October 1, 2015

Exemption No. 13049 Regulatory Docket No. FAA

−2015

−2785

Mr. Lane Swainston President Swainston Digital Imaging 1542 Little Dove Court Henderson, NV 89014 Dear Mr. Swainston: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated June 29, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Swainston Digital Imaging (hereinafter petitioner or operator) for an exemption

. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial imaging, safety surveys, forensic inspections, and law enforcement support

. See the docket, at www.regulations.gov, for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airworthiness Certification The UAS proposed by the petitioner is a DJI Inspire

. In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation2

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

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 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;  The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and
 A grant of exemption is in the public interest. Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Swainston Digital Imaging is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below. Conditions and Limitations In this grant of exemption, Swainston Digital Imaging is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission ofthis exemption. 1. Operations authorized by this grant of exemption are limited to the DJI Inspire when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed

-set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised4

documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. 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 prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. 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. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must 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 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. 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during 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. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. 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. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled

-access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA

. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 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. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 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 UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply. 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (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: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. 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; g. Signature of exemption holder or representative; and h. 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. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on October 31, 2017, unless sooner superseded or rescinded. Sincerely,

/s/ John S. Duncan Director, Flight Standards Service Enclosure29 June 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

Dear Sir or Madam: Attachedplease find Swainston Digital Imaging's (SDI) request for an exemption from the listed Federal Aviation Regulations to allow commercial operation ofSmall Unmanned Aircraft Systems ("sUAS") for aerial imaging, safety surveys, forensic inspections, and law enforcement support. This exemptionrequest is initially for the use ofthe "Inspire" sUAS manufactured by DJI, an established sUAS company. Also attached to this letter is the equipment SDI Flight Manual, which outlines the operating requirements, limitations, and technical specifications for the DJI Inspire sUAS System as used by SDI. SDI has reviewed this Manual and has found itto be acceptable for sUAS operations. Applicant submits this manual as a Confidential documentunder 14 CFR 11.35 (b) as the entire manual contains proprietary informationthat the applicant has not and will not share with others. The Manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom ofInformation Act 5 USC 552 et. seq. Thank you for your time and consideration, and please let me know ifyou have any questions. Sincerely, ' / • _ _,_,___ _

# ~_/~~**f;;sw~;o~ ,~**  Swainston Digital Imaging President Cc File Enclosures

SwainstonDigital Imaging29 June 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119;91.121; 9.151(a); 91.405 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Swainston Digital Imaging (SDI), an aerial photography and digital imaging company, onbehalfofitselfand its related affiliates under common ownership and control, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits Small Unmanned Aircraft Systems ("sUAS") for aerial imaging for video, still photography, forensic inspections, safety surveys, and law enforcement support, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As detailed inthis document andthe attached Flight Manual, the requested exemption would permitthe operation ofsUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled and 4) wouldprovide safety enhancements to the already best practices safety protocols followed by SDI during aerial photography and inspection operations. SDI is a member ofthe "Professional Aerial Photographers Association, International" (PAPA) and has a longstanding demonstrated record ofsafe operations inthe National Airspace System (NAS). Principal employees have received Private Pilot ground school training and eachhave logged well over 25 hours ofsUAS flight operations. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems inthe National Airspace System." Section 333(c) ofthe Reform Act.

SwainstonDigital ImagingThe name and address ofthe applicant is: Swainston Digital Imaging 1542 Little Dove Court Henderson, Nevada 89014 Lane Swainston PH: 702-501-7555 Email: lane@swainston.com Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 109 14 C.F.R. 119 14 C.F.R. 121 14 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b)

I. STATUTORYAUTHORITY FOREXEMPTIONS 

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The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, including sUASs, from the requirementthat all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthistitle ifthe Administrator finds the exemption inthe public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1). Section 333(b) ofthe Reform Act assists the Secretary in determining whether sUAS may operate inthe National Airspace System (NAS) without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider:

• The sUAS's size, weight, speed, and operational capability; • Whether the sUAS operates within the visual line ofsight ofthe operator

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+ Whether the sUAS operates outside ofhighly populated areas and away from close proximity to airports Reform Act §333(a). Ifthe Secretary determines that a sUAS "may operate safely inthe national airspace system, the Secretary shall establishrequirements for the safe operation ofsuch aircraft inthe national airspace system." !d. §333(c) SDI's sUAS are multirotor vehicles, weighing 20 or fewer lbs. including payload. They operate under normal conditions at a speed ofno more than 70 knots and have the capabilityto hover, and move inthe vertical and horizontal plane simultaneously. The sUAS will operate only inthe PIC and Visual Observers visual line ofsight at all times and will operate only withinthe designated area described in the Confidential SDI Flight Manual, attached as Exhibit 1 (hereinafter "the Manual"). Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." Reform Act Section 333 (b). Given the small size ofthe sUAS involved and the restricted and controlled environment within which they will operate, our application falls squarely within the zone ofsafety (an equivalent level ofsafety) in which Congress envisionedthatthe FAA must, by exemption, allow commercial operations ofsUAS to commence immediately. Also, due to the small size ofthe sUAS, altitudes, and restricted areas inwhichthe sUAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal AviationAct, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significantpublic benefit, including enhanced safety, the grant ofthe requested exemptions is inthe public interest. Accordingly, SDI respectfully requests thatthe FAA grantthe requested exemption without delay.

II. PUBLIC INTEREST This exemption application is expressly submittedto fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportationto consider whether certain unmanned aircraft systems may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. By granting an exemption the FAAwill fulfill Congress's intent ofallowing UAS to operate with significant safetyprecautions inlowrisk environments. The use ofsUAS on aerial photography operations can significantly reduce the risk to photographers and participants. Also, sUAS can inspect, photograph, and collect data onhardto get to areas that otherwise wouldrequire direct access or manned aircraft. Additionally, sUAS could replace the use ofhelicopters and small aircraft to produce imagery for various purposes. The sUAS we propose to fly in this application are less than 20 pounds, and carry no combustible material onboard, as opposed to the much larger conventionally powered small aircraft. Shifting to sUAS from helicopters and other manned aircraft presents a marked safety increase for our workers and the public.

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Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection. The sUAS used by SDI use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation ofsmall aircraftthat are many hundreds oftimes heavier.

