Marathon Petroleum Corporation LP (“MPC”) , petitions for an exemption from the Federal Aviation Regulations listed below:

 14 C.F.R. Part 21 Subpart H  Sections o f 14 C.F.R. Part 45 (specifically §§45.23, 45.27, and 45.29)  Sections of 14 C.F.R. Part 61 (specifically §§61.3, 61.23)  Sections of 14 C.F.R. Part 91 (specifically § §91.7 (a) , 91.9, 91.109 (a) , 91.119, 91.121, 91.151 (b) , 91.203 (a) & (b) , 91.401, 91.403 , 91.405, 91.407, 91.409, and 91.417). The requested exemption would authorize MPC’s Ohio Refining Division (“ Canton, OH Refinery”) to operate the unmanned aircraft system (“UAS”)

– DJI Phantom 2+ Quadcopter (“The Phantom”)

– to support emergency respons e efforts within the refinery and surrounding Stark County, OH. MPC will use the Phantom to provide an aerial image to assist in rapid mitigation of emergencies , including but not limited to

– fire, rescue and hazardous materials (HAZMAT) incidents. These emergency

response operations will be subject to strict safety requirements set forth by MPC to ensure an equivalent level of safety is met to align with current regulations governing the use of manned aircraft
.11



### Appendix C: Maps of **the Marathon Petroleum Canton Refinery and Stark**  **County** Please see below for maps of the Canton Refinery and surrounding Stark County
. As indicated in Map A, t he tallest refining unit is the Continuous Catalyst Reformer (“CCR”) at approximately 250 ft. Map B shows the location of the Canton Refinery within Stark County
. Inaddition, the nearest major airport, Akron

– Canton Regional Airport, is indicated on Map B. This airport is approximately

12 miles from the Canton Refinery
.

**Map A**

**– MPC**  **Canton, OH Refinery**12 **Map B -**  **Stark County, OH**13



### Appendix D: Pre**- Flight Checklist and Standard Operating Procedures**  **Marathon Petroleum Canton Refinery Fire Department UAS Pre -** **Flight Checklist**  **Crew Member**  **Responsibilities Pilot** **-** Responsible for turning on all equipment, and making sure the UAS is prepped and ready to operate . **Co -** **Pilot -**  Responsible for all checklists, and ensures all equipment is functioning. **Crew Member** **-** Maintains flight logs, gathers extra equipment needed for pilot/co
-pilot, monitors radios, accesses any other items needed to fly
.
**Pre -** **Flight Checklist**  **- Incident**  Crew members will confer with the Incident Commander (“IC ”) as to what type of incident the drone is to be utilized at. Depending on the incident, the UAS may be utilized in an emergent fashion, or it may be utilized in a non- emergent fashion, where there is more time to plan the flight, and log it. **Weather Conditions** **-** Verify the weather conditions are adequate for flight operations
. (i.e. Wind, Time of Day, Daylight, Precipitation, Area of Flight) **Flight Plan** **-** Crew members will prepare a flight plan for the flight. The area, direction, altitude, speed, and any other factors will be recorded by either the co -pilot, or the crew member. The pilot’s main job is to operate and control the aircraft
. **Objectives -**  Depending on the type of incident, the objective of the flight may vary. The aircraft could be utilized as a homing beacon of sorts, for rescue personnel to find and rescue a missing or trapped person.14

**Pre -** **Flight Checklist**

**– The P**  **hantom** The pilot and co -pilot will check the Phantom out to ensure the following are attached properly and functioning properly. 1. Landing Gear 2. Camera/Gimb al 3. Propeller Guards 4. Propellers 5. Controller and equipment 6. iPhone/iPad Verify there are multiple batteries charged and ready with the Phantom, also ensure Canton Refinery F ire Department stickers are placed on the Phantom. If a flight plan is to be used, all members will be briefed on the path, as well as the home spot, which will be marked by a landing spot. The Phantom will be calibrated to land at that spot if any emergencies occur. The Phantom battery will alert when it gets to the Point of Safe Return (“PSR”)
. The Phantom will automatically return when reaching this point.
**Flight Checklist**  **- Preparing**  **To Operate the**  **Phantom** When the pilot is ready to operate the Phantom , complete the following checklist: **Action Complete**  **Not Complete**  **Com ments**  1. Turn on GPS Tracker (an automatic email will be sent to the UAS flight duration folder) 2. Turn on Wi
-Fi Extender, and connect phone to be used to Wi
-Fi signal. 3. Turn on Controller 4. Turn on the Phantom 5. Verify the Phantom responds appropriately to controls 6. Verify iPhone/iPad is connected to the Phantom application system The pilot and co -pilot mobile phone should be showing all the flight parameters of the Phantom , as well as the live video feed. After completing these procedures, the pilot c an begin the mission.15

