• esrr 

February 4, 2016 

U.S. Department of Transportation Docket 

Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition for an Exemption Pursuant to Section 333 of the FAA Modernization and 

Reform Act of2012 

Dear Sir or Madam: 

Pursuant to Section 3 3 3 of the FAA Modernization and Reform Act of 2012 ("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 below to allow 

commercial operation of small unmanned aerial systems ("UAS") for the purpose of conducting 

aerial imaging, videography, topographic mapping, photogrammetry and remote sensing. 

The operating conditions and limitations set forth below, which Esri is willing to accept, are 

identical to those in the exemption granted to other similarly situated UAS operators, including, 

but not limited to Aeryon Labs, Inc. The only difference in this request is that Esri is proposing 

the 3DR Solo UAS; however, the FAA has also granted an exemption request previously for use 

of the 3DR Solo for commercial purposes. Since the 3DR Solo specified in this 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 in the Federal Register or ask for public comment. For these reasons, this petition for an 

exemption meets the requirements for summary processing. 

This petition for exemption is made based on information 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.com 
Page2 

For your convenience, this Petition is organized as follows: 

I. Description of Petitioner 

II. Description of Proposed Operations 

A. Aerial Imaging, Videography, Topographic Mapping, Photogrammetry and 

Remote Sensing 

III. Relevant Statutory Authority 

IV. Esri's Proposed UAS Operations Meet the Requirements of Section 333 of 

the Reform Act 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manuals 

V. Regulations from Which Exemption is Requested 

A. 14 C.F.R. Part 21, Subpart H -Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1) 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking 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): Civil Aircraft Airworthiness 

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

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

Registration 

H. 14 C.F.R. § 91.103: Preflight Action 

I. 14 C.F.R. § 91.109(a): Flight Instruction 

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

K. 14 C.F.R. § 91.121: Altimeter Settings 

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

Vl. Drug and Alcohol Program 

VII. Public Interest 

VIII. Privacy 

IX. Federal Register 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 staff and extensive network of business 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 of the 200 largest 

cities in the United States, more than two-thirds of Fortune 500 companies, more than 24,000 state 

and local governments worldwide, hundreds of U.S. government organizations including DoD, IC, 

and federal civil agencies, and many others in dozens of industries. Private ownership, a zero-debt 

policy, and a firm commitment to fulfilling the needs of our customers all help Esri maintain its 

position as the world leader in GIS software. 

As a socially conscious business, we are proud that our technology 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 of Imagery and Remote Sensing 

Environmental Systems Research Institute, Inc. 

380 New York Street 

Redlands, CA 923 73 

USA 

Phone: (909) 793-2853, Extension 1406 

E-mail: ljordan@esri.com 

II. DESCRIPTION OF PROPOSED OPERATION 

Esri seeks an exemption pursuant to Section 3 3 3 of the Reform Act to operate small, 

commercially-produced, consumer Unmanned Aircraft (UA) to collect imagery, video and 

mapping data to be used in the development and testing of Esri software. All U AS operations will 

occur under controlled conditions on where Esri has received documented permission to operate 

from the landowner, controller or authorized representative. The proposed UAS operations will be 

conducted in accordance with the conditions and limitations of this Petition for Exemption and 

Esri's Operations Manuals. As detailed in Esri's Operations Manuals, all UAS operations will be 

limited to daytime VFR conditions in accordance to an approved Certificate of Waiver 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. 
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III. RELEvANT STATUTORY AUTHORITY 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the 

FAA Modernization and Reform Act of2012 ("Reform Act"). Congress has directed the FAA 

"to safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 ofthe Reform Act, the FAAAdministrator is to permit UASs 

to operate in the National Airspace Systems ("NAS") where it is safe to do so based on the 

following considerations: 

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

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

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

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and 

§ § 44 702 - 44 716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety 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 OF THE REFORM ACT 

The small UAS operations proposed by Esri as noted above in this Petition for Exemption 

qualify for expedited approval pursuant to Section 3 3 3 of the Reform Act as each of the statutory 

criteria and relevant factors are satisfied. 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

A Grant of Exemption is appropriate for operations conducted using the UASs due to their size 

weight, speed, and operational capability. 

• Similar UAS to that proposed by Esri have been approved for use in prior Section 

333 Grants of Exemption from the FAA. 

• The UAS weighs less than 55 pounds, including payload 

• The UAS will not be flown at a ground speed in excess of 87 knots. The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. 
Page 5 

• Altitude information will be generated by equipment onboard the UAS as 

specified using GPS triangulation, digitally encoded barometric altimeter, radio 

altimeter, or any combination thereof. This information will be transmitted to the pilot 

via telemetric data feed. 

• The UAS will have system redundancies and independent functionality to ensure 

the overall safety and predictability of the system. If connection to the remote 

control or ground control station is lost, failsafe systems will permit the UASs to 

return to a predetermined location and safely land without injury or damage. 