III. EQUIVALENT LEVEL OF SAFETY SDIproposes thatthe exemption requested herein apply to sUAS that have the characteristics and that operate withthe limitations listed herein. These limitations provide for at least an equivalent or evenhigher level ofsafety to operations under the current regulatory structure becausethe proposed operations represent a safety enhancementto the already safe protocols followed on imaging, photography, safety surveys, forensic inspection, and law enforcement support operations conducted withhelicopters and other conventional aircraft. SDI will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption: 1. The sUAS will be less than 20 pounds. 2. Flights will be operated within visual line ofsight ofa Pilot in Command. 3. Maximumtotal flight time for each operational flight will be 20 minutes. The Pilot in Command calculates battery reserve, and will return the sUAS to the "Designated Safety Zone" with at least 20% battery power reserve should that occurpriorto the 20 minute limit. 4. Flights will normally be operated at an altitude ofnot more than 400 feet AGL, never exceeding 1200 feet AGL. 5. Crew for each operation will consist ofthe sUAS Pilot in Command (PIC) who will keep the sUAS withinhis visual line ofsight at all times and will be supported by a qualified Visual Observer (VO). 6. The sUAS operator will be trained in flight operations, and safety procedures as detailed in the FlightManual. 7. The sUAS will only operate within a confined "Area ofOperations" (AO) as defined inthe Manual. The Manual also requires the establishment ofa "Designated Safety Zone" (Safety Zone) for the preparation, takeoff, and landing flight operations area. 8. A briefing will be conducted regarding the planned sUAS operations priorto each day's production activities. Itwill be mandatorythat all personnel who will be performing duties withinthe boundaries ofthe Safety Zone be presentfor this briefing. 9. All onsite personnel will consentto the UAS flyover on site bywaiver, and the operator will obtain additional verbal or written consent ofall persons who will be allowed within 100 feet ofthe flight AO. 10. Pilot in Command will have beentrained in operation ofUAS generally and will have received up-to-date information onthe particular sUAS to be operated as required bythe SDI Manual. 11. Necessary written and/or oral permission from the relevant property holders will be obtained.

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12. All necessary permissions and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate government agencies as may be required. 13. Ifthe sUAS loses communications or loses its GPS signal, it will have the capabilityto enter "loiter mode" and hover, reestablish satellite connection, and return to a predetermined location withinthe "Designated Safety Zone" and land. IV. DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command Sections 61.113 (a) & (b) limitprivate pilots to non-commercial operations. Because the sUAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations by requiring the Pilot in Command operating the aircraft to have completed a sUAS flight training course of25 hours before flying a sUAS (See the SDI Manual for details). Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo onboard. The area ofoperation is controlled and restricted per priorplanning and necessary coordination withthe local FSDO ifapplicable, and all flights are planned and coordinated in advance as required and as set forth inthe SDI FlightManual. The sUAS to be operated hereunder is less than 20 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a controlled Area ofOperation as set out inthe SDI Flight Manual. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored bythe Pilot in Command, pursuantto the SDI FlightManual requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the Area ofOperation as is currently done by SDI on normal aerial photography operations. The FAAwill have advance notice ofall operations as may be required. The risks associated withthe operation ofthe sUAS are therefore diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, and allowing operations ofthe sUAS as requested with an operator who has metthe minimum requirements stated inthe SDI Manual achieves the level ofsafety contemplatedby 14 C.F.R. §61.113 (a) & (b). 14 C.F.R. 91.103: Preflight Action This regulationrequires each Pilot in Commandtake certain actions before flight to ensure the safety offlight. An exemption is needed from this requirement as the PIC will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions inthe Preflight Checklist in the SDI Manual. These actions will provide an equivalent level ofsafety.

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14 C.F. R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, providedthe person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multirotor craftthat flies similarly to a helicopter, with vertical takeoffand vertical landing, which will typically operate at altitudes ofless than 400 AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude higher than 1200 AGL and will be in a controlled area with a "Designated Safety Zone", where buildings and people will not be exposed to operations without the specified pre-obtained consent. (See SDI Manual for detailed procedures.) The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the required permission of the property owner or local officials. Because ofthe advance notice to the property owner and any onsite personnel as outlined inthe SDI Flight Manual, all affected individuals will be aware ofthe planned flight operations. Unlike flight operations with aircraft or rotorcraft weighing far more than the maximum 20 lbs. proposed herein, our sUAS will not carry flammable fuel. In addition, the coordinated operations ofthe sUAS will ensure separationbetween sUAS operations and the operations ofconventional aircraft that must comply with Section 91.119. 14 C.F.R. 91.121: Altimeter Settings This regulationrequires eachperson operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS maynot have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. Anequivalent level ofsafety will be achieved by the operator, pursuantto the SDI FlightManual and Safety Check list, confirming the altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight. 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight inVFRconditions. Our sUAS is limited to operations in controlled environments as outlined inthe SDI FlightManual, and has a limited range and flight time which require an exemption from 14 CFR91.151 (a) The battery powering the sUAS provides over 20 minutes ofpowered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, sUAS flights wouldnecessarily be limitedto a few minutes in length. Giventhe limitations onthe sUAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight ornight VFRconditions is reasonable. SDI believes that an exemption from 14 CFR §91.151(a) falls withinthe scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporationto operate without compliance with FAR 91.151(a)). Operating the small sUAS, in a controlled area where only people and property owners or official representatives who have signed waivers will be allowed,

SwainstonDigital Imagingwith less than 30 minutes ofreserve fuel, does not engender the type ofrisks that Section 91.151(a) was intendedto alleviate giventhe size and speed ofthe small UAS. Additionally, limiting sUAS flights to a few minutes would greatly reduce the utility for whichthe exemption will be granted. 7

An equivalent level ofsafety canbe achieved by limiting flights to approximately 20 minutes, or enough battery reserve to ensure thatthe sUAS lands at the ground stationwith at least 20% of battery power (as determined bythe onboard monitoring system andthe PIC), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 CFR91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed inthe subpart E ofthis part and shall betweenrequired inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed inpart 43 of this chapter.

..," and others shall inspect ormaintainthe aircraft in compliance with Part 43. Giventhatthese sections and Part43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to SDI. Maintenance will be accomplished bythe Operator and pursuantto the flight manual and operating handbook as referenced inthe SDI FlightManual. An equivalent level ofsafety will be achieved because these small sUAS are very limited in size and will carry a small payload and operate only in controlled areas for limited periods oftime. If mechanical issues arise, the sUAS can land immediately and will be typically operating from 400 AGL or less and no higher than 1200 feet AGL. As provided inthe SDI Flight Manual, the PIC will ensure that the sUAS is inworking orderpriorto initiating flight, performrequired maintenance, and keep a log ofany maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suitedto maintainthe aircraft in an airworthy condition to provide the equivalent level ofsafety. 

### *********
Pursuantto C.F.R. Part 11, the following summary is provided for publicationinthe Federal Register, should it be determinedthatpublication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in aerial photography operations.

