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# General Operations Manual

Preface
The following procedures are intended to promote safe, efficient and lawful operation of unmanned
aerial system (UAS), Safety, above all else, is the primary concern in each and every operation,
regardless of the nature of the mission.

Philoso phy

It shall be the mission of Limotta & Co., Inc. to perform controlled flights for multiple operations
in various practices as defined and detailed in the 333 Exemption Letter of Petition

. T he use of

u nmanned aerial Edu Programs (UAS), as a complete aerial resource provide s a system that at its

core will illuminate a digital path to real world matching needs

. Limotta ’s unique aerial UAS
research, education and training program will deliver to its students UAS knowledge for UAS
operation, desired mission services, situational awareness and logistical information. Limotta ’s

research and education will help in developing plans that can be utilized in many scenarios and

circumstances which will deliver the most efficient and safe mission s hundreds of times without

flaw.

The use of the Limotta ’s UAS Edu Programs provides important information and data that can’t be
supplied by any other means. Such important education and training information and data provides

for endless opportunities of application specific operations flying hundreds if not tho usands of

missions. It shall be the intent of every Limotta ’s trained and qualified pilots to make every reasonable effort to not invade a person's expectation of privacy when operating the UAS in all

situations . When operating the UAS, the Limotta ’s PIC will abide by all FAA Regulations and receive
the proper authorization for flight.

Protection of Rights and Privacy,

Limotta ’s trained leaders

, PIC s and VO s will assure that the protection of citizen ’ s civil rights and
reasonable expectations of privacy as a key co mponent of any decision made to deploy the UAS.

PICs and VO s will be trained on their accountability for ensuring that operations of the UAS

i ntrude to a minimal extent upon citizens

. To accomplish this primary goal Limotta will provide
training for a variety of scenarios :

a) In the event of a minor training deployment the UAS is being flown

, the onboard cameras
will be turned so as to be facing away from occupied structures to minimize inadvertent
video or still images of uninvolved persons.

b) All video and still images will be maintained in strict compliance with state and federal
privacy policies and procedures.

c) A website for student and public input will be maintained and regularly monitored to

address student and citizen concerns and recommendations

.

d) Limotta students will not conduct random surveillance activities. The use of the UAS will

be t ightly controlled and regulated.UAVSA Release 1.4 2015

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e) H i g h l i g h t e d t h e 4 s p e c i f i c a p p l i c a t i o n s t h a t Limotta will cover

. The re are hundreds of
applications here are a few:

A g r i c u l t u r e Pipeline Inspection
Stratospheric Telecommunications

M otion Picture Production

E d u c a t i o n News Gathering
Security Operations

R e s e a r c h

Maritime Surveillance
Environmental Sensing
Media and Traffic Monitoring

Law Enforcement

Emergency Management Natural disasters
Real Estate Photography
Meteorology
Hurricane Monitoring
Cryospheric R esearch

- Arctic and Antarctic
Bridge Inspection
Transmission Line Inspection
HAZMAT Inspection
Emergency Medical Supply
Traffic Monitoring
Aerial Surveying
Damage Assessment
Insurance Claim Appraisal
Real Estate Marketing
Concert Security
Sports Video

Run way Inspection

Virtual Tours
Landmark Inspection
Coffee Harvest Optimization
Crop Disease Management
Herd Tracking and Management
Entomology
Forestry Inspection
Fisheries Management
Species Conservation
Wildlife Inventory
Mineral Exploration

Remote Aerial Survey

Forest Fire Surveillance
Forest Fire Mapping
Volcano Monitoring
Remote Aerial Mapping
Oil Spill Tracking
Snow Pack Avalanche Monitoring
Ice Pack Monitoring
Poaching PatrolUAVSA Release 1.4 2015

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f) A trained Limotta committee will be formed and meet semi

- annually for the purpos e of
reviewing the existing UAS procedures as well as new technolog ies, laws and regulations on

UAS usage . The committee will consist of Limotta ’s personnel from the UAS research and

education . The committee will follow the leadership of the UAS vision for the use of aerial

research and education operations UAS for who will help present all proposed policy and
procedures changes and the needs of City Council s , legal and comm unit y groups. Additionally, the UAS committee will solicit feedback prior to meetings referencing to

research and education strategies and policy changes.

g) The UAS research and education program s will operate, strictly within the letter of the
law and regulations and will balance all operations with the need to accomplish the mission
while maintaining public safety, privacy and the, freedom from intrusion.