• The radio frequencies used for operations and control of the 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. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would 

likely exceed 6,000 pounds depending on payload. The difference in weight between the UAS 

and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event of an 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 necessary to safely and successfully perform the 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 of operational limitations and conditions that 

Esri will adhere to, and which will ensure an equivalent or higher level of safety to operations 

conducted under current regulatory guidelines: 

1. The UAS weighs less than 55 pounds, with payload. 

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 prior to operation. 

3. All UASs operated under the Grant of Exemption will comply with 14 CFR part 48 

pertaining to the registration and marking requirements for small unmanned aircraft. 

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in 

Command ("PIC") of the UAS, and one or more Visual Observers ("VO") as 

necessary to safely conduct the mission. 
Page 6 

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, or the Federal government. The 

PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate. 

6. The UAS shall be operated within visual line of sight ("VLOS") of the PIC and VO 

at all times. The PIC must use human vision unaided by any device other than 

corrective lenses, as specified on the 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 or texting will not be permitted during flight operations. 

9. The additional requirements identified in the Grant of Exemption 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. If a discrepancy 

exists between the conditions and limitations in the Grant of Exemption and Esri's 

Operations Manuals, the conditions and limitations in the Grant of Exemption shall 

take precedence and will be followed. Otherwise, Esri shall follow the procedures 

outlined in their Operations Manuals. 

10. Esri may update or revise its Operations Manuals. Revisions will be tracked and a 

revised copy of the Manual will be provided to the Administrator upon request. Esri 

will also present an updated and revised Operations Manuals if it petitions for 

extension or amendment to its Grant of Exemption. If an update or revision would 

affect the basis upon which the FAA grants the exemption, Esri will seek an 

amendment to its Grant of Exemption. Esri will contact the FAA's UAS Integration 

Office (AFS-80) if questions arise regarding updates or revisions to the operating 

documents. 

11. Esri Operations Manuals and its Grant of Exemption 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. Maximum total 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 of no more than 400 feet above ground level 

("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 other than the PIC, VO, operator trainees or essential persons), 
Page 7 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAS and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UAS, flight operations must cease immediately 

and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue 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 of 200 feet unless specifically authorized in the 

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 in the 

relevant sections of the operating documents as well as equipment updates. The PIC 

will not operate any UAS ifthe inspection reveals a condition that affects the safe 

operation of the UAS until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. The ground control station shall be 

included in the preflight inspection. All maintenance and alternations will be properly 

documented in the 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 in the UAS records, including total time in 

service, description of maintenance accomplished, date completed and the signature 

of the 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 of a flight critical component) 
Page 8 

must timely 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 in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and UAS record entry shall be included in the 

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 product updates. 

21. Prior to the operation, a Mission Plan will be created in accordance with the 

requirements on Esri's Operations Manuals. 

22. Esri will obtain Certificate of Waiver or Authorization, otherwise known as a 

"COA," prior to conducting any operations under this Grant of Exemption. 

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. If the UAS loses communication with the PIC, it will have the capability to safely 

return to a pre-determined location within the operational area and land safely. 

25. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the 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 of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. 

27. Operations shall occur during daytime VFR Meteorological Conditions; flights under 

special visual flight rules ("SVFR") will not be conducted. 

28. The UAS shall remain clear and yield the right of way 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 not be operated by the 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 Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

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

the Act, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. 3 

Esri seeks an exemption from several interrelated provisions ofTitle 14 of the Code of Federal 
Page 9 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting 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 of safety better than or equal to the rules from which 

exemption is sought. 4 

UNMANNED AIRCRAFT SYSTEM 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. 

§91.203(a)(l) 

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met and in point of fact 

exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines that there 

are some characteristics of the chosen U AS that fail to meet the requirements of the Reform Act, 

an exemption is requested. 

Equivalent Level of Safety 

Esri's use of the UAS is safe when taking into account its size, weight, speed, and operational 

capability. As set forth in the description of proposed operations in Section IV(A), the UAS 

weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess 

of 87 knots. Additionally, the UAS carries neither pilots nor passengers, carries no explosive 

materials or flammable liquid fuels, or other elements identified by the Department of Homeland 

Security as being prohibitive. 

Operations conducted under this exemption will be closely controlled and monitored by the PIC 

operator and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. In all cases, operation ofthe UAS under the proposed 

conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an 

airworthiness certificate. Lastly, the UASs do not need a means 

3 49 U.S.C. § 44701 (f) (authorizing the grant of exemptions from requirements of regulations prescribed pursuant to 

Sections 4470l(a) and (b) and Sections 44702- 44716). 

4 14 C.F.R § 11.81 (e), which requires a petition for exemption to include: The reasons why granting the exemption 

would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that 

provided by the rule from which you seek exemption. 

5 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22). 
Page 10 

to communicate with other aircraft or ATC, because those capabilities will be solely possessed by 

the PIC and VO, who are not onboard the UAS. 6 

B. 14 C.F.R. Part 27 Airworthiness 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 extent that 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 in the 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 identification requirements 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 person may operate a U.S.-registered civil aircraft unless that aircraft 

is identified in accordance with Part 45 of this 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 on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, 

the words "limited," "restricted," "light-sport, "experimental," or 

"provisional," as applicable. 