SwainstonDigital ImagingApproval ofexemptions allowing commercial operations ofsUAS in the aerial photography, safety surveys, forensic inspection, law enforcement support, and video industries enhances safety while reducing risk. Manned aircraft still photography, forensic inspection, law enforcement support and video creates a greater risk because the aircraft are much larger, have combustible fuel, and carry an onboard human crew. In contrast, a sUAS weighing fewer than 20 lbs. and powered by batteries eliminates virtually all ofthatrisk, giventhe reduced mass and lack ofcombustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose themto the risks associated with manned aircraft flights. 8

The operation ofsmall sUAS, weighing less than 20 lbs., conducted inthe strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far saferthan conventional operations conducted withturbine orreciprocating helicopters or full scale manned aircraft operating in close proximity to the ground and people. Privacy All flights will occur overprivate or public property with the necessary private property owner's prior consent and knowledge. Images taken will be ofindividuals who have also consentedto being filmed or otherwise having agreed to be inthe area where aerial photography, safety surveys, or forensic inspections will take place. 

### ********* Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security -provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofapplicant's sUAS in construction industry pursuantto the SDI Manuf!.l appended hereto.

# ~~~-.e-<-- Lane Swainston Swainston Digital Imaging President

Cc File

SwainstonDigital Imaging

# UAS Flight Manual
Swainston Digital Imaging

29 June 2015

This manual contains standard operating procedures and guidelines for UAS operations.

# Swainston Digital Imaging UAS Operations Manual Table ofContents Purpose, Scope, and Mission Statement
.............................................................5 Definitions
..........................................................................................................6 Personnel Responsibilities
..................................................................................8

Visual Observer

....................................................................................................8 PIC

.......................................................................................................................8 Flight Team Composition

.....................................................................................8 Qualification Requirements

.................................................................................8 Operating limitations and Conditions
.................................................................9 Maintenance Procedures
.................................................................................. 10 Routine Maintenance

........................................................................................10 Full Flight Test

....................................................................................................11 Software Firmware Update Policy

......................................................................11 

### Logs and Records
..............................................................................................12 Pilot and Aircraft Hours

......................................................................................12 Battery Logbook

.................................................................................................12 Flight Planning
..................................................................................................13

Weather

.............................................................................................................13 Site Permissions

.................................................................................................13 Pre-Flight Inspections and Checks

......................................................................13 Documentation

..................................................................................................14 Pre-Flight Area and Personnel Checks

................................................................14 Closed Set Operations

........................................................................................15

2On-Site Procedures

............................................................................................16 Site Survey

..................................................................................................16 Selection of Operating Areas and Alternatives

............................................16 Boundaries

..................................................................................................17 Anemometer Weather Check

.....................................................................18 Crew Briefing

..............................................................................................18 Communications

.........................................................................................18 Frequency Scans

.........................................................................................19 Recharging and Battery Use {Fuel Management)

........................................19 Load-outs and Equipment

...........................................................................19 Flight Procedures
..............................................................................................20 Motor Start

........................................................................................................20 Take-Off

.............................................................................................................20 ln-Fiight

..............................................................................................................21 Let Down/Landing

..............................................................................................21 Shutdown

..........................................................................................................22 Emergency Procedures

.....................................................................................23 MotorThrust Loss

..............................................................................................23 Battery Failure

...................................................................................................23 Battery Failure Failsafe

...............................................................................24 Transmitter/Controller Battery Failure

.......................................................25 Controller Battery Failsafe

..........................................................................25 Loss of Control Frequency

..................................................................................25 Loss of Control Frequeny Failsafe

......................................................................25 Malicious or Accidental Interference with Control Frequency

...........................26 Pilot Incapacitation

.....................................................................................26

3Aircraft Incursion

........................................................................................26 Fly Away Procedure
..........................................................................................27 Crash 

### & Incident Response

................................................................................27 Appendix A - Checklists
.....................................................................................28 Pre-Flight Start-Up Checklist

..............................................................................29 Pre-Flight Inspection Checklist

...........................................................................31 ln-Fiight

..............................................................................................................32 Landing Checklist

...............................................................................................33 Appendix B
.......................................................................................................34 Maintenance Logbook

.......................................................................................35 Appendix C
.......................................................................................................36 Incident/ Accident Logbook

................................................................................37 Appendix D
.......................................................................................................38 Flight Record Logbook

.......................................................................................39 Appendix E

.......................................................................................................40 Inspire User Manual

...........................................................................................41

4

## PURPOSE, SCOPE, AND MISSION STATEMENT Swainston Digital Imaging (SDI), a member ofthe Professional Aerial Photographers Association, International (PAPA} intends as the Operator to promote safe operation of sUAS in the National Airspace System (NAS} in a manner that is consistent with a long history of safe and professional flight operations in close cooperation with the Federal Aviation Administration (FAA). The Operators are experienced professional aerial photographers and have completed private pilot ground school for rotary wing aircraft as well as approximately 40 hours of instructor supervised flight time. The sUAS Pilots in Command (PIC} that will operate systems according to the approach outlined in this Flight Manual of procedures (Manual) are trained in accordance with this Manual and have received at least 25 hours of UAS training combined with experience on conventional Aerial Photographic flight missions.
The intent ofthe Manual is to provide the outline of a system to conduct safe and successful sUAS operations in accordance with the applicable FAA regulations and consistent with the section 333 waiver that this Manual is based upon. It is expected that the Operator will continue to apply the skills and experience they have employed in manned aircraft operations under FAA regulations. This combination of prior successful flight experience and sound sUAS flight operational procedures is intended to promote the highest levels of professionalism in safe aerial photographic flight missions.

5

### DEFINITIONS The following definitions ofwords and terms apply to the information contained in this Manual and are specific to procedures and operations that are outlined herein. In the case of a conflict with an official FAA definition, the FAA definition will be the rule.

Anemometer- An instrumentto measure the velocity ofthe wind in the Area of Operations.
Area of Operations- Defined as the area where sUAS operations will be carried out for a specific flight or series offlights on a given mission. Checklists- Procedural checklists used by the PIC to verify proper and safe procedures during all phases of sUAS operations. Designated Safety Zone- Defined and marked area of ground operations used for safe takeoffs and landings ofthe sUAS at a given Area of Operations. Flight Control Systems- The combination oftelemetry, PIC operated controls, and onboard control mechanisms that are employed to control the flight ofthe sUAS. Frequency Analyzer- A device used to scan the Area of Operations for possible interference from radio waves. 

### GPS- Global Positioning System.
Handheld Radio- A radio transceiver capable of communication with other Pilots or FAA personnel in the Area of Operations.
Loiter Mode- A default recovery mode the sUAS goes into when communications are lost from the PIC.
Maintenance Recommendations- Periodic maintenance recommendations for each ofthe sUAS components that have a usable life.

