Dow's Aerial Photography

Unmanned Aircraft System

Operations Manual

Rev3

(Jan 11, 2016)

TABLE OF CONTENTS

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Unmanned Aircraft Systems Operations Manual

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Unmanned Aircraft Systems Operations Manual

1. Preface

The following procedures are intended to promote safe, efficient and lawful operation of

the DOW'S AERIAL PHOTOGRAPHY unmanned aerial system (UAS). Safety, above

all else, is the primary concern in each and every operation, regardless of the nature of the

mission.

 2.Philosophy & Mission Statement

It shall be the mission of those personnel of DOW'S AERIAL PHOTOGRAPHY who are

trained in the use of unmanned aircraft systems (UAS), to use this resource for Aerial

Land Surveying, Action Sports Videography and or General Commercial Aerial

Photography.

It shall be the intent of every UAS operator to make reasonable effort to not invade a

person's reasonable expectation of privacy when operating the UAS. When operating the

UAS, DOW'S AERIAL PHOTOGRAPHY operators abide by all FAA Regulations for

flight and receive the proper authorization for flight. 

3. Protection of Rights and Privacy

UAS operators and observers ensure the protection of private individuals’ civil rights and

reasonable expectations of privacy before deploying the UAS. UAS operators and

observers ensure and are held accountable for ensuring that operations of the UAS

intrude to a minimal extent upon the private persons and businesses. To accomplish this

primary goal, DOW'S AERIAL PHOTOGRAPHY observes the following:

1. When the UAS is flown, the on board cameras are turned so as to be facing away

from occupied structures, etc. to minimize inadvertent video or still images of

uninvolved persons or property.

2. DOW'S AERIAL PHOTOGRAPHY does not conduct random surveillance

activities. The use of the UAS is tightly controlled and regulated.

3. All authorized missions for DOW'S AERIAL PHOTOGRAPHY UAS are for:

a. Aerial Land Surveying, Action Sports Videography, General Commercial

Aerial Photography

4. A committee is formed and meets semi-annually for the purpose of reviewing the

existing UAS procedures as well new technologies, laws, and regulations on UAS

usage. The committee consists of personnel from DOW'S AERIAL

PHOTOGRAPHY and business partners and advisers. 

5. DOW'S AERIAL PHOTOGRAPHY UAS operate strictly within the law and

regulations. If in doubt, prior to operating the UAS we ensure that the proper

forms and applications are applied for and obtained. We balance all operations

with the need to accomplish the mission while maintaining public privacy and the

freedom from intrusion.

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4. Definitions

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air.

2. Airport: a landing area used regularly by aircraft for receiving or discharging

passengers or cargo.

3. Civil aircraft: an aircraft except a public aircraft.

4. Landing area: a place on land or water, including an airport or intermediate

landing field, used, or intended to be used, for the takeoff and landing of aircraft,

even when facilities are not provided for sheltering, servicing, or repairing

aircraft, or for receiving or discharging passengers or cargo.

5. Administration 

5.1 Operations Manual

1. The policies and procedures contained in this manual are issued by DOW'S

AERIAL PHOTOGRAPHY. As such it is an official business document of

DOW'S AERIAL PHOTOGRAPHY.

2. This manual is not intended to be all-inclusive, but as a supplement to other

company guidelines, Federal Aviation Administration regulations, pre-flight

safety checklists, aircraft manufacturers' approved flight manual, etc.

3. This manual is been written to address UAS operations as they existed when it

was drafted. Equipment, personnel, environment (internal and external), etc.,

change over time. The management of change involves a systematic approach to

monitoring organizational change and is a critical part of the risk management

process. Given this, it is essential that this manual be continually updated as

necessary. The entire manual must be reviewed, at a minimum, annually to assure

it is up to date. Any changes to the manual will be communicated as currently

dictated by company policy.

4. A copy of the manual (electronic and/or paper) is issued to every person having

UAS responsibilities.

5.2 Organization

1. The UAS unit is comprised of those personnel approved by DOW'S AERIAL

PHOTOGRAPHY and includes operators, observers and others deemed necessary

and an have assignment as part of the UAS crew.

