COPELANDRED	LLC	

Standard	Operating	Procedures	(SOPS)

Section	1	

General	UAS	Operational	Requirements

A. UAS	General	Operational	Requirements. The	following	operational	

requirements	apply	to	all	UAS	operators,	pilots,	visual	observers,	maintainers	

and	crewmembers	operating	under	CopelandRED	LLC:

1. PIC	must	always	maintain	VLOS.

2. The	PIC	of	an	aircraft	is	directly	responsible	for,	and	is	the	final	authority	of,	the	

operation	of	that	aircraft.

3. Each	PIC	controls	only	one	unmanned	aircraft	(UA)	at	a	time.

4. PIC	must	hold	an	FAA	airman	certificate.	At	a	minimum,	either	hold	a	Private	

Pilot	Certificate	or	obtain	a	small	UAS	rating	issued	from	the	FAA.	Or	pass	an	

initial	aeronautical	knowledge	test	at	an	FAA	approved,	aeronautical	knowledgetesting center.	The	Transportation	Security	Administration	shall	vet	the	PIC.	The	

PIC	must	be	at	least	17	years	of	age	and	pass	a	biannual	aeronautical	test.	Make	

available	to	the	FAA,	upon	request,	the	small	UAS	for	inspection	or	testing,	and	

any	associated	documents/records	required	to	be	kept	under	the	proposed	rule.

5. The PIC	shall	not	perform	concurrent	duties	both	as	the	pilot	and	the	visual	

observer	(VO).

6. The PIC will	qualify on	the	aircraft	being	flown prior	to	closed	productions.

7. Only	one	PIC	per	aircraft	is	authorized,	and	the	PIC	must	be	in	a	position	of	

control	of	the	aircraft at	all	times.

8. If	a	VO	is	required:	Prior	to	flying	a	closed	production,	the	PIC	and	VO	must	have	

successfully	completed	a	qualification	process,	as	outlined	in	the	pilot	operator’s	

handbook.	As	this	is	a	requirement	stipulated	by	the	operator,	the	test	must	be	

developed	and	implemented	by	a	qualified	person	designated	at	the	sole	

discretion	of	the	operator.	A	record	of	completion	of	this	qualification	process	

must	be	documented	and	made	available	to	the	Administrator	upon	request.	

The	PIC	and	VO	must	pass	the	UAS	Knowledge	and	Airmanship	Test	provided	by	

CopelandRED	LLC	prior	to	working	on	a	live	production.

9. If	a	VO	is	required:	The	PIC	and	VO	must	discuss	the	flight	profile	prior	to	each	

flight.	The	VO	and	PIC	must	be	able	to	communicate	verbally	at	all	times.

10. CopelandRED	LLC	maintenance	shall	follow	the	manufacturer’s	UAS	

aircraft/component,	maintenance,	overhaul,	replacement,	inspection,	and	life	

limit	requirements.	When	unavailable,	aircraft	

maintenance/component/overhaul,	replacement,	and	inspection/maintenance	

requirements	must	be	established	and	identified	in	the	pilot	operator’s	

handbook.

11. CopelandRED	LLC	must	maintain	individual	training	records	of	all UAS	personnel.	

All	training	and	testing	will	be	documented	in	the	individual’s	training	record	by	
the	instructor	and	initialed	by	the	trainee. A	record	of	completion	of	this	

qualification	process	must	be	documented	and	made	available	to	the	

Administrator	upon	request.	Because	the	knowledge	and	airmanship	test	

qualifications	have	been	developed	by	the	operator,	and	there	are	no	

established	practical	test	standards	that	support	a	jurisdictional	FAA	FSDO	

evaluation	and	approval	of	company	designated	examiners,	the	petitioner	will	

conduct	these	tests	in	accordance	with	the	operator’s	manual.

12. UAS	operations	shall not	be	conducted	at night,	as	defined	in	14	CFR	§	1.1.	All	

operations	must	be	conducted	under	visual	meteorological	conditions	(VMC).	

Flights	under	special	visual	flight	rules	(SVFR)	are	not	authorized.

13. The	UA	may	not	operate	in NAS	Class	B,	C,	D,	and	E airspace	without	written	

approval	from	the	FAA.	Operation	in	Class	G	airspace	is	allowed	without	written	

FAA	approval.	The	UA	may	not	operate	within	5	nautical	miles	of	the	geographic	

center	of	a	non- towered	airport	as	denoted	on	a	current	FAA-published	

aeronautical	chart	unless	a	letter	of	agreement	with	that	airport’s	management	

is	obtained,	and	the	operation	is	conducted	in	accordance	with	a	NOTAM	as

required	by	the	COA.	The	letter	of	agreement	with	the	airport	management	

must	be	made	available	to	the	Administrator	upon	request.