6Manual- This flight manual that combines the Operator specific procedures with the sUAS manufacturers' manual.
Manufacturers Recommendations- Written recommendations provided by the manufacturers ofthe various components ofthe sUAS.
NAS- National Airspace System.
Non Participants- Persons who have not agreed to participate in sUAS operations. Operator- The entity submitting as the applicant on this waiver request to the FAA who will be responsible for all sUAS operations and procedures.
PAPA- Professional Aerial Photographers Association, International. Participants- Persons who have agreed to participate in sUAS operations.
Pilot In Command- Person who will fly the UA during sUAS operations and who is responsible for all safety related or operational decisions under the direction of the Operator in accordance with this Manual and FAA requirements. SOP- Standard operating procedures.
sUAS- Small Unmanned Aerial Systems as contemplated underthe FAA guidelines, not to exceed 55 pounds in weight or 100 miles per hour in speed. Telemetry- Electronically transmitted data that provides control and information transmissions to and from the PIC and the sUAS.
UA- Unmanned Aircraft. Visual Observer- An individual who is designated to observe flight operations and to maintain visual contact with the UA during flight operations while maintaining communications and coordination with the PIC.

7

## PERSONNEL RESPONSIBILITIES

VISUAL OBSERVER All operations will utilize a Visual Observer. The main responsibilities ofthe Visual Observer will be to ensure that the UA is operated within the visual line of sight of both the PIC and Visual Observer at all times. The Visual Observer will maintain verbal communication with the PIC at all times. Prior to flight, the PIC will ensure thatthe Visual Observer understands and can perform all the duties required of the Visual Observer.
PIC Pilot in Command is responsible for the safe operation ofthe sUAS at all times in accordance with this Manual and the applicable FAA regulations.
Pilot in Command will be responsible for: • All support personnel. • Performing all pre-flight, flight phase, and post flight inspections, air worthiness, diagnostics, and testing. • Manufacturer recommended maintenance operations. • Weather condition assessments and forecast reviews.
FLIGHT TEAM COMPOSITION The onsite flight team is composed of a Pilot in Command (PIC} and a Visual Observer (VO}. The PIC is responsible for all flight operations and decisions to proceed. The VO is responsible to maintain visual contact with the UA and to provide constant communication with the PIC regarding aircraft status and surrounding conditions within the Area of Operations.
QUALIFICATION REQUIREMENTS The PIC must be a licensed Commercial Pilot and must have completed the PAPA sponsored ground school with at least 25 hours ofsUAS flight time. The VO must have completed sUAS ground school training and must demonstrate experience with FAA procedures and the standard procedures ofthis Manual.

8

### OPERATING LIMITATIONS AND CONDITIONS Operational Ceiling- Maximum 1,200 ft AGL, typical400 ft AGL. Operational Endurance- approximately 20 minutes.
Maximum Speed- 100 MPH
Maximum OperatingTemperature- 110 degrees F
Minimum OperatingTemperature
- 0 degrees F
Maximum Operational Wind Speed- 15 MPH (gusts to 20 MPH)

9

## MAINTENANCE PROCEDURES Only SDI personnel or an appointed service technician may carry out maintenance on the sUAS aircraft systems described in this operations manual. In all cases a Maintenance Logbook (see Appendix B) is completed to reflect any work undertaken and a flight test, testing all functions (including the return-to-home failsafe facility), is subsequently carried out by the PIC.
ROUTINE MAINTENANCE The Pre-Flight and Post-Flight checklists shown in Appendix A are completed by the PIC every time a SDI sUAS aircraft is operated. Every six months (or fifty hours offlight time- whichever comes first) the following inspection is carried out by the PIC. The inspection is recorded in the Maintenance Logbook along with any findings. Any issues identified are remedied and the aircraft undergoes a full flight-test before the aircraft is returned to Operational Status: • Inspection ofthe airframe for any damage, unusual marks and tightness of fixings; • Inspection ofthe motor mountings for correct tension; • Inspection ofthe propellers for condition, unusual marks, chips, cracks and tightness of fasteners; • Inspection of electrical wiring for condition, unusual marks or discoloration; • Inspection of electrical terminal fittings and plugs for secure attachment and general condition; • Inspection ofthe attachment of all fittings such as flight controller, GPS antennas etc. for secure attachment; • Inspection of payload attachment points for condition and security of payload; • Inspection ofthe condition and function of all ancillary equipment such as transmitter etc. • Testing of all system battery packs for charge status and general condition.
If any issues or problems are identified then the aircraft is not allowed to fly until the issue has been remedied. If minor problems (such as damaged propellers, faulty battery packs etc.) are identified and remedied, and the PIC believes the aircraft is suitable to return to Operational Status then the work completed is noted in the Maintenance Logbook. If major issues are identified (such as an unserviceable motor, damaged airframe etc.}, then the aircraft undergoes a full
10flight test regime (as described below), once the identified fault has been remedied.
FULL FLIGHT TEST The system has all functions tested with a minimum offive minutes flight time by a qualified PIC recording any abnormalities in the Flight Record Logbook (Appendix D). Ifthe PIC deems the aircraft to be safe then he must sign the Flight Record Logbook as fit for Operational use. Systems with identified issues relating to firmware or software (see below) are grounded by SDI until any problems are rectified. SOFTWARE AND FIRMWARE UPDATE POLICY All new software and firmware are thoroughly assessed before installation. Particular attention is focused on relevance to operations, reason for release and any known issues. Multi-rotor and UAS forums are consulted regularly for any reported issues with the release and only when the validity ofthe upgrade has been confirmed is the upgrade considered.
In all circumstances the upgrade is performed by qualified SDI personnel or appointed service providers. All upgrade information such as version numbers and new functions are recorded in the Maintenance Logbook. All SDI PIC are made aware that the firmware or software has been upgraded before any flight operations are undertaken. Any upgraded system has all functions thoroughly tested with a minimum offive minutes flight time by a qualified SDI PIC who records any abnormalities in the Flight Record Logbook. Ifthe PIC deems the aircraft to be safe then the PIC signs the Flight Record Logbook as fit for Operational use. If any doubts exist as to the new upgrade the aircraft is downgraded to the previous firmware and the flight test procedure is repeated. Systems with identified issues relating to firmware or software are grounded until the problem can be rectified.

11

## LOGS AND RECORDS
PILOT AND AIRCRAFT HOURS SDI PIC are required to keep a log of pilot and aircraft hours. To meet this requirement SDI holds and updates a spreadsheet-based Personal Flying Log Book for Aircraft Operating Crew. This log book is a separate document which can be viewed on request (see sample page at Appendix D).
BATTERY LOGBOOK SDI Personal Flying Log Book (Appendix D) additionally records information about battery condition (charge) before and after each flight. The Battery Logbook is accompanied by- and supported with- SDIIncident Logbook (Appendix C) and Maintenance Logbook (Appendix B).