**Marathon Petroleum Canton Refinery**  **Fire Department**  **Unmanned Aircraft**  **System Standard**  **Operating Guidelines**  **Scope of**  **Operation:** These standard operating guidelines will provide for the safety of Marathon Petroleum Canton Fire Fighters when operating an unmanned aircraft s ystem **(UAS). I.**  **Fire fighters**  **will not**  **deploy and**  **fly UAS**  **until:** A. Preflight checklist has been completed, weather conditions evaluated and approved by IC. B. A minimum of two firefighters have had both pilot and co -pilot training for UAS
. C. An event emergency or non- emergency arises in which the UAS is needed. D. A written list is completed that outlines scope of flight and reasoning for flight (to support Stark County emergency response efforts only) E. The proper permits are obtained and notifications are made when using the UAS outside of MPC property

to support Stark County

emergency

response efforts
. This includes, but not limited to:  Ensuring private landowners and the persons who may be on the ground in the flight area are briefed of the expected route of flight and the associated risks to persons and property on the ground.  Ensuring all airports within 5 miles are briefed of the flight area, and permission is obtained to operate the UAS. **II. All**  **personnel engaged**  **in UAS**  **operations shall**  **record at**  **minimum but**  **not limited**  **to:** A. Time B. Date C. Operational Personnel D. Unit number E. Flight plan F. Altitudes G. Distance Flown H. Weather Conditions/ Visibility I. Wind Direction/Speed J. Take off, Departure points K. Pre/Post Battery Life **III. Takeoff,**  **in flight,**  **and landing:**  A. Pilot and Co
-pilot must agree on objectives, flight plan, and capabilities of UAS. B. Memory cards must be blanked prior to take off. C. Scene survey for takeoff paying special attention to overhead obstructions. D. Height restrictions are to not exceed 400 feet and shall be determined16 prior to flight. E. Distance restrictions shall be no further than visual line of sight from Pilot, Co
pilot or Spotter. F. If staffing permits, a third trained person will be recording updates to flight log as well as maintaining communication with the staging officer. G. In the event of a search and rescue mission, if the Pilot, Co
-pilot, or anyone reviewing the aerial footage spots a clue a "Hands Off'' will be called and further investigation will ensue. H. Person responsible with documentation of flight log will note times, locations, and what was seen to further facilitate the search. I. Prior to landing, the UAS Pilot and Co
-pilot will agree on landing zone (“LZ”). J. Immediately after landing UAS the crew will replace batteries, upload aerial footage, and get UAS back into working order. K. A flight log with minimum requirements will be completed with every takeoff and every landing. Ifthe UAS is landing for a battery switch a new flight log needs to be started.
**IV. Conditions**  **in which**  **flight may**  **be grounded**  A. Any weather deemed hazardous by the IC. B. Winds in excess of 20mph. C. Insufficient man power. D. Insufficient number of qualified Pilots and Co
-pilots. E. Temperatures under 32 degrees Fahrenheit F. Visibility is too low hindering Co
-pilots line of sight of UAS. G. Any reason deemed unsafe by IC or other emergency response personnel.17

**UAS Crew**  **Member** 1. Ensure all equipment is available and pull equipment as requested by pilot/co
pilot 2. Check weather reports for a. Temperature b. Wind speed and direction c. Humidity 3. Monitor radios to be used 4. Secure charging spot for batteries 5. Form perimeter at least 10 feet around launch site 6. Announce over radio when UAS is taking flight 7. Announce anything found over the radio 8. Announce when the UAS is at "bingo" fuel, and is returning to the helispot 9. Gather extra batteries/equipment as needed while the UAS is on the ground 10. When the UAS is ready to fly, return to step 6 11. Post flight, assist with breaking down UAS/equipment, and finish flight logs18

**Flight Crew**  **- Em** **ergency S**  **ituation UAS**  **pre -** **flight** 1. Determine fly/no
- fly 2. Set up landing zone 3. Check UAS a. Remove gimb al/camera cover b. Attach propellers c. Insert battery 4. Turn on GPS tracker and attach to UAS 5. Turn on Wi
- Fi 6. Turn on controller 7. Turn on UAS 8. Contact ground crew when ready 9. Ground crew will call out a. Battery % of UAS battery b. Battery %of Wi
- Fi c. Number of satellites d. Flight direction e. Weather 10. Flight crew will call out "UAS flying" 11. Upon return, flight crew will a. Turnoff UAS b. Replace battery and SD card c. Return to step 719

**Ground Crew** 
- **Emergency Situation** 1. Unpack equipment to be used 2. Start iPad
- open applications 3. Verify weather conditions 4. Connect Wi
- Fi to iPad 5. Callout a. Battery % of i. UAS battery ii. Wi
- Fi battery b. Satellites c. Weather 6. When flight is started a. Video record flight b. Monitor iPad for i. Battery % ii. Satellites iii. Location, direction, speed of UAS c. Call out to flight crew any adjustments needed20

**Flight Crew**  **UAS Pre** **- Flight**  1. Determine fly/no
- fly based upon conditions 2. Check UAS a. Propellers/propeller guards b. Landing gear c. Gimb al/camera covers removed d. Gimb al/camera free
- spinning when off e. GPS tracker and battery secured 3. Check controller a. GPS unit charged b. Batteries inserted in controller c. S1and S2 switches both up d. Both control sticks return to neutral 4. Find suitable "helispot" for UAS a. Check for obstructions/hazards in the vicinity of the flight area **UAS Flight Checklist**  1. Turn on GPS tracker 2. Turn on Wi
- Fi extender 3. Turn on controller 4. Turn on UAS 5. Connect to device, and verify "home point" 6. Create flight path if applicable 7. Notify members that the UAS is going airborne

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