• 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally 

on both surfaces of the cabin, fuselage, boom, or tail the marks required by 

§ 45.23. 

6 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13). 
Page 11 

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the 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 

Equivalent Level of Safety 

All UAS operated by Esri will comply with 14 CFR part 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 in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) 

(stating that each owner or operator of an aircraft "[ s ]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS platforms to be operated under this grant of exemption will not have. (Emphasis added) 

Equivalent Level of Safety 

An equivalent level of safety will be achieved or exceeded because maintenance and inspections 

will be timely performed in accordance with the Manufacturer's Manual and any required 

manufacturer Safety or Service Bulletins. Further, as required by Esri 's Operations Manuals, the 

PIC will conduct a pre-flight inspection of the UAS and all associated equipment to account for 

all discrepancies and/or inoperable components. Maintenance will be performed and verified to 

address any conditions potentially affecting safe operation of the UASs and no flights will occur 

unless, and until, all flight critical components of the UAS have been found to be airworthy and 

in a condition safe for operation. A functional test flight will be conducted following the 

replacement of any flight-critical components. As required by Esri's Operations Manuals, the 

PIC who conducts the functional test flight will make an entry in the UAS aircraft records of the 

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 (including batteries), 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 of replacement 

/overhaul component parts, and the total time in service of the UAS used under this Grant of 

Exemption. As a whole, the maintenance and inspection procedures required in 

7FAADocketNo. FAA-2014-0352. 
Page 12 

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

PILOT-IN-COMMAND OF THE UAS 

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 

Esri seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical 

certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches 

the airspace in which the PIC will be operating, as well as requiring certifications if the private 

pilot is carrying passengers or cargo for hire. In this case, while the U AS will be operated as part 

of a commercial operation, they carry neither passengers nor cargo. In the Grant of Exemption 

to Astraeus Aerial, the FAA determined that the unique characteristics of U AS operation outside 

of controlled 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 

of the additional requirements for a private pilot to become qualified as a commercial pilot 

would not lead to any additional safety benefits for the type ofUAS operations requested in this 

petition. 

Equivalent Level of Safety 

The restrictions Esri has placed on its UAS operations meet or exceed the restrictions similarly 

imposed on Astraeus Aerial. Esri will operate on private property away from persons and 

property not involved in the operation. All operations will be conducted in accordance with the 

conditions ofthis waiver and airspace limitations specified in the COA. 

In addition to these flight restrictions, Esri will further ensure safe operation by requiring that 

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all 

aircraft operators but also in the unique aspects of UAS flight. The pilot qualification, training, 

and currency requirements in the Operations Manuals ensure that Esri pilots are competent and 

proficient in the UAS they are operating. Esri'straining and qualification requirements are 

consistent with those contained in prior FAA Section 333 Grants of Exemption, and will provide 

a higher level of competency and proficiency for its pilots and will ensure at least an equivalent 

level of safety to the public. 

8 Exemption No. 11062 (FAA Docket No. FAA-2014-0352). 
Page 13 

OPERATING PARAMETERS OF THE UAS 

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Inasmuch as there will be no airworthiness certificate issued for the U ASs, 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 FAA has stated that no exemption is required for 14 C.P.R.§ 91.7(a) to the 

extent that the requirements of Part 21 are waived or found inapplicable. 9 Accordingly, Esri 

requests that the requirements for§ 91.7(a) be treated in accordance with Section V(A), supra. 

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

§ 91.203(a) and (b): Carrying Civil Aircraft 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. Pursuant to 14 C.P.R.§ 91.9(b) (2): 

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

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination 

thereof. 

Pursuant to 14 C.P.R.§ 91~203(a) and (b): 

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

within it the following: 

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

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

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

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

Given the small size and configuration of the UAS, it would be impractical to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and the 

UAS has no cabin or cockpit. As a way to comply with the code Esri will maintain the 

documents with the PIC and make them available for inspection. 

Equivalent Level of Safety 

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean 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 if the pilot ofthe unmanned aircraft has access to the UAS flight 

9 See Id. at 13-14,22. 
Page 14 

manual, registration certificate, and other required documents from the ground control station 

from which he or she is operating the aircraft. 10 As this FAA Office of Chief Counsel Opinion 

clarifies, the intent of the rule is to ensure the pilot has access to these key documents during 

flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has 

access to the documents at the ground control station from which he or she is piloting the UAS. 

H. 14 C.F.R. § 91.103: Preflight Action 

Esri seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA-approved 

Flight Manual on board the aircraft. While the PIC will be familiar with all information 

necessary to safely conduct the flight, an exemption is requested to the extent that an FAAapproved Flight Manual is required. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Esri's Operations Manuals and 

the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any 

defects or inoperable components in accordance with the Esri 's Operations Manuals, including 

checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also 

be required to review weather, flight requirements, battery charge, landing and takeoff distance, 

UAperformance data, and contingency landing areas-before initiation of flight. Esri's 

Operations Manuals and the Manufacturer's Manual will be kept at the ground control station 

and will be accessible to the PIC at all times while operating the 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 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. Accordingly, an exemption will be required for the flight instruction 

requirements of 14 C.F.R. § 91.109(a). 