14. At	least	three	days	before	scheduled	filming,	the	operator	of	the	UAS	must	

submit	a	written	Plan	of	Activities	(See	CopelandRED	Plan	of	Activities	Template)

to	the	local	FSDO	with	jurisdiction	over	the	area	of	proposed	filming.	The	3-day	

notification	may	be	waived	with	the	concurrence	of	the	FSDO.	The	plan	of	

activities	must	include	at	least	the	following:

i. Dates	and	times	for	all	flights;	

ii. Name	and	phone	number	of	the	operator	for	the	UAS	filming	

production	conducted	under	this	grant	of	exemption;	

iii. Name	and	phone	number	of	the	person	responsible	for	the	onscene	operation	of	the	UAS;	

iv. Make,	model,	and	serial	or	N-number	of	UAS	to	be	used;	

v. Name	and	certificate	number	of	UAS	PICs	involved	in	the	filming	

production	event;	

vi. A	statement	that	the	operator	has	obtained	permission	from	

property	owners	and/or	local	officials	to	conduct	the	filming	

production	event;	the	list	of	those	who	gave	permission	must	be	

made	available	to	the	inspector	upon	request;	

vii. Signature	of	exemption-holder	or	representative;	and	

viii. A	description	of	the	flight	activity,	including	maps	or	diagrams	of	

any	area,	city,	town,	county,	and/or	state	over	which	filming	will	

be	conducted	and	the	altitudes	essential	to	accomplish	the	

operation.	

15. Before	conducting	operations,	the	radio	frequency	spectrum	used	for	operation	

and	control	of	the	UA	must	comply	with	the	Federal	Communications	

Commission	(FCC)	or	other	appropriate	government	oversight	agency	

requirements.	All	Unmanned	Aircraft	System’s	utilized	by	CopelandRED	LLC	shall	

follow	the	radio	frequency	requirements	as	outlined	in	the	POH.

16. CopelandRED	LLC	will obtain	an	Air	Traffic	Organization	(ATO)	issued	Certificate	

of	Waiver	or	Authorization	(COA),	and	request	a	Notice	to	Airman	(NOTAM)	not	
more	than	72	hours	in advance,	but	not	less	than	48	hours	prior	to	the	

operation.

Section	2

Pilots In	Command

GENERAL	PERSONNEL	QUALIFICATIONS. This	section addresses	the	qualifications	of	all	

Unmanned	Aircraft	Systems	(UAS)	flight crew	members,	observers,	maintainers,	and	

other	personnel,	as	appropriate.	All	references	to	a	pilot	certificate	or	Federal	Aviation	

Administration	(FAA)	written	examination	refer	to	a FAA‐issued	private	pilot	certificate,	

a	higher	certification,	or	an	FAA-recognized	equivalent.

UAS	PILOT	QUALIFICATIONS. CopelandRED	LLC	in	conjunction	with	the	FAA	is	focused	

on	ensuring	that	UAS	pilots	have	an	appropriate	level	of	understanding	of	the	Title	14	of	

the	Code	of	Federal	Regulations	(14	CFR)	sections	applicable	to	the	airspace	where	UAS

operate.	UAS	pilots	are	responsible	for	controlling	their	aircraft	to	the	same	standards	

as	the	pilot	of	a	manned	aircraft.	

NOTE: UAS	pilot	time	may	not	be	used	to	meet	the	aeronautical	experience	

requirements	towards	the	issuance	of	a	manned	aircraft	pilot	certificate	under	14	CFR	

part	61.

The	Pilot	In	Command	(PIC)	must	possess	at	least	a	private	pilot	certificate	and	at	least	a	

current	 second-class	 medical	 certificate.	 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.