2. Assignment to the UAS crew is carefully selected by DOW'S AERIAL

PHOTOGRAPHY from specially trained staff members of DOW'S AERIAL

PHOTOGRAPHY with knowledge of the airspace within which the operation will

take place and how that airspace fits into the National Airspace System (NAS).

5.3 Personnel

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1. The UAS flight coordinator or pilot-in-command (PIC) is responsible for the

overall direction and performance of the UAS unit and exercises command and

control over it. 

2. UAS Coordinator Responsibilities:

a. maintaining all training, flight and maintenance records for each operator

and observer as well as individual airframes;

b. maintain contact with the FAA and regulations as they change

c. evaluate airframes based on mission needs;

3. Operators:

a. To be considered for selection as an operator, applicants must meet the

requirements for and successfully pass a DOW'S AERIAL

PHOTOGRAPHY administered UAS Operators Course in order to be

accepted into the UAS crew.

b. Operators interacting with Air Traffic Control (ATC) or Terminal Radar

Approach Control Facilities (TRACON) shall have sufficient expertise to

perform that task readily. Operators must have an understanding of, and

comply with FAA Regulations applicable to the airspace where the UAS

operates. 

c. An operator's primary duty is the safe and effective operation of the UAS

in accordance with the manufacturers' approved flight manual, FAA

regulations and company policy and procedures. Operators must remain

knowledgeable of all FAA regulations; UAS manufacturer's flight manual

and bulletins and company policy and procedures. 

d. Operators may be temporarily removed from flight status at any time by

the UAS coordinator, for reasons including performance, proficiency,

physical condition, etc. Should this become necessary, the operator will be

notified verbally and in writing of the reason, further action to be taken

and expected duration of such removal.

e. The UAS Coordinator shall maintain a file for each operator which shall

include copies of training records, flight incidents, etc. This file is

reviewed in accordance with current company policy and procedures.

4. Observers

a. Observers must have been provided with sufficient training to

communicate clearly to the operator any turning instructions required to

stay clear of conflicting traffic and obstacles. Observers receive training

on rules and responsibilities described in 14 CFR 91.111, Operating Near

Other Aircraft, 14 CFR 91.13, Right-of-Way Rules, cloud clearance, inflight visibility, and the pilot controller glossary including standard ATC

phraseology and communication. 14 CFR 91.17, Alcohol or Drugs,

applies to UAS observers.

b. An observer's primary duty is to operate the UAS's equipment including

cameras, FLIR, radio communications with other crew members and

property owners as well as be an observer for anything that may affect the

operator's primary duty (see and avoid).

c. The UAS Coordinator maintains a file for each observer, which includes

copies of training records, UAS incidents, etc. 

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5.4 Facilities

1. UAS operations are housed and maintained at a facility designated by DOW'S

AERIAL PHOTOGRAPHY.

2. Personnel must not leave the designated facility without making sure the UAS

equipment is secured.

3. All personnel are equally responsible for maintaining the facility in a neat, clean

and orderly fashion.

5.5 Scheduling

1. To facilitate the broad use of the UAS, it shall be made available to all UAS flight

crew members.

2. To maintain a level of proficiency with the UAS, operators are required, as part of

their acceptance into the UAS flight crew, to attend training every two months.

Training is coordinated through the UAS flight crew and announced in advance

for scheduling purposes.

5.6 Miscellaneous

1. Inquiries from the news media must be forwarded to the DOW'S AERIAL

PHOTOGRAPHY Chief Executive Officer. Operators/Observers shall follow

currently established company policy regarding interactions and inquiries from

the media.

2. Requests for support from third-parties will be responded to by the UAS

coordinator. Should the request involve an immediate threat to life, or property,

the operator is authorized to accept or decline the request. Proper policy and

procedure, as well as FAA regulations must be followed when accepting mutual

aid support for the UAS.

3. Complaints or inquiries regarding UAS operations must be referred to the UAS

coordinator.

6. Safety

6.1 Safety Policy

1. DOW'S AERIAL PHOTOGRAPHY is committed to having a safe and healthy

workplace, including:

a. The ongoing pursuit of an accident free workplace, including no harm to

people, no damage to equipment, the environment and property.

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b. A culture of open reporting of all safety hazards in which management

will not initiate disciplinary action against any personnel who, in good