Equivalent Level of Safety 

Given the size and speed ofthe UASs that Esri intends to use, an equivalent level of safe training 

can still be performed without dual controls because no pilot or passengers are aboard the UAS, 

and as required by the Esri 's Operations Manuals, all persons will be a safe distance away in the 

event that the UAS experiences any difficulties during flight instruction. Moreover, as required 

by the 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 that the proposed UAS operations provide an equivalent or higher level of safety 

10 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, 

to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18. 
Page 15 

than that provided by the flight instruction regulations. 

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

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 or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

An exemption is required because the proposed UAS operation will normally need to occur 

below 400 feet AGL. Additionally, due the nature of the proposed operations, the PIC and/or 

VO(s) may need to be less than 500 feet away from the UAS. 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with the above noted UASs, any risk 

associated with these operations is far less than those which presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the 

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 of at least 

500 feet from any nonparticipating persons, unless that person is in a position where he or she is 

shielded from the UAS and any possible debris resulting from its failure. As required by the 

Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet of the 

UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from 

vehicles or structures unless the property owner/controller timely has granted permission and the 

PIC has made a safety assessment of the risk of operating 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 Relief from§ 91.ll9(a) will not be necessary because Esri will be able to perform an emergency landing without 

undue hazard to persons or property on the ground in the event of a failure. Petitioner's proposed UAS operations 

will not occur over congested areas, and therefore an exemption from§ 91.119(b) will not be necessary. See e.g., 

Grant of Exemption No. 11157 to Slugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15). 
Page 16 

Esri's Operations Manuals will ensure operations can be 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, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of 

the departure airport or barometric pressure. An exemption is required to the extent that the UASs 

do not have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety to the requirements of 14 C.P.R. §91.121 

can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or 

below13, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the 

operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude 

initiation point is established for the PIC to confirm accuracy of the onboard GPS. 14 

The UAS that Esri intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by Esri 's Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 

Grants of Exemption, the U AS Esri intends to use, and the safety mitigation procedures 

contained in the Operations Manuals, both ensure that an equivalent level of safety or greater 

level will be achieved, and a Grant of Exemption to 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 ofExemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are 

present that can sufficiently protect nonparticipating persons from the U A or debris in the event of an accident, then 

the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that 

nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease immediately. When considering how to 

immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the 

FAA fmds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the 

owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a 

safety assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard." 

13 If the height of the structure being inspected exceeds 400 feet AG L, the U AS will not be operated more than 100 

feet above the highest point on the structure. 

14 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-20 14-0352 at 21 ). 
Page 17 

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or 

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

Here, the technological limitations on UAS battery power means that no meaningful flight , 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption 

from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Moreover, it is not 

Esri's intention to fly the UASs at night. 

Equivalent Level of Safety 

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved 

by prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast 

weather conditions) there was enough power to 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 of powered flight (with payload) and provided battery level and battery time 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 in the aerial vehicle", and that in 

the event that the UAS should run low on power, the PIC will be alerted and can safely land theUAS as soon as possible. Like the VDOS Grant of Exemption, Esri's use of the UAS, combined 

with the requirements of Petitioner's Operations Manuals, ensure that an equivalent level of 

safety can be achieved and in fact exceeded. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA 

determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions 

could be achieved by prohibiting the PIC from beginning a flight with the UA unless 

(considering wind and forecast weather conditions), there was enough power to safely fly at 

normal cruising speed to the intended landing point and land the UA with 25% battery power 

remaining. Esri will adhere to this limitation for its U AS flights. 

The UAS includes a low battery warning system and the amount of battery reserve power 

remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from 

the UAS to a ground-based-on-screen display. 16 As required by Esri's Operations Manuals, the 

PIC will promptly fly the UAS back to the home launch location or pre- determined abort 

location where it may safely land, while still maintaining a minimum of 25% 

15 Grant ofExemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

16 The UAS ground control station displays, the UASs position, navigation route, tail number, altitude, heading, 

north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and orientation 

relative to the UAS. 
Page 18 

reserve battery power. Esri submits that the procedures requiring flights to be safely terminated 

once the batteries fall below 25% capacity, combined with the requirement that flights only be 

conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and within 

VLOS of the PIC and VO(s), ensure that the proposed operation will provide an equivalent or 

higher level of safety to the public to that provided by the regulations from which exemption is 

sought. 

VI. DRUG AND ALCOHOL PROGRAM 

Esri has policies in place to ensure that no person may participate in UASs flight operations if 

they are under the influence of alcohol 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 in this Petition. Granting this Petition for 

Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform 

Act-the FAA Administrator's assessment of whether certain UAS may operate safely in the 

NAS before completion of the statutorily required rulemaking. 