Definitions

COA (Certificate of Authorization)

— Given by the FAA grants permission to fly within specific
boundaries and perimeters. Training fli gh ts cannot take place without UAS research and

education mission critical personnel who will be the only people authorize to perform such
training missions

.

VO (Visual Observers)

— VO’s are required by the FAA for the flights of UAS defined as a person
who uses only his or her eyes to scan for traffic and inform the pilot of an unmanned aircraft (UA)
when traffic is in the vicinity of the UA so that its pilot can avoid it. See add itional definitions and

aviation abbreviations on the FAA.gov website

.

PIC (Pilot in Command)

— The pilot in command (PIC) of a UAS is the person who is
ultimately responsible for its operation and safety during flight.

VFR (Visual Flight Rule)

— VFR flight is based on the principle of “see and avoid.” The
presumption made in establishing the basic VFR weather minimums is that aircraft flying at
lower altitudes flight in an unobstructed visual flight path.

Administration
5.1 Operations Manual
The policies and procedures contained in this manual are issued by authority of Limotta leaders hip

. As such it is an official document of the Limotta

- “Aerial Robotics Education Company”

. This

manual is not intended to be all

- inclusiv e, but as a supplement to Federa l Aviation Administration
regulations, aircraft manufacturers' directives and approved flight manual guides

.

This m anual has been written to address Limotta ’s research, education and training operations as

existed the date published. Technology advancement in ae ri a l e q uipment, personnel and operations
change over time. The management of change involves a systematic approach to monitoring
organizational change and is a critical part of the risk management process provided through

education . Given this, it is essential that this manual be continually updated as necessary. The entire
manual will be reviewed, at a minimum, annually to assure it provides current information

. A copy
of the manual (electronic and/or paper) will be issued to every student having UAS flight operations
responsibilities.

5 .2 OrganizationUAVSA Release 1.4 2015

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a) The Limotta shall be comprised of those personnel approved in part by the Federal

Aviation Administration

, Limotta ’s UAS personnel that will include PIC s, VO s and
others deemed necessary such as IT personnel, and those personnel with an assignment as
part of the Limotta training team

.

b) The Limotta training team will be comprised of Limotta personnel that have research and
educational training knowledge

.

5.3 Personnel

a) The Training Director is responsible for the overall direction and performance of the

Limotta and will exercise their control

.

b) The Training Director is responsible for the day to day supervision and management of

Limotta students

.

c) U AS Training Director
Responsibilities:

i. M aintaining all training, flight and maintenance records for each PIC and VO as well as individual airframes,

ii. M aintain contact with the FAA and regulations as they change,

iii. E valuate students based on mission type and need

. iv. The Training Director must maintain a working knowledge and proficiency on all
UAS operated by the students

.

v. PIC trainers t o be considered for selection a s a PIC instructor are required to

possess a n FAA sport pilot ’ s certification a Class II I FAA physical examination

and / o r a current state driver’s license

.

PICs interacting with Air Traffic Control (ATC) shall have sufficient expertise to perform that task
readily. PICs must have an understanding of, and comply with FAA and Military Regulations
applicable to the airspace where the UAS will operate.

A PIC 's primary duty is for the sa fe and effective operation of UAS in accordance with the

manufa cturers' approved flight manual and FAA regulations policies and procedures. PICs must remain knowledgeable of all FAA regulations; UAS manufacturer's flight manual and bulletins

and City and State UAS policy

.