12

## FLIGHT PLANNING
WEATHER Operator will require PIC to obtain all necessary weather information in order to plan and conduct safe flight operations according to and as referenced by any applicable UA Operator Manuals. If operating near an operating Automatic Terminal Information Service {ATIS), the ATIS broadcast system will be consulted. IfA TIS is not available, PIC will consult-alternative sources for a current weather forecast.
The operating envelope for the Inspire has been referred to earlier. It is emphasized that the PIC is to ensure the operating envelope environment meets or exceeds all safe and legal visibility, precipitation, humidity, and wind limitations for safe operation. SITE PERMISSIONS • Secure permissions from property owner if required. • Secure permissions from participants. • Coordinate with local law enforcement if required. • Prior to operations, Operator receives permission for take-off and landing from the relevant land-owner. In most cases permission attainment is unproblematic as the landowner and the client are the same individual (or entity). In the case of local authority owned land, the relevant authority is contacted in advance to secure permission for take-off and landing, and to find out about any operating restrictions or specific insurance requirements that might apply.
PRE-FLIGHT INSPECTIONS AND CHECKS Prior to each flight, the PIC will conduct a pre-flight inspection and determine if the UAS is in a condition for safe flight, and to account for all possible discrepancies or inoperable equipment. Ifthe inspection reveals any condition that will affect the safe operation ofthe UAS, the aircraft will be prohibited from operating until the necessary maintenance can be performed and the UAS can be returned to safe flight. The preflight inspections will include the following components according to the recommended checklists in the DJI Inspire operator manual, and in the SDI checklist:

13

### D Airframe 

### D Battery 

### D Transmitters 

### D Camera and Gimbal 

### D Propulsion system including propellers
In addition, with the battery attached and turned on in the UAS, the PIC will oversee and monitorthe series of diagnostic tests to determine and verify proper voltage levels, control function, communication, and GPS satellite connectivity acquisition. PIC will utilize the DJI Inspire LED indicators as well as telemetry data to determine ifthe proper preflight diagnostics have been completed. The PIC will also perform and log a pre-flight compass calibration each time the UAS is flown from a new location. DOCUMENTATION PIC will ensure that all documents used by SDI to ensure safe flight operations and any document required under 14 CFR 91.9 and 91.203 must be available at the Ground Control Station on site at any time the UAV is operating, and ready to be made available to any law enforcement official upon request. If possible, these documents will be on the PIC's person at all times during flight operations, and accessible to law enforcement without interrupting the PIC while conducting flight operations (possibly in a pouch on the back ofthe vest).
PRE-FLIGHT AREA AND PERSONNEL CHECKS • Survey flight operations area for safety concerns and to verify conditions. • Examine all components ofthe UAS to verify proper function in accordance with the applicable manuals and manufacturer's instructions. • Verify notification to all personnel on site. • Establish Designated Safety Zone and verify safe clearances. • PIC should wearthe specified safety vest. • The ultimate responsibility for aircraft airworthiness and operational safety rests with the UAV pilot-in-command. For this, the PIC- as an aid- uses a Pre-Flight Checklist (see Appendix A). In summary, the Pre-Flight Checklist prompts examination ofthe following: 

### D The airframe (for condition and lack of damage); 

### D The battery (for level-of-charge and security of attachment); 

### D The transmitter (for level-of-charge and to check that switches

14are in the 'home' position); 

### D The camera (secured, on and operating). 

### D Propulsion system

• In addition, when the flight battery is connected to the UAV, the flight controller undertakes a series of diagnostic tests (while simultaneously locating the position of GPS satellites). CLOSED SET OPERATIONS Ifthis exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply: • The operator must have a Motion Picture and Television Operations Manual {MPTOM) as documented in this grant of exemption. • At least 3 days before aerial filming, the operator ofthe UAS affected by this exemption must submit a written Plan ofActivities to the local Flight Standards District Office {FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concurrence ofthe FSDO. The plan of activities must include at least the following: o Dates and times for all flights; o Name and phone number ofthe operator for the UAS aerial filming conducted underthis grant of exemption; o Name and phone number ofthe person responsible for the onscene operation ofthe UAS; o Make, model, and serial or N-Number of UAS to be used; o Name and certificate number of UAS PICs involved in the aerial filming; o A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list ofthose who gave permission must be made available to the inspector upon request; o Signature of exemption holder or representative; and o A description ofthe 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. • Flight operations may be conducted closer than 500 feet from participating

15persons consenting to be involved and necessary for the filming production, as specified in the exemption holder's MPTOM. ON-SITE PROCEDURES 

### The on-siteprocedures undertaken bySDIare conductedin accordance with and controlledthrough an extensive use of checklists. Forthis reason thefollowing sectionsrepeatedlyreferto various checklistsfoundinAppendixA of thisManual.

• Site Survey- In advance of operations, a survey is undertaken to review the site, its terrain, structures and surroundings- to check any assumptions made about the location prior to arrival and to adjust the operations plan accordingly. For this, an On-Site Survey Checklist is used (see Appendix A, page 25}. The primary purpose ofthe site survey is to make avisual check ofthe operating area with the objective of identifying any potential hazards.

• Selection of Operating Areas and Alternatives- In advance ofthe pre-flight On-Site Survey, Google maps will be consulted and- if possible- the local site will be visited beforehand. The site will be specifically checked in terms of: o Proximity to Airport Reference Points (ARP} as denoted in the Airport Facility Directory (AFD}. Must operate outside 5 miles ofARP, unless otherwise agreed upon by virtue ofwritten letter of agreement with the airport's management, or otherwise permitted by the COA issued to Photographic Solutions o Ability of PIC and VO to operate the UAS clear of, and give way to, all manned aviation operations and activities at all times. o 500ft. clearance of all non-participating persons, vessels, vehicles, and structures unless; A. sufficiently protected in the event ofan accident, and the nonparticipating persons remain protected at all times during operations ofthe UAS, and 

### B. The owners and controllers of any vessels, vehicles, or structures has granted permission for the operating closer to those objects and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that it does not present an undue hazard.

16o Ability of SDI to conduct operations over private or controlled access property with permission from the owner/controller or representative of such, and said permissions are granted. o Proximity to radio interferences o Prevailing weather conditions have been adequately assessed, including; high winds, convection, visibility, minimum cloud clearance {500ft below, and 2,000 ft horizontal clearance), or when visibility is less than 3 miles from the PIC.
The primary site for take-off and landing will be assessed (size, shape, surface, slope and surroundings) and an alternative site will be identified should the primary site become unavailable or unsuitable.

• Boundaries- SDI requires that proper identifiers and signage will be in place in the operating area to alert people to the fact that aerial work is being conducted. The PIC will be responsible for cordoning to ensure safe distances from operations are observed. Cordoning procedures to be practiced include: o Take-off and Landing safety Area: PIC will determine the safe distances ofall people from the take-off and landing operation ofthe UAS. The PIC will also establish a cordoned area with clearly marked delineation the take-off and landing operations. o Signage and Identifying Clothing: The PIC will place signage at each entry point within the operations area alerting people to the following: A. Low altitude aerial work is being conducted B. Use of any actual sensing equipment being used C. A request asking people to not enterthe area without first notifying the PIC or SDI designated on-site flight operations personnel D. PIC and VO will put on outerwear that will identify them in their respective roles. Signage will be attached on their person that will instruct law-enforcement, observers, or any other people present that they are not to be interrupted un-necessarily while conducting flight operations.