The proposed UAS operations in this Petition for Exemption significantly improves the safety 

and reduces risk of harm, physical injury and property damage to the public at large, the 

property owners from whom permission was granted for use by Esri and abutting properties, 

staff of Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations and 

all those who may be in the local vicinity. Traditional methods of inspecting and monitoring 

potential locations and relevant sites and facilities requires location personnel 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 of serious physical injury from dangerous falls or other physical mishaps. 

Moreover, inspectors/surveyors are often unnecessarily exposed to hazardous conditions, unsafe 

environments, culturally tense situations and other hazards associated with identifying specific 

locations for potential recording sites to be used in the end product. The use of small UASs can 

eliminate these hazards and ultimately create a much safer method of performing these types of 

inspections creating a safer environment for the public as well as Esri employees. 

The use of small U AS also enhances safety and reduces risk to the surrounding public because, 

unlike manned aircraft weighing thousands of pounds, 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 battery powered UAS presents significantly less danger to persons on 

the ground when compared to operations by conventional manned aircraft. 17 As 

17 See Grant ofExemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting 

aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard 

crewmembers, as necessary. The petitioner's UAS will weigh less than 55 pounds with no onboard pilot or crew. 

The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential 

for harm to participating and nonparticipating individuals or property in the event of an incident or accident. Risk 

to an on board pilot and crew during an incident or accident is eliminated with the use of a U A for the aerial filming 
Page 19 

Esri's UAS are battery powered, the public will also benefit from a reduction in harmful petroleum 

based emissions associated with conventional aircraft performing in the same functions proposed 

herein. Air quality will naturally be improved with the reduction of fuel 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 over property with permission from the land 

owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL 

REGISTER, should it be determined that publication is needed: Esri seeks an exemption from the 

following rules in Title 14 of the Code of Federal 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 exemption will enhance safety by reducing risk to the aircraft crew, production crew, general 

public, property owners and city structures from the substantial hazards associated with performing 

equivalent survey work and aerial video production with conventional fixed-wing aircraft, rotorcraft, 

or other methods. 

X. CONCLUSION 

Esri's Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of2012 

which includes weight; speed; operating capabilities; proximity to airports and populated areas; 

operation within VLOS and national security. The proposed UAS operations will benefit the public as a 

whole by improving safety and reducing risk by alleviating human exposure to danger while lowering 

the attendant related costs for data collection. In consideration of the foregoing, this Petition for 

Exemption provides the FAA with more than adequate justification for granting the requested 

exemptions allowing Esri to use small UASs in the recorded production of its product. 

We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted, 

~~ Director of Operations 

Attachment: Flight Operations Manual 
Verson 1.5 

Unmanned 

Aircraft 

Operations 

Manual 

February 2016 
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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 I VO 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 

Version 1.5 2 February 2016 
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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 of the flight. 

2 Definitions 

COA Certificate of Waiver or Authorization. An FAA-issued authorization to 

operate in a particular airspace. Contains limitations and restraints. 

Flight Director Designated individual with oversight responsibilities for flight operations 

Flight Operation A flight operation consists of one 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 other essential 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 or safety 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 Administrator to 

authorize UAS operations. 

PIC Pilot-in-Command (PIC) is a current FAA-license pilot (airline transport, 

commercial, private, recreational, or sport pilot). 

Program Designated senior Esri manager who is the business sponsor of flight 

Director operations 

Required Flight Individuals who have assigned functional or safety responsibility for a 

Crew specific flight. 

UA Unmanned Aircraft. Pertains to any remote controlled flying platform 

regardless of size 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 of the required flight crew for 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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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 effort to not violate 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 or video of any individual. 

UA operators will assure that the protection of citizen's civil rights and reasonable expectations of 

privacy is a key component of any decision made in operating the 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 a variety 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 equipment for 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 of the 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 of the date 

published. Technology advancement in aerial equipment, personnel and operations changes 

over time, and this establishes a requirement for Esri's management to systematically monitor, 

edit, organize and change critical parts of the manual and other safety and operations manuals 

and systems to reduce UAS flight and operations risk of aircraft failures or loss of operations. 

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 of the manual (electronic and/or 

paper) will be provided to all Esri personnel having UAS flight operations responsibilities. 

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5.1 Scope 

This manual applies to the following operations: 

5.1.1 U.S. Operations. 

The FAA regulates all UAS operations in the U.S. and its territories. All outdoor flights 

conducted in the U.S. or its territories will follow the limitations and policies of this 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 widely from country-to-country and may have local 

restrictions. No flights will be performed by Esri employees outside of the U.S. 

without a thorough review and written flight plan approved by the Program Director. 

5.1.3 Indoor Flights 

The FAA does not regulate airspace inside of a building. Indoor flights are exempt from the 

conditions and policies in this manual. 

5.2 Organization 

Flight crew shall be comprised of those 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 manager and business sponsor of flight operations. The 

Program Director is responsible to provide oversight of all flight operations and safety 

programs. 