Training Director may temporarily remove any student or PIC instructor from flight status at any time

for any reasons including ; performance, proficiency, physical condition, etc. Should this become
necessary, the student or PIC will be notified verbally and in writing of the reason, further action to
be taken and expected duration of such removal.

UAS VO s

To b e considered for selection as a student VO , applicants are not required to already possess a

Class I I I FAA certification ( s p o r t o r private pilots) or a v a l i d s t a t e d r i v e r ’ s l i c e n s e

.

a) UAS Student VO s must have been provided with sufficient training to communicate clearly

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b) V O s will receive training on rules and responsibilities described in 14 CFR 91.111,
Operating Ne ar Other Aircraft, 14 CFR 91.13, Right

- of

- Way Rules, cloud clearance, in

flight visibility, and the pilot controller glossary including standard ATC phraseology and

communication.

c) UAS Student VO s must hav e in their possession a current 14 CFR 91.17, Alcohol or

Drugs, test as applies to UAS VO s.

d) A UAS Student VO 's primary duty is to operate the UAS's equipment including cameras,

sensors

, radio communications as well as be an VO for anything that may affect the PIC
's primary duty (see and avoid).

e) The department Training Director shall maintain a file for each Student VO which shall
include copies of FAA certifications, training records, etc. This file can be reviewed in

accordance with current Federal policies and procedures.

5.4 Scheduling

a) To maintain a level of proficiency UAS student personnel will be required as part of their
continued participation to attend online training updates as they are made available

. Student

t raining will be coordinated through Limotta and announced in advance for scheduling

purposes for participating students

.

5.6 Miscellaneous

a) Student r equests for immediate training support and assistance will be responded to by the

UAS Director. Should the request involve an immediate th reat to life, or property, the

Limotta trained PIC is authorized to accept or decline such request based on previously
approved authorization from Limotta

. Proper policy and procedure, as well as FAA
regulations shall be followed when accepting such important support

.

b) Complaints or inquiries regarding UAS oper ations shall be referred to Limotta ’s UAS
Training Director for immediate cure and a ccountability then referred to Limotta

.

6.1 Safety Policy

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

a) The student wil l at all times protect and prevent d amage to equipment, the environment and

property.

b) Student culture of open reporting of all safety hazards or incidents

.

c) The student will s upport all UAS safety training and awareness programs.

d) The UAS Training Director is trained on c onduct regular reviews of safety policies,
procedures and practices with all Personnel members

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e) The UAS Training Director continuously m onitors the UAS comm unit y at large to, ensure that
best safety practices are inco rporated into the UAS research and education programs and
operations

.

f) It is the duty of every student to contribute to the goal of continued safe operations. This
contribution may come in many forms and always includes operating in the safest manner
practicable and never taking unnecessary extreme risks.

g) Any safety hazard, 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 UAS Training Director

.

If any PIC s , VOs or students have knowledge of unsafe or dangerous act s committed by anyone, the

UAS Training 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 UAS Training Director
verbally, without delay.

6.20 Operational Hazard and Occurrence Report (OHOR) and Investigations
Occurrences are unplanned safety related events, including accidents and incidents that could
impact safety or a hazard that has the potential to cause harm, requires a systematic identification
and control of all major UAS operations and is foundational t o safety.

a) The OHOR concept provides a mechanism to report hazards and occurrences, real and
perceived, to those responsible for Limotta and operations.

b) There is no specific format for the OHOR 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 hazard, or occurrence. OHOR can be submitted anonymously to

UAS Training Director s to g et the matter proper attention.

c) Every hazard and/or occur rence that involves UAS will be investigated, with the results

and corrective action taken communicated to all students . The investigation will be
conducted by UAS Training Director and Personnel under the direction of the Limotta ’s

officer s , or any other students who has the technical skill necessary.

d) UAS o perational Hazards requiring immediate attention will be brought to the attention of

the UAS Training Director, verbally, without delay firstly, then to the attention of Limotta

.

e) ALL PE R S ONNEL ARE AUTHORIZED TO TAKE ACTION TO CORRECT A

HAZARD if in that student 's opinion delay will result in accident or injury. The Limotta
Training Director will be notified immediately in such situations.