17• Anemometer Weather Check- Beyond pre-site planning weather forecast checks, SDI requires that the PIC conduct specific on-site weather checks. The PIC will utilize a hand-held or portable Anemometer to determine wind speed, direction, temperature, and humidity. Aerial operations will only be conducted within the specific recommended wind and humidity limitations ofthe UAS manufacturer's operating manuals, or if not identified therein, only in conditions where wind speed is less than 15mph, gusting up to 20mph.

• Crew Briefing- SDI flight operations personnel will typically include the PIC, VO, and other possible ground crew. The operations personnel, in addition to any other parties that may be present, will be briefed prior to the start of operations. The briefing will include: o Introduction to the equipment being used including the UAS and the ground station functions, with particular emphasis on moving parts including weight ofthe UAS, and the harm or damage that could possibly be inflicted by coming into contact with those components {particularly the propellers, and hot surfaces) o Familiarization with the failsafe return-to-home systems and instruction on how to activate those systems ifthe PIC is unable to activate those systems o Expected flight plan, holding positions, flight duration, and overall flight boundaries. o Expected responsibilities and authority of each flight operations personnel o Identification and familiarization with the take-off and landing designated areas, and the requirements for remaining clear of those areas at all times. o The need for all present to alert the PIC of any encroachments of people or objects into the airspace and ground boundaries o Importance of mitigating any possible distractions or unnecessary communication with the PIC during operations o Careful review of Lost Link and emergency procedures • Communications- SDI uses channel-hopping technology on 2.4GHz to maintain communications with the UAV for the purposes of platform control. There is no communication ('downlink') from the UAV to the

18ground station. In the event of loss of or interference with the control frequency, the UAV is programmed to return to its take-off position and land autonomously ('return-to-home'}. This failsafe procedure is described further under Emergency Procedures.

• Frequency Scans- SDI will perform frequency scans to help identify possible conflict with radio communications. This will be performed via a hand-held or portable radio spectrum scanner by the PIC. These scans will include a full spectrum scan ofthe applicable frequency range ofthe UAS. Possible sources of radio interference or conflict will be identified and evaluated to determine ifflight operations can be safely continued.

• Recharging and Battery Use (Fuel Management)- The DJI Inspire utilizes a 4,500mAh 22.8 V LiPo {{intelligent" battery. Batteries are charged at base prior to flight operations. The number of batteries that will be transported to the flight operations area will be based on the specific needs ofthe flight operations or mission. The battery capacity will be tested utilizing the internal proprietary tester on the battery, and will also be checked utilizing the proprietary DJI software, as well as any internally sensed telemetry software and hardware attached to the UAS. A battery charge log will be kept via the proprietary DJI Inspire software and will be completed prior to every flight. Any battery found to be less than fully-charged, damaged, displays insufficient voltage, or otherwise defective will not be used.

• Load-outs and Equipment- The lnpire is a simple quad-copter UAS with limited capability for loads and equipment. Removable equipment includes the battery, gimbal, camera, telemetry hardware, antenna, and imaging transmitter. The battery is held in place via proprietary fittings. The gimbal is attached via screws into the airframe. The camera is attached to the gimbal using screws and a proprietary harness. All other equipment is attached using nylon fittings, Velcro, or adhesives. Total takeoffweight with these components will not exceed the maximum recommended takeoffweight identified in the Inspire Users/operators Manual of 2935 grams. Payload security is tested prior to any operations both visually and by vigorous tactile testing. All attachment points will be inspected and tested weekly.

19

## FLIGHT PROCEDURES
SDI will utilize checklists to directthe flight operations personnel in flight procedures. The following section will continually refer to the several checklists presented in the Appendix.

• Motor Start- All ofthe various preflight checks will have been performed priorto motor start and will include: o PIC and VO will put on identifying outerwear. o Pre-flight compass calibration, GPS verification, and voltage diagnostics completed. o Take-off position and location is checked to ensure it is clear of obstacles, debris, potential hazards, and people. o Transmitter switches are placed in the proper configuration, including the home switch and GPS mode switch. o Transmitter is on and properly charged with voltage confirmed. o Battery is secured, on, and properly seated. o Camera and gimbal is armed, responding to commands, and stabilized. o UAS is placed in the proper takeoff position. o LED flight mode indicator, and telemetry read-out shows adequate GPS connectivity according to the DJI Inspire User/operators Manual. o LED flight mode indicators and telemetry read-outs show the proper flight mode is selected DJI Inspire User/operators Manual. o Camera is switched on. o All flight operations personnel are in their proper position and at the ready. o Start motors, and establish functional pre-take-off power setting.



### • Take-Off- Once motors have been started, the PIC will verifythat the pretake-off checklist has been completed. Once this has been verified, the PIC will follow the following take-off procedure: 1. Apply power for a controlled ascent to a safe low-level test altitude over the take-off area, and then hold. 2. After in hold, PIC performs check of all control stick response including rudder, aileron, elevator, and throttle to ensure proper response to commands.

203. PIC confirms with VO that the flight operations area is free of obstructions or other manned or unmanned air traffic. 4. PIC confirms with all flight operations personnel that they are ready to proceed with flight operations as planned.



### • In-Flight- SDI requires that the PIC is free to concentrate on positioning, scanning, and monitoring systems and the flight operations area without un-necessary distraction, and to ensure the flight is compliant with remaining 500ft clear of all non-participating persons, vessels, vehicles, or structures unless proper permissions have been obtained as described in the previous section addressing the selection of sites. Throughout the flight, PIC will take particular care to remain within the established operating permissions and envelope by executing the following practices: o Verify through verbal communication with the VO that they are alerted to any manned or unmanned aircraft within the flight area. o Verify through verbal communication with the VO that obstacles are being identified and avoided. o Interval monitoring ofvoltage and communication with UAV to ensure adequate voltage according to the DJI Phantom 2 User/operating Manual for safe return and landing. o Monitortime since motors were started to ensure a minimum of 3 minutes of batteryfuel is available for return and landing of UAV. o A safety margin of a minimum of 3 minutes of battery life is maintained at all times. o Maintain visual contact with flight systems/mode and battery LED light indicators at all times. o Maintain situational awareness of changes in weather, visibility, or cloud avoidance at all times. o Maintain operation speeds less than lOOmph. o Maintain visual contact with UAV at all times. o Ensure VO has visual contact with the UAV in flight at all times. Establish a position hold until VO re-establishes visual contact with the UAV if contact is lost.



### • Let-Down/Landing- To execute a safe recovery and landing ofthe UAV, the PIC will ensure that the following practices are followed:

21o Establish and guide the UAV through a safe route to directly above the cordoned take-off and landing area. o Maintain a safe descent rate and follows all procedures and techniques to avoid vortex state or settling with power. o Verify that a minimum of 3 minutes of battery life is available, as mentioned above, to ensure a holding position ifthe landing area is not cleared. o Verify that the landing area is clear of debris, obstacles, people, or hazards that would preclude a safe landing.

