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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.

Philosophy

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. The use of 

unmanned aerial Edu Programs (UAS), as a complete aerial resource provides 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 missions 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 thousands 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, PICs and VOs will assure that the protection of citizen’s civil rights and 

reasonable expectations of privacy as a key component of any decision made to deploy the UAS. 

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

intrude 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 tightly controlled and regulated.
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e) Highlighted the 4 specific applications that Limotta will cover. There are hundreds of 

applications here are a few:

 Agriculture

Pipeline Inspection

 Stratospheric Telecommunications

Motion Picture Production

Education

News Gathering

Security Operations

Research

Maritime Surveillance

Environmental Sensing

Media and Traffic Monitoring

Law Enforcement

Emergency Management Natural disasters

Real Estate Photography

Meteorology

Hurricane Monitoring

Cryospheric Research - 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

Runway 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 Patrol
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f) A trained Limotta committee will be formed and meet semi-annually for the purpose of 

reviewing the existing UAS procedures as well as new technologies, 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 Councils, legal and community 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 programs 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 flights 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 additional 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 leadership. 

As such it is an official document of the Limotta- “Aerial Robotics Education Company”. This 

manual is not intended to be all-inclusive, but as a supplement to Federal Aviation Administration 

regulations, aircraft manufacturers' directives and approved flight manual guides.

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

existed the date published. Technology advancement in aerial equipment, 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 Organization
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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 PICs, VOs 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) UAS Training Director

Responsibilities: 

i. Maintaining all training, flight and maintenance records for each PIC and VO as 

well as individual airframes, 

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

iii. Evaluate 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 to be considered for selection as a PIC instructor are required to 

possess an FAA sport pilot’s certification a Class III FAA physical examination

and/or 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 safe and effective operation of UAS in accordance with the 

manufacturers' 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 flightstatus 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 VOs

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

Class III FAA certification (sport or private pilots) or a valid state driver’s license.

 

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

to the PIC any turning instructions required to stay clear of conflicting traffic. 
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b) 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, inflight visibility, and the pilot controller glossary including standard ATC phraseology and 

communication. 

c) UAS Student VOs must have in their possession a current 14 CFR 91.17, Alcohol or 

Drugs, test as applies to UAS VOs.

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 

training will be coordinated through Limotta and announced in advance for scheduling 

purposes for participating students.

5.6 Miscellaneous

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

UAS Director. Should the request involve an immediate threat 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 operations shall be referred to Limotta’s UAS

Training Director for immediate cure and accountability then referred to Limotta. 

6.1 Safety Policy

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

a) The student will at all times protect and prevent damage to equipment, the environment and 

property.

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

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

d) The UAS Training Director is trained on conduct regular reviews of safety policies, 

procedures and practices with all Personnel members.
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e) The UAS Training Director continuously monitorsthe UAS community at large to, ensure that 

best safety practices are incorporated 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 PICs, VOs or students have knowledge of unsafe or dangerous acts 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 to 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 Directors to get the matter proper attention.

c) Every hazard and/or occurrence 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

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

d) UAS operational 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 PERSONNEL 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.
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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 copy and circulate pertinent safety information.

f) Such incidents should be copy and circulate 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. VOs 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 medication being taken could hamper an PIC s, VOs or students, that 

person shall be prohibited from the training exercise.

e) No personnel shall act as an PIC , VO or student pilot within eighteen 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 Instructors

a) FAA certified flight instructors will be given instructor duties. Such duties can include 

developing training courses, provide full knowledge training and student evaluation and 

documentation.
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b) Duties for the training of new student falls 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) VOs 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, Operating 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 appropriate 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 (either 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 flight training exercises 

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

knowledge of UAS.

7.5 Recurrent Training

a) Students 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 training is not limited to actual UAS flight skills but also includes knowledge of 

all pertinent UAS operations and aviation matters.
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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 UAS trained VOs 

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 concern 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 endanger civilians, then the PIC will 

respectfully inform the Training Director of the reasons for refusing to operate the UAS and 

contact the Training Director immediately. The UAS will not be flown in this circumstance and the 

authority of the PIC is absolute.

If the PIC determines that the requested mission will potentially damage the UAS or its associated 

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 Director 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. PICs shall see-and-avoid any obstacle that will lessen safety during the mission.
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vii. Pilots shall operate any attachments 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. PICs shall monitor appropriate (ATC, or other) radios as necessary or required.

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

8.7 Personal Equipment

a) The UAS pilot and VOs 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 personnel 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 VOs are both responsible for a thorough preflight inspection of the UAS and 

other important operations equipment.

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-flight 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.
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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 be 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/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 mission goal.