6.3 UAS Training Director, Safety Officer, PIC

, VO and Students
In regards to safety, all Personnel are responsible for the following:

a) Ensuring all UAS flight operations students understand applicable regulatory requirements,
standards and organizational safety policies and procedures.UAVSA Release 1.4 2015

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b) Observe and control safety Edu Programs by monitoring all operations.

c) Review standards and the practices as they impact UAS operational safety.

d) Communicate all reported safety related problems and the corrective action taken. If there
were any in

- flight problems (or learned experiences), the proper procedures for handling that
problem should be discussed and documented

.

e) Such incidents should be c opy and circulate pertinent safety information.

f) Such incidents should be copy and c irculate emergency safety bulletins.

g) Place any electronic copies of safety information or bulletins on Limotta ’s UAS website for

student access.

It is emphasized again that safety is the responsibility of ALL personnel.

6.5 Medical Factors

a) PIC s. VO s and all students shall only deploy the UAS when rested and emotionally
prepared for the tasks at hand.

b) Physical illness, exhaustion, emotional problems, etc., can seriously impair judgment, memory

and alertness. The safest rule is not to act as a PIC or VO when suffering from any of the

above. Students are expected to "stand down" when these problems could reasonably be
expected to affect their ability to perform UAS flight operations

.

c) A self

- assessment of physical condition shall be made by all students during pre

- flight activities.

d) Performance can be seriously hampered by prescription and over the counter drugs. The

UAS Training Director will be advised anytime such drugs are being taken. If it is

determined that the medica tion being taken could hamper an PIC s, VO s or students

, that

person shall be prohibited from the training exercise.

e) No personnel shall act as an PIC

, VO or student pilot within eight een hours after
consumption of any alcoholic beverage, while under the influence of alcohol, or while having

an alcohol concentration of 0.04 (FAR 91.17)

7. Training

7.1 Objective
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 those students

.

7.2 On

- site Basic I nstructors a) F AA certified flight instructors will be given instructor duties

. Such duties can include
developing training courses, provide full knowledge training and student evaluation and

documentation.UAVSA Release 1.4 2015

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b) Duties for the training of new student fall s upon the UAS Training Director or to the PIC that

has the most flight time and knowledge of UAS operations. Instructors will be designated by

the UAS Training Director

.

7.3 Training Plans

a) All students will have a UAS training plan on file that outlines training objectives . This
training plan will be held in conjunction with the new student 's normal training file.

b) Limotta approved training plan can be developed by Limotta or the UAS Training Director

.

c) All UAS deployments or exercises will be documented and count toward a student’s time in
operations training.

d) It is the student’s responsibility to verify their training file contains all pertinent

information.

7.4 Initial Training

a) Upon acceptance the UAS Training Director shall review the FAA UAS operations
requirements as defined in the 333 Exemption grant

.

b) VO s must have completed sufficient training to communicate to the pilot any instructions
required to remain clear of conflicting traffic. This training, at a minimum, shall include
knowledge of the rules and responsibilities described in 14 CFR 91.111, Opera ting Near
Other Aircraft; 14 CFR 91.113, Right

- qt.

- 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 ap propriate sections

of the Aeronautical Information Manual.

c) PIC instructors will enroll in appropriate (fixed wing) training in order to obtain their sport or private pilot license/certificate if not already in possession of one (e ither fixed wing or

rotorcraft)

.

d) PIC instructors who fail to successfully complete the initial training may be re

- scheduled for
additional UAS training

.

e) Before a PIC instructors can provide training

, they must complete at least 8 hours of flight
training with the UAS Training Director to show proficiency of the fl ight training exercises

and airframe knowledge

. This must be accomplished to show their ability and general
knowledge of UAS.