5.2.1.2 Flight Director. 

The Fight Director has overall responsible for flight safety policy and training. The Flight 

Director provides oversight of all flight operations and approves all flight plans. The Flight 

Director must meet all of the requirements of PIC below. 

The UAS Flight Director is responsible for the day-to-day supervision and management of 

Esri flight operations and flight personnel. The Flight Director responsibilities include: 

• Maintaining all training, flight and maintenance records for each UAS, PIC, and VO as 

well as individual airframes. 

• Maintain a file for each PIC and VO which shall include copies of FAA certifications, 

training records, etc. 

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• Maintain contact with the FAA and be familiar with current regulations. 

• Evaluate flight personnel based on flight type and need. 

Pilot-in-Command (PIC). 

All PICs must hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC must 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, 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 rated on his or her pilot certificate. 

The PIC is responsible to understand and comply with all conditions, restraints and 

constraints associated with the FAA granted Waiver and Certificate of Waiver or 

Authorization. 

UAS PICs interacting with Air Traffic Control (ATC) shall be proficient in air traffic 

communications. UAS PICs must have an understanding of and 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 of UAS in 

accordance with the manufacturers' approved flight manual and FAA regulations policies 

and procedures. UAS PICs must remain knowledgeable of all FAA regulations; UAS 

manufacturer's flight manual and bulletins and City and State UAS policy. 

UAS Flight Director may temporarily remove any employees and personnel or UAS PIC from 

flight status at any time for any reasons including, safety concerns, performance, 

proficiency, physical condition, etc. Should removal become necessary, the person will be 

notified verbally and in writing of the reason(s) and any required corrective actions. 

PICs are responsible for the safety of all personnel during flight operations. The PIC shall 

terminate flight operations immediately if anyone or property is at risk or if any Esri 

employee calls for flight operations to stop. 

UAS Visual Observers (VO). VOs must hold a valid U.S. driver's license issued by a state, the 

District of Columbia, Puerto Rico, a U.S. territory, a U.S. possession, or the Federal 

government. 

VOs will communicate clearly to the PIC any instructions required to stay clear of conflicting 

traffic. VOs will receive training on rules and responsibilities described in 14 CFR §91.111, 

Operating Near Other Aircraft, 14 CFR §91.13, Right-of-Way Rules, cloud clearance, and inflight visibility. Visual Observers must complete communications training before 

communicating with any control tower or air traffic controller. 

The YO's primary responsibility is to see and avoid all other aircraft traffic, stay clear of 

people, buildings, structures and obstacles. 

YO's may operate the UAS's equipment including the UA, cameras, sensors, and radio 

communications under the direct supervision of the PIC. 

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5·3 Safety 

Esri is committed to promoting a safe and healthy workplace, including: 

• Personnel will at all times protect and prevent damage to equipment, the environment 

and property. 

• Company culture of open reporting of all safety hazards or incidents. 

• The personnel will support all UAS safety training and awareness programs. 

• The Flight Director will conduct regular reviews of safety 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 of every person to contribute to the goal of continued safe operations. This 

contribution may come in many forms and always includes operating in the safest 

manner practical and never taking unnecessary extreme risks. 

• Any safety hazards whether procedural, operational or maintenance related should be 

identified if possible before an incident occurs. Any suggestions in the interest of safety 

should be made directly to the Flight Director as soon as known. 

• If any UAS PICs, VOs or other personnel have knowledge of unsafe or dangerous 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 of the Flight Director verbally and without delay. 

• Electronic Messaging or texting is prohibited during all flight operations. 

• The PIC and VO must maintain 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 of Alcohol and Drugs. 

No person may act as a crewmember of a UA operation: 

• Within 8 hours after the consumption of any alcoholic beverage; 

• While under the influence of alcohol; 

• While using any drug that affects the person's faculties in any way contrary to safety; 

or 

• While having an alcohol concentration of 0.04 or greater in a blood or breath 

specimen. Alcohol concentration means grams of alcohol per deciliter of blood or 

grams of alcohol per 210 liters of breath. 

5.3.2 Personal Safety Equipment 

Flight crewmembers will dress appropriately for weather and conditions for each flight. All 

crewmembers must wear the following during flight operations: 

• Protective eyewear that meets ANSI Z87.1+ standards 

• Reflective safety vest 

• Use of safety hat (hard hat) is encouraged, but not required 

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• Use of non-flight radios or cellular 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 format for the OHIR as the information provided is what is important, 

not the format and should be used without hesitation to report any anticipated, current, or 

experienced safety hazards, or occurrence. 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 under the direction 

of the Program Director. 

• UAS operational hazards requiring immediate attention will be brought to the 

attention of the 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 may terminate 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 of flight 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 of an 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 their training file contains all 

pertinent information. 