For	operations, the	designated	PIC:

a) Has	been	designated	as	PIC	before	the	flight	commences.

b) No	person	may	operate	a	UAS	in	a	careless	or	reckless	manner.

c) A	person	may	not	operate	a	UAS	if	he	or	she	knows,	or	has	reason	to	know,	of	

any	physical	or	mental	condition	that	would	interfere	with	the	safe	operation	of	

the	UAS.

d) Is	responsible	for	the	UAS	flight	operation	as	described	under	14	CFR	part	91,	§	

91.3,	or	an	FAA-recognized	equivalent.
e) Is	responsible	for	determining	whether	the	UAS	is	in	condition	for	safe	flight.	If	

the	inspection	reveals	a	condition	that	affects	the	safe	operation	of	the	UAS,	the	

aircraft	is	prohibited	from	operating	until	the	necessary	maintenance	has	been	

performed	and	the	UAS	is	found	to	be	in	a	condition	for	safe	flight.	The	Ground	

Control	Station	must	be	included	in	the	preflight	inspection.	All	maintenance	and	

alterations	must	be	properly	documented	in	the	aircraft	records.	

f) Prior	to	each	flight,	a	zero	altitude	initiation	point	will	be	established	and	

confirmed	for	accuracy	by	the	UAS	PIC.	

g) Prior	to	operations	conducted	for	the	purpose	of	motion	picture	filming	(or	

similar	operations),	a	flight	demonstration,	administered	by	an	operatorapproved	and	-qualified	pilot	must	be	successfully	completed	and	documented.	

This	documentation	must	be	available	for	review	upon	request	by	the	

Administrator.

h) Must	land	as	soon	as	safely	practical	when	any	condition	occurs	that	causes	

operations	to	be	unsafe.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	

the	UA	must	return	to	a	pre-determined	location	within	the	security	perimeter	

and	land	or	be	recovered.	The	UAS	must	abort	the	flight	in	the	event	of	

unpredicted	obstacles	or	emergencies.

i) May	be	augmented	by	supplemental	pilots;	however,	the	PIC	retains	complete	

and	overall	responsibility	of	the	flight,	regardless	of	who	may	be	piloting the	

aircraft.

j) Has	the	ability	to	assume	the	duties	of	an	internal	or	an	external	UAS	pilot	at	any	

point	during	the	flight.

k) Must	have	a	thorough	knowledge	of	the	Certificate	of	Waiver	or	Authorization	

(COA)	issued	to	the	organization	when	conducting	a	public	aircraft	operation,	

and	must	retain	a	copy	to	reference	during	flight.

l) Must	be	trained	and	qualified	on	the	specific	UAS	for	the	conduct	of	the	flight	

with	pilot	operating	handbook-specific	training	and	demonstrate	proficiency	in	

all	UAS	operations	determined	by	CopelandRED	and	defined	in	the	Knowledge	

and	Airmanship	Test.	Additional	requirements	are:

i. A	minimum	of	200	flight	cycles.

ii. Twenty	five	hours	of	total	time	as	a	UAS	rotorcraft	pilot	

iii. Ten	hours	logged	as	a	UAS	pilot	with	a	similar	UAS	type.	

iv. Three	take-offs	and	three	landings	must	be	accomplished	in	the	

preceding	90	days.	

v. Normal,	abnormal,	and	emergency	procedures	in	all	specific	

details	of	the	UAS	being	operated.

m) The	UA	may	not	be	operated	directly	over	any	person,	except	authorized	and	

consenting	production	personnel,	below	an	altitude	that	is	hazardous	to	persons	

or	property	on	the	surface	in	the	event	of	a	UAS	failure	or	emergency.	At	all	

times,	those	persons	must	be	essential	to	the	closed-set	film	operations.	

n) Regarding	distance	from	nonparticipating	persons,	the	operator	must	ensure	

that	no	persons	are	allowed	within	500	feet	of	the	area	except	those	consenting	
to	be	involved	and	necessary	for	the	filming	production.	This	provision	may	be	

reduced	to	no	less	than	200	feet	if	it	would	not	adversely	affect	safety	and	the	

Administrator	has	approved	it.	For	example,	an	equivalent	level	of	safety	may	be	

determined	by	an	aviation	safety	inspector’s	evaluation	of	the	filming	production	

area	to	note	terrain	features,	obstructions,	buildings,	safety	barriers,	etc.	Such	

barriers	may	protect	nonparticipating	persons	(observers,	the	public,	news	

media,	etc.)	from	debris	in	the	event	of	an	accident.	This	is	also	consistent	with	

the	same	FAA	Order	8900.1,	V3,	C8,	S1.	

o) The	UA	must	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.).	

p) The	UAS	may	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.	

q) The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	

horizontally	from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	

PIC.

r) Section	91.17 or	an	FAA-recognized	equivalent	applies	to	all	UA	crewmembers.

s) Prior	to	each	flight	the	PIC	must	inspect	the	UAS	to	ensure	it	is	in	a	condition	for	

safe	flight.	If	the	inspection	reveals	a	condition	that	affects	the	safe	operation	of	

the	UAS,	the	aircraft	is	prohibited	from	operating	until	the	necessary	

maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	a	condition	for	

safe	flight.	All	maintenance	and	alterations	must	be	properly	documented	in	the	

aircraft	records.	

t) Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	

operation	or	flight	characteristics,	e.g.	replacement	of	a	flight	critical	

component,	must	undergo	a	functional	test	flight	in	accordance	with	the	

operator’s	manual.	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	aircraft	record	entry	must	be	added	to	the	

operator’s	manual.

u) Flights	must	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	

level	(AGL),	as	indicated	by	the	procedures	specified	in	the	operator’s	manual.	All	

altitudes	reported	to	ATC	must	be in	feet	AGL.	

v) The	documents	required	under	14	CFR	§§	91.9	and	91.203	must	be	available	to	

the	PIC	at	the	Ground	Control	Station	of	the	UAS	any	time	the	aircraft	is	

operating.	These	documents	must	be	made	available	to	the	Administrator	or	any	

law	enforcement	official	upon	request.

w) Each	UAS	operation	must	be	completed	within	30	minutes	flight	time	or	with	

25%	battery	power	remaining,	whichever	occurs	first.

Section	3

Visual	Observers	and	Other	Personnel

General	Qualifications. All	observers	must	have	an	understanding	of	the	Title	14	of	the	

Code	of	Federal	Regulations	(14	CFR)	parts	applicable	to	the	airspace	where	the	
Unmanned	Aircraft	Systems	(UAS)	will	operate.	Observers	are	considered	

crewmembers.	Observers	must	not	perform	crew	duties	for	more	than	one	UAS	at	a	

time.	Observers	are	not	allowed	to	perform	concurrent	duties	both	as	UAS	pilot	and	

observer.

A. Medical. All	observers	must	have	a	valid	Federal	Aviation	Administration	

(FAA)	second-class	medical	certificate	issued	under	14	CFR	part	67;	an	FAA-recognized	

equivalent	is	an	acceptable	means	of	demonstrating	compliance	with	this	requirement.	

The	second-class	medical	certificate	expires	at	the	end	of	the	last	day	of	the	12th month	

after	the	month	of	the	date	of	the	examination	shown	on	the	medical	certificate.	Title	

14	CFR	part	91,		§	91.17,	or	an	FAA-recognized	equivalent,	applies	to	all	UAS	

crewmembers.

B. Training. Observers	must	complete	sufficient	training	to	communicate	to	the	

pilot	any	information	required	to	remain	clear	of	conflicting	traffic,	terrain,	and	

obstructions;	maintain	proper	cloud	clearances;	and	provide	navigational	

awareness.	This	training,	is	outlined	in	the	UAS	Knowledge	and	Airmanship	Test	

and	at	a	minimum,	includes knowledge	of:

1. The	VO	responsibility	to	assist	pilots	in	complying	with	the	requirements:

i. Section	91.111,	Operating	Near	Other	Aircraft;

ii. Section	91.113,	Right-of-Way	Rules:	Except	Water	Operations;

iii. Section	91.115,	Right-of-Way	Rules:	Water	Operations;

iv. Section	91.119,	Minimum	Safe	Altitudes:	General;	and

v. Section	91.155,	Basic	VFR	Weather	Minimums.

2. Air	traffic	and	radio	communications,	including	the	use	of	approved	air	

traffic	control	(ATC)/pilot	phraseology.

3. Appropriate	sections	of	the	Aeronautical	Information	Manual	(AIM).

Other	UAS	Personnel	Qualifications. Ancillary	personnel,	such	as	Systems	Operators	

(SYSOP)	or	mission	specialists,	must	be	thoroughly	familiar	with	and	possess	operational	

experience	of	the	equipment	being	utilized.	If	the	systems	being	utilized	are	for	

observation	and	detection	of	other	aircraft	for	collision	avoidance	purposes,	personnel	

must	be	thoroughly	trained	on	collision	avoidance	procedures	and	techniques	and	have	

direct	communication	with	the	UAS	pilot,	observer,	and	other	applicable	personnel.

Observer	Requirement. Visual	flight	rules	(VFR)	UAS operations	may	be	authorized	

utilizing	either	ground-based	or	airborne	VOs	on	board	a	dedicated	chase	aircraft.	A	VO	

must	be	positioned	to	assist	the	PIC	to	exercise	the	see-and-avoid	responsibilities	

required	by	§§	91.111,	91.113,	and	91.115 by	scanning	the	area	around	the	aircraft	for	

potentially	conflicting	traffic	and	assisting	the	PIC	with	navigational	awareness.