7.5 Recurrent Training

a) Student s who do not have any documented training or flight time within a span of 90 days

will have to attend UAS update training programs to show proficiency

.

b) Recurrent tra ining is not limited to actual UAS flight skills but also includes knowledge of
all pertinent UAS operations and aviation matters.UAVSA Release 1.4 2015

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7.6 Miscellaneous

a) Depending on the nature of the training request, all efforts will be made to accommodate the

student training.

b) All requests for UAS training shall be approved through the UAS Training Director and
timekeeping during those training hours.

c) Students are encouraged to attend, and forward information on FAA sponsored safety

seminars.

d) Training shall only be conducted at Limotta

- UAS locations and follow the provisions
approved by UAS Training Director for flights within the COA.

8.2 Call

- out Procedure

The UAS Training Director will contact the PIC and VO from the list of available U AS trained VO s requesting a UAS VO meet the PIC at the scene. The PIC and the Personnel are responsible for
transporting the UAS and all required equipment to the scene. Upon arriving at the requested

location the PIC will contact the Training Director and will check in and receive a briefing on the
mission requested. The PIC will make an on scene determination of the ability of the UAS and the

Personnel required to perform the requested mission safely and within department and FAA policies
and procedures.

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

directives then the PIC will inform the Training Director of the potential conflict along with
recommendations for modifying the requested mission to conform to safety measures and the
department policies and procedures.

As this is a change from the original approved mission the PIC will contact the Training

Director for direction on how to proceed. As soon as possible after the completion of the

mission, the PIC will make a full report of the circumstances and their conce rn through the UAS

Director.

PICs will have sole discretion for declaring safety or violation of FAA rules. If the PIC determines
that a requested mission would violate FAA rules or en danger civilians, then the PIC will
respectfully inform the Training Director of the reasons for refusing to operate th e UAS and

contact the Training Director immediately. The UAS will not be flown in this circumstanc e and the
authority of the PIC is absolute.

If the PIC determines that the requested mission will potentially damage the UAS or its assoc iated
equipment the PIC will inform the Training Director of their concerns. If the Incident Officer, orders

the PIC to engage, the PIC will contact the Limotta and Training Direc tor after engagement as this

was a deviation of the originally approved mission, The PIC will fully document and send a
report to the UAS Director

.

8.3 Deployment Priorities

a) The UAS shall not be used for the purpose of random surveillance or photo or video
production unrelated to the mission

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b) If several separate requests for UAS support are received simultaneously, they shall be
prioritized.

c) In general terms, requests for UAS support are prioritized as:

i. Life Threating

ii. Immediate Safety Measures

iii. Complete its Chartered Mission

iv. Situational Awareness

v. Preventative Danger Documentation

8.4 Flight Boundaries
Although there may be requests for UAS support outside the Limotta ’s terms for deployment , the

authorization for such uses of the Limotta are restricted by its specific mission as designed by the

UAS deployment training and approved by Federal, State and City departments. Unless in time of
disaster and air traffic communications have been lost, flight restrictions in the proximity of No Fly

Zone locations such as airports will be approved

.

a) At no time shall UAS support be granted outside the UAS’s Personnel base of operations
without first obtaining an emergency FAA

- COA and approval by the UAS Director.

b) Information regarding flight boundaries can be found in the FAA

- COA and the use of the air
traffic regional WIZ Terminal.

c) Maximum altitude shall not be set more than 400' (AGL) per the FAA COA unless directed
by the disaster Incident Officer

.

8.5 Minimum Personnel Requirements

Due to the nature of the UAS mission, the minimum personnel required on all missions (including
training) will be a UAS pilot and a VO

. Under no circumstances will a UAS pilot or VO attempt to complete a deployment alone.