• Shutdown- Upon landing, the throttle is returned to the home position causing the rotors to stop spinning. Operations then proceed as follows: • The UAV battery is switched off or disconnected. • The camera is stopped and is then switched off. • The UAV is removed from the landing area and is checked for any abnormalities or damage. • The transmitter is switched off. • The UAV battery is removed, tested, and then the battery is safely secured and stored.

22

## EMERGENCY PROCEDURES
The emergency procedures described below address the following, safety-critical question: 

### In the eventof amalfunctionfailure orotherin-flight**emergenc~** 

### how is the UASgoing to safelylandwithoutcreatinga hazardto otherairspace users orpersons orpropertyon theground?
MOTOR THRUST LOSS As a quad copter, The Phantom 2 has no 'rotor redundancy'. Loss of power to a motor on a quad copter will result in a crash. For this reason, SDI takes specific preventative steps to ensure that loss of powerto a motor will not occur: • Wiring integrity is checked visually prior to any flight operations. • A pre-flight battery check is undertaken to test the charge ofthe cells. • Upon take-off, the UAS is lifted into atemporary, low-altitude holding position and the throttle/ rudder and aileron/elevator control sticks are moved to check that UAV is responding as expected.
Ifthere is a loss ofthrust to a motor, any residual control left available to the PIC will be used to guide the UAV away from people and objects to avoid injury or damage to property and people. Every effort will be made to restrict the crash site to the safest possible position.
UAV BATTERY FAILURE As has been addressed in above previous sections, SDI has procedures and practices in place designed to prevent UAV batter failure or malfunction, and they include: • The batteries are physically inspected and tested through all phases of preflight and post flight for damage or swelling • The Battery performance and condition is tested prior to each flight to ensure they are fully charged, and the proprietary DJI Inspire software charge track/log is checked to ensure the battery meets the minimum safe requirements as specified by DJI in operating manual and firmware specs. • Throughout all phases offlight, the battery voltage, percentage of charge remaining, and time in operation is constantly monitored via the telemetry transmission to the ground station to ensure there is the proper minimum voltage and time to return and land is achieved and maintained. • The PIC will immediately land the UAV in the nearest possible landing area
23iftelemetry indicates the minimum voltage, time in operation, or percentage of charge are not met.
BATIERY FAILURE FAILSAFE As a preventative measure to keep the UAV from a forced landing or crash due to battery failure, the DJIInspire flight controller has several levels of lowvoltage protections incorporated as specified in the attached User/Operator's Manual, triggering an automated Failsafe Return to Home and Landing command as follows: • The low battery capacity warning alerts users when the battery is close to depletion during flight. When it appears, users should promptlyfly back and land to avoid accidental damage. The Inspire has two levels of low battery capacity warning. The first appears when the battery has less than 30% power and the second appears when it has less than 15% power. The following list details the battery power warnings: o When battery power drops below 30% the LED indicator will blink red slowly. o At lower than 15%, the LED indicator will blink red rapidly. The Phantom 2 will also begin to descend and land automatically. After it has landed, keep the throttle stick at its lowest point or execute 

# esc. o There is a hidden third low battery threshold in addition to the 1st and 2nd level warnings. This uses 10.65V as its threshold. Both this voltage threshold and the 2nd Level Low Battery Warning will trigger auto-landing. • Altitude can be maintained if necessary by pushing up on the Throttle stick

. 

# ..... 1st Level Low Battery Capacity Warning 

# •••••• 2nd Level Low Battery Capacity Warning 

# ••• NotStationaryorSensor Bias istoo big Errors 

### &Aircraft cannotfly.* 

# • 

# • • Compass data abnormal because offerro-magnetic interference or the compass needs calibration.

24TRANSMITTER/CONTROLLER BATTERY FAILURE As has been mentioned previously, through the extensive use of checklist procedures, SDI requires that the PIC ensure the DJIInspire controller (ground station) will be fully charged prior to any aerial operation. Any monitors being used to display telemetry will also be fully charged. CONTROLLER BATTERY FAILSAFE SDI will use The DJIInspire flight control system that incorporates an automated failsafe system which commands the UAV to return to home and land ifthere is a loss offrequency due to battery failure. The PIC will reference the below LED lighting system to monitorthe controller charge;
Remote Controller Power LED Indicator Status
None Normal 

# •••••• 8-8-8...... Low voltage (at 4V-4.3V). Replace the batteries immediately 

# •••• Alert will sound after 15 minutes of inactivity. Itwill stop 8--B--B

..... . once you start usingthe remote controller.

The remote controller will power off automatically when battery voltage drops below 4V. Land and change batteries as soon as possible when the low voltage alert occurs to avoid loss ofcontrol during flight. LOSS OF CONTROL FREQUENCY {and/or Ground Station Failure} To help prevent a loss of control frequency, SDI requires that the PIC ensure flight operations only occur within un-aided visual line of site VLOS at all times. Doing so will keep the UAV well within the required minimum range ofthe DJI Inspire controller/transmitter. LOSS OF CONTROL FREQUENCY FAILSAFE Ifthe control frequency signal is lost for more than 3 seconds (UAS out of range, ground station failure etc.) the DJI Inspire Flight Controller has been programmed to switch the UAS into failsafe mode and it will'return to home' (RTH} and also land: • Ifthe failsafe occurs while in GPS mode according to the parameters of the DJIInspire User/Operator Manual, the UAV will return to the take-off

25and landing area and auto-land. • Ifthe fail location occurs while in ATil mode according to the parameters ofthe DJIInspire User/Operator Manual, the UAV will auto-land. • The RTH failsafe mechanism works by the UAS Flight Controller saving the home (take-off) point automatically when the throttle stick is moved for the first time (after 6 or more GPS satellites have been acquireddenoted by a single red pulse from the LED or a series of continuous green pulses).
The RTH failsafe function on the UAS is tested on a weekly basis by SDI by switching the transmitter off during atest flight session. MALICIOUS OR ACCIDENTAL INTERFERENCE WITH CONTROL FREQUENCY As was mentioned in previous sections, through the extensive use of checklists, SDI requires that the PIC utilize a Spectrum Scanner to ensure there is no accidental or malicious radio interference. In the unlikely event that this should occur, the PIC will initiate the failsafe procedure mentioned in the previous section

• Pilot Incapacitation- Ifthe pilot-in-command becomes incapacitated to the extent that control ofthe UAV becomes unviable, the UAV will hover in a stationery position until the battery's second level low-voltage protection is triggered. At this point, the UAV will descend and land in a steady, controlled manner. If an observer is present, they will have been briefed on the UAS's failsafe (return-to-home) mode and its activation (see Section on "Crew Briefing").