1. VOs	must:

i. Assist	the	PIC	in	not	allowing	the	aircraft	to	operate	beyond	the	

Visual	Line	of	Sight	(VLOS)	limit.
ii. Be	able	to	see	the	aircraft	and	the	surrounding	airspace	

sufficiently	to	assist	the	PIC	with:

• Determining	the	unmanned	aircraft’s	(UA)	proximity	to	all	

aviation	activities	and	other	hazards	(e.g.,	terrain,	

weather,	and	structures);

• Exercising	effective	control	of	the	UA;

• Complying	with	§§	91.111,	91.113,	and	91.115;	and

• Preventing	the	UA	from	creating	a	collision	hazard.

iii. Inform	the	PIC	before	losing	sufficient	visual	contact	with	the	

UA	or	previously	sighted	collision	hazard.	This	distance	is	

predicated	on	the	observer’s	normal	vision.

NOTE: Normal	vision	may	include	use	of	corrective	lenses,	

spectacles,	and	contact	lenses	as	necessary.

2. Because	of	field	of	view	(FOV)	and	distortion	issues	with	aids	to	

vision	such	as	binoculars,	field	glasses,	night-vision	devices,	or	

telephoto	lenses,	these	are	allowed	only	for	augmentation	of	the	

observer’s	visual	capability;	they	cannot	be	used	as	the	primary	

means	of	visual	contact.	When	using	other	aids	to	vision,	VOs	

must	use	caution	to	ensure	the	aircraft	remains	within	normal	

VLOS	of	the	observer.	These	aids	to	vision	are	not	to	be	confused	

with	corrective	lenses	or	contact	lenses,	which	do	not	alter	the	

FOV	or	distort	vision.

3. The	responsibility	of	ensuring	the	safety	of	flight	and	adequate	

visual	range	coverage	to	avoid	any	potential	collisions	remains	

with	the	PIC.	The	PIC	for	each	UAS	operation	must	identify	a	

location	from	which	the	observer	will	perform	his/her	duties.	This	

location	will	be	selected	to	afford	the	best	available	view	of	the	

entire	area	within	which	the	operation	is	to	be	conducted.

Section	4

General	Maintenance	Personnel	Qualifications

1) Maintenance	Ratings. An	FAA	Airframe	and	Powerplant	Licensed	

Personnel	will	be	on	staff	for	all	CopelandRED	UAS	maintenance.	

2) Maintenance	Experience. It	is	suggested	that	operators/applicants	

follow	applicable	guidelines	of	Title	14	of	the	Code	of	Federal	Regulations	

(14	CFR)	part	65,	§	65.83,	as	appropriate,	until	final	Unmanned	Aircraft	

Systems	(UAS)	regulatory	guidelines	are	available.
3) Maintenance	Medical	Requirements. At	a	minimum,	the	requirements	of	

14	CFR	part	91,	§	91.17 or	a	Federal	Aviation	Administration	(FAA)-

recognized	equivalent	must	be	met.	

4) Maintenance	Training. Refer	to	the	Maintenance	Training	Handbook	for	

all	UAS	Maintenance	Training	guidelines.

Maintenance	Record. All	maintenance,	preventative	maintenance,	alterations,	status	of	

replacement/overhaul	component	parts,	and	the	total	time	in	service	of	the	UAS must	

be	documented	in	the	Maintenance	Log	maintained	by	CopelandRED	for	each	UAS in	

service.

Section	5

ACCIDENT	AND	INCIDENT	INVESTIGATION	AND	REPORTING

Civil	Aircraft	Operations

1) Any	incident/accident	and	any	flight	operation	involving	Unmanned	

Aircraft	Systems	(UAS)	that	transgresses	the	lateral	or	vertical	boundaries	

of	a	flight	test	area,	restricted	airspace,	or	other	operational	boundary,	

such	as	a	Certificate	of	Waiver	or	Authorization	(COA),	must	be	reported	

to	the	Federal	Aviation	Administration’s	(FAA)	UAS	Integration	Office	

(AFS-80)	within	24 hours.	AFS-80	can	be	reached	by	telephone	at	202-

385-4636	and	fax	at	202-385-4559.	

2) Accidents	must	be	reported	to	the	National	Transportation	Safety	Board	

(NTSB)	per	instructions	contained	on	the	NTSB	Web	site:	www.ntsb.gov.	

3) Further	flight	operations	may	not	be	conducted	until	the	incident,	accident,	or	

transgression	is	reviewed	by	AFS-80	and	authorization	to	resume	operations	is	provided.