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SA·3 Initial Training 

The PIC and VO must have completed sufficient training to communicate to alerts, directives 

or instructions required to remain clear of conflicting traffic. This training at a minimum shall 

include knowledge ofthe rules and responsibilities described in 14 CFR 91.111, Operating Near 

Other Aircraft; 14 CFR 91.113, Right-of-Way Rules: Except Water Operations; and 14 CFR 91.155, 

Bask VFR Weather Minimums; knowledge of air traffic and radio communications, including 

the use of approved ATC/pilot phraseology; and knowledge of appropriate sections of the 

Aeronautical Information Manual. 

SAA Recurrent Training 

Flight crew who do not have any documented training or flight time within a span of 

180 days are required to perform a proficiency review by a current PIC or Flight 

Director. 

Recurrent training is not limited to UAS flight skills but also includes knowledge of all 

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 concerning the UAS flight including, but not limited to, the weather conditions, 

flight zone or area, hazards, and the flight goals. 

Esri voluntarily chooses to fly over property with written permission from the property 

owner or authorized official, but may fly over other areas when necessary. For routine 

operations, written approval to overfly is required. If written approval is not practical or 

possible, written authorization from the Program Director is required. 

The PIC is responsible for ensuring that the flight complies with the constraints and restraints 

of Esri's COA. The PIC shall review the airspace and become familiar with any Special Use 

Airspace and Temporary Flight Restrictions (TFRs) in effect for 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 airport with a published instrument flight procedure, but not an 

operational tower; or 

• 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or 

• 2 NM from a heliport with a published instrument flight procedure 

The PIC is also responsible for ensuring that all additional crewmembers have received the 

proper training and meet the currency requirements identified in this manual. 

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PIC will ensure that the location for take-off and 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 or by other appropriate methods. 

The PIC will identify and mark at least one alternate/emergency landing area before flight and 

make all crewmembers aware of its location. 

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

landing is necessary. This includes the ability to recover the UAS in encumbered areas. 

Prior to any flight operations, the flight crew will thoroughly review the planned flight to 

include: 

• Identification and review of the airspace; 

• Review of Temporary Flight Restrictions (TFRs ); 

• Detailed weather forecast; 

• Review of potential hazards; 

• Review of roles and responsibilities; 

• Review of communication protocols; 

• Review of emergency procedures; 

• Thorough equipment inspection; 

• Thorough test of communications equipment; 

• Review of the flight to be conducted; 

The PIC will make an on location determination of the UAS, equipment and personnel 

required to perform the requested flight safely within Esri's and the FAA policies and 

procedures. 

If the PIC determines that the use of the UAS would violate safety measures, Esri policy or 

federal, state or local laws or directives then the PIC has the authority to modify the flight 

parameters as needed to conform. If the flight is unsafe or violates policy, the flight will be 

cancelled. Upon completion of the flight, the PIC will make a full report of the modified 

flight circumstances and their concerns and issues associated with the flight to the Flight 

Director. 

PICs have the final decision regarding safety, Esri policy or flight rules. 

5.5.1 Weather 

Before each flight the Flight Director, PIC and or VO will ensure that he/she gathers enough 

information to make themselves familiar with the weather conditions existing throughout 

the area of flight for the Flight Duration of the flight. 

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• The PIC shall utilize FAA approved weather resources to obtain the latest and most 

current weather conditions. 

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• When necessary, use a hand-held anemometer to better estimate the wind speed 

and determine if it is within the flight performance envelope of the UAS before flight. 

• Flight operations will not be conducted if gusts exceed 75% of the UA rated wind 

limitation. 

• The weather conditions reported for the operation shall be recorded in the flight log 

pre and post flight. 

• The PIC shall ensure that the flights will occur within VFR weather requirements. 

5.6 Flight Operations 

5.6.1 Flight Boundaries 

Flights will not be conducted outside of the COA. No person at Esri has the authority to 

authorize flights outside of the COA. 

Information regarding flight boundaries can be found in Esri's FAA- COA and regulations 

regarding the use of the 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 over the actual flight 

operations of the UAS. 

• UAS PICs have final authority to reject any flight based on personnel safety or violation of Esri 

policy or FAA regulations. 

• No one has the authority, regardless of their position, to order a PIC to conduct a flight of 

any type when, in the opinion of the 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 a flight is to operate the UAS safely and protect all ground 

personnel while accomplishing the goals of the flight. 

• PICs will maintain visual contact with the UA at all times. 

• PICs shall avoid all obstacles that will lessen flight safety during the flight. 

• PICs shall be responsive to the requests of the VO in order to accomplish the flight. 

• PICs shall be responsible for documentation of each flight updating flight logs and notating 

post flight UAS or equipment issues. 

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5.6.3.2 The UAS VO 

• AVOs primary duty during a flight is to have continuous eyes-on the UAS during all modes of 

operation allowing the PIC to maintain complete focus on the operation of the 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 after the flight. 

• When necessary, VOs shall operate any attached systems and accessories to the UAS such as 

cameras or sensor arrays. 