Personnel Responsibilities for Deployments

“ OPEN COMMUNICATION ACHIEVES SAFE OPERATIONS ”

a) PIC Pilot In Command

i. The PIC is directly responsible for, and is the final authority over the actual operation of the

UAS.

ii. PICs have absolute authority to reject a flight based on personnel safety or violation of FAA
regulations

.

iii. PICs are responsible for compliance with this manual, department policy and procedure and FAA
regulations.

iv. The PIC 's main duty during the deployment of the UAS is to observe UAS safely while
accomplishing the goals of the deployment.

v. PICs shall see

- and

- avoid any obstacle that will lessen safety during the mission.

vi. PIC s shall see

- and

- avoid any obstacle that will lessen safety during the mission.UAVSA Release 1.4 2015

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vii. Pilots shall operate any attachme nts to the UAS, allowing the PIC to maintain complete focus on
the operation of the UAS.

viii. PICs shall remain alert for suspicious persons or activities on the ground and coordinate response
by ground Personnel

.

ix. PIC s shall monitor appropriate (ATC, or other ) radio s as necessary or required.

x. VO s shall be responsible for documentation for mission training and updating of flight books.

8.7 Personal Equipment

a) The UAS pilot and VO s shall wear appropriate eye sun protection at times when required

while the UAS is in flight.

b) Although there is no specific company uniform all p ersonnel should take necessary
measures to deploy in a professional matter and assure that they are recognized via special

wear.

c) Limotta crew member’s personal use of radio or cellular phones during the deployment of the

UAS are used only as backup or emergency communication resources.

9. Pre

- Flight/Post

- Flight Actions

9.1 Inspections

a) PICs and VO s are both responsible for a thorough preflight inspection of the UAS and
other important operations equ ipment

.

b) Before and after each deployment (whether an incident or training), the PIC and VO shall
conduct a thorough inspection of the UAS in accordance with UAS instructions contained

in the manufactures user's manual.

c) Any issues found that will put in jeopardy the safe operation of the UAS shall be

documented and resolved immediately prior to flight.

d) It has been recognized that the use of a checklist is a significant method to combat UAS
accidents. A pre

- flight and post

- flight checklist is contained at the Base Station and will be
utilized prior to each flight.

e) Any physical equipment that cannot be resolved on

- site, and which have an impact on
safety or the mission, will be not be used in the deployment. All pre

- fl ight issues with
personnel or equipment will be resolved before flight.

9.2 Weather
Before each deployment the PIC and or VO will ensure that he/she gathers enough information
to make themselves familiar with the weather situation existing throughout the area of
deployment and the time of launch and the duration period of the flight

.

a) The PIC shall utilize FAA approved weather resources to obtain the latest and most current

weather conditions.UAVSA Release 1.4 2015

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b) An anemometer should be utilized in order to better estimate the wind speed and
determine if it is within the capabilities of the UAS airframe being flown.

c) The weather conditions reported for the operation shall be recorded in the flight log.

d) The PIC shall ensure that the flight will occur within FAA VFR weather requirements.

9.4 Planning

a) The PIC / VO shall familiarize themselves with all available information concerning the
deployment including, but not limited to, the weather conditions, hazards, and deployment
goals, etc.

b) PICs will ensure that the location for take

- off and emergency landing is adequate for a safe
deployment.

c) The take

- off/landing location should be clearly marked and identifiable with electric flares

and short cones.

d) At least one emergency landing area should b e identified per deployment.

e) 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.

9.5 Checklists

a) PICs shall utilize the checklists to ensure the highest level of safety for deployment.

b) Prior to flight, the flight log shall be initiated.

9.6 Maintenance

a) Although there are few parts on the UAS that need servicing, it is necessary that the
manufacturer's maintenance schedule is followed and properly documented

.

b) Any issues that arise during maintenance that cannot be resolved by routine methods and

shall be forwarded to the manufacturer for further technical support.

9.7 Other

a) PIC s/ VO s will ensure that no items are attached to the UAS prior to flight that are not required for safe operation and to complete the mission goal.