• Aircraft Incursion- If another aircraft should enter or appears to be entering the Visual Line of Sight Operating Envelope VLOS, PIC will operate the UAV to immediately maintain safe visual separation, and give way to any manned flight operation.

26FLY AWAY PROCEDURE A "fly away" is defined as the loss of control transmission link where the PIC no longer has control orthe ability to command the UAV to remain within the bounds ofthe intended operation area. In the unlikely event that this should occur, the PIC will observe and record the direction offlight heading, speed, and altitude ofthe UAV, and then follow the Incident Response Procedure as outlined below: • Crash 

### & Incident Response While SDI takes extreme caution in its flight procedures to prevent a loss of control or crash, any incident, accident, or operation that transgresses the lateral orvertical boundaries as defined by the applicable COA issued must be reported to the FAA UAS Integration Office {AFS 80 within 24 hours. The following procedures will also be ensured by the PIC: o PIC will have on their person a copy ofthe local emergency response contact information, including fire, law enforcement, medical response, and the UAS Integration Office contact information

27Slf1UNS'I'ON ))J(;I'J'JU UlllmNH 

# AppendixA
Checklists

28

### PRE-FLIGHT START-UP CHECKLIST: o Verify all transmitter, on-board aircraft and camera batteries are fully charged (confirm voltages). o Ensure no frequency conflicts with video and transmitter 

## I receiver. D Check all control surfaces for signs of damage, loose hinges, and overall condition. Inspect the wings 

## I rotors to ensure they are in good structural condition and properly secured. o Check motor

## I engine and mounting attachments to the airframe. o Inspect propellers 

## I mounting hardware (tight) 

## I rotor blades for chips and deformation. o Check the landing gear for damage and function. o Test electrical connections (plugged in and secure). o Ensure photo 

## I video equipment mounting system is secure and operational. o Check location of GPS equipment controlling the autopilot. o Check the IMU movements in the ground control software. o UAV in stabilization mode, ensure control response move toward the correct positions. o UAV 

## I Drone is in a level location safe for takeoff. D FPV 

## I Power up ground station. o FPV 

## I Power up Video receiver. o If using Video recorder, turn on camera system. o Camera settings are correct (still images, video, frame rate). o SD camera memory clear and inserted into the camera. o Action 

## I Start filming. o All transmitter controls move freely in all directions. o All transmitter trims in neutral position. o All transmitter switches in correct position (typically away). o Transmitter throttle to zero. o Radio transmitter on. o Connect 

## I power on batteryto airframe. o Ensure led indicators and audible tones are correct. o Timer on (if applicable). o FPV, confirm video is in monitor

## I goggles. o Scan for nearby cars 

## I people 

## I animals. D SayuCLEAR!". o Arm flight controller.

29o Increase throttle slightly listening for any abnormalities. o Short 20-30 second hover at 3-5 feet (listen for vibrations 

## I loose items). o Confirm Voltage levels are correct.

30

### PRE-FLIGHT INSPECTION CHECKLIST: 

### D Perform initial walk-around. 

### D Inspect UAV for cracks in joints and structural members. 

### D Inspect UAV for loose or damaged screws, ties, fasteners, straps. 

### D Inspect UAV for loose or damaged wiring. 

### D Inspect UAV for loose or damaged connections (solder, plugs, etc.). 

### D Inspect prop mounts and screws and apply slight counter pressure on arms to check for loosened components. 

### D Ensure antennas and masts are secure. 

### D Inspect 

## I clean FPV Camera and Lens and insure it is secured and connections are firmly attached. 

### D Ensure camera settings are correct (still images, video, frame rate). 

### D Ensure FPV Transmitters are secure and operational. 

### D Ensure batteries are fully charged, properly seated and secured. 

### D Ensure the following fail-safe equipment is functioning: 

### D RTH (return to home). 

### D Recovery Command Response (toggle test). 

### D Firmware Airport Proximity Detection. 

### D Ensure props are smooth and free of damage 

## I defect (check blade, surface and hub). 

### D Ensure prop adapters are tight 

## I secure. 

### D Ensure voltage alarm is connected. 

### D Ensure arming 

## I idle timeout is properly configured. 

### D Ensure correct model is selected in transmitter (if applicable). 

### D Check RC transmitter for the correct range and centering for all sticks. 

### D Perform range test.

31

### IN-FLIGHT CHECKLIST: 

### D Basics: Ifflying manually, always keep your fingers on the controller/transmitter. 

### D Never letthe UAV out ofyour sight even for a second. 

### D Climb to a safe altitude away from potential hazards and to reduce noise pollution. 

### D Keep aircraft at a safe operating distance from people, electric utility lines and buildings. 

### D Ifthe UAV must be flown over buildings or people, use a lightweight UAV and maintain a safe altitude for recovery and make every effort to minimize exposure. 

### D Spotter: Use a spotter whenever possible and appropriate, especially when flying by First Person View {FPV). 

### D Do not fly UAVs within distance defined by local laws of any private/commercial airport/helipad. 

### D Do not fly around a pre-existing UAV flying site without afrequencymanagement agreement. 

### D Do not interfere with operations and traffic patterns at any airport.

32

### LANDING CHECKLIST: D Regardless ofwhether of a manual or automated UAV landing, scan landing area for potential obstruction hazards. 

### D Announce out loud {{Preparing to Land". D Use a safe descent rate and follow correct procedures to avoid a vortex state or settling. D Carefully land the aircraft away from obstructions and people. D Turn the power offto the aircraft and/or disconnect the batteries. D Turn offthe transmitter. D Turn the power offto the photo equipment. D Visually check aircraft for signs of damage and/or excessive wear. D Remove the unused fuel if applicable. Secure the aircraft. D Check pictures: Verify that the UAV camera actually tookthe pictures. 

### D LOG FLIGHT.

33SW1UNSl'ON nm1'1'1U UIJl{;JNG 

# Appendix B
Maintenance Logbook

34Date 

### Swainston Digital Imaging MAINTENANCE LOGBOOK Component Maintenanc Maintenanc eActivity eTime

35 CommentsSlfi\INS'I'ON nl(rl'l'iU UIJl(;ING 

# Appendix C
Incident/ Accident Logbook

36Date of Time of Incident/ Incident/ Accident Accident 

### Swainston Digital Imaging INCIDENT/ ACCIDENT LOGBOOK Name of Injured Incident/ Accident Action Taken Details

37 NotesSW1UNS'I'ON UUJI'1'1U**1111\.HI~G** 

# Appendix 

# D Flight Record Log Book

38

### Swainston Digital Imaging FLIGHT RECORD LOGBOOK (Sample Page) Date Location Activity Flying Time Battery Battery Comments Before After

39

# Appendix E
DJI Inspire User Manual

40

# INSPIRE 1 User 

## Manual [v1.o 

## l
2015.3