• VOs shall remain alert of suspicious persons or activities on the ground and coordinate 

response by informing the 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 of the 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 of flight 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 other crewmembers are responsible for the safe operation of UA regardless 

whether a task or factor 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 of the flight record. 

5.6.5 Pre-Flight Actions 

5.6.5.1 Pre-Flight Inspection 

• PICs/VOs are both responsible for a thorough preflight inspection of the 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 of the 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 or systems 

and equipment in jeopardy of safe operations, shall be documented and resolved prior 

to flight. 

• A pre-flight checklist will be utilized prior to 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 of the 

flight will change the UAS's airworthy and ready status to "Not Ready for Fight." All 

flight and pre-flight issues with personnel or equipment will be resolved before flight. 

5.6.6 Post-Flight Actions 

The primary tasks following a flight are to document the flight and prepare for the next flight. 

Maintaining accurate records is important as part of an 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 of flight, 

• Flight duration, 

• Location, 

• Weather conditions, 

• Purpose of flight, and 

• Names of other required crewmembers. 

5.8 Maintenance 

Although there are few parts on the UA that need servicing, it is necessary that the 

manufacturer's maintenance schedule is followed and documented. This includes the 

replacement of damaged parts or software/firmware upgrades. 

Software and firmware updates will be retained as part of the permanent maintenance record. 

Any issues that arise during maintenance that cannot be resolved by routine methods shall be 

forwarded to the manufacturer for further technical support and repair. Any repairs 

performed by the manufacturer or other company will also be noted in the maintenance log. 

5.8.1 Squawk Log 

The Squawk Log contains a running list of any 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 that they will be better prepared to deal with the 

problem should it reoccur. The log will contain: 

• Date/time discovered, 

• Name of the person who discovered the problem, 

• Description of the problem 

• Conditions under which the problem occurred, and 

• Resolution, if any. 

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 prior to flight that are not 

required for safe operation and to complete the flight goal. 

5.1 o Record Keeping 

Maintain all aircraft flight and maintenance records for a minimum of two years after Esri 

disposes of the aircraft. 

Retain flight, maintenance and crew training records indefinitely for any aircraft involved in an 

accident that causes personal or property damage other than damage to the UA itself. 

Destruction of any logbooks or flight records requires the written approval of the Program 

Director. 

6 Checklists 

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6.1 Flight Planning Checklist 

(conducted before departing for flight 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, if applicable 

0 No planned Temporary Flight Restrictions (TFRs) 

0 PIC ("Pilot in Command") is current 

0 VOs ("Visual Observers") are current 

0 Weather forecast 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 B airspace 

0 > 2 miles from any restricted airspace or TFR 

0 Batteries are charged 

D UA 

0 Camera 

0 Tablet/phone/display 

0 Inspect UA 

0 Damage I Loose Components 

0 Cracks in UA or props 

0 Verify controller function 

0 Inspect communications equipment 

0 Batteries charged with spares 

0 Verify operation 

0 Headsets, if applicable 

0 Avionics Radio check, if applicable 

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 of 30 minutes before sunset 

D Inspect flight area for hazards 

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

0 No people within approx. 500' of any part of the planned flight 

0 Assess RF interference 

0 WI-FI Networks 

D GPS Signal Strength 

• Minimum of 4 satellites acquired 

D Conduct pre-flight briefing 

D All flight crew present 

D Review planned flight 

0 Review contingency I termination 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 off surface 

0 Place orange safety cones approx. 15' from takeoff/landing spot 

• Minimum of 4 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, if applicable 

• 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 of all 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 immediately before Takeoff) 

0 PIC: Yell "Clear" 

D PIC: Ensure takeoff path is clear 

0 Controller: Hold "Fly" to start rotors 

0 All: Observe for vibrations 

0 Controller: Verify data receptions, check for anomalies 

0 Controller: Hold "Fly" to take off 

0 All: Reassess for vibrations 

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 below 400' at all times 

D Land NOT LESS THAN 25% remaining battery 

Landing 

D Ensure LZ is clear 

D Verify "Fly to home" flight path is clear 

D On final approach 

o Hover for 5 seconds at 10 feet 

o Confirm LZ is clear 

o Slowly descent to land 

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

Shutdown 

D AC Power off and remove battery 

D Controller off 

D Disconnect camera 

D CameraOff 

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6.4 3DR Solo Emergency Checklist 

Loss of orientation 

D Climb to safe altitude 

D Reestablish orientation 

D If unable to regain orientation, Fly-to-home and land. 

Loss of WiFi Signal 

D UA will return to home 

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

Loss of Control 

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, UA will 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 If another flight 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, if needed 

0 Debrief with VOs 

0 Complete flight log 

D PackupUA 

o All equipment present and secured 

o Case closed and locked 

o Remove any trash or debris 

0 Recharge batteries 

0 If another flight 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, if needed 

0 Debrief with VOs 

D Complete flight log 

0 Pack up UA 

o All equipment present and secured 

o Case closed and locked 

o Remove any trash or debris 

0 Recharge batteries 

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D 

7 Logbooks 

7.1 Pilot I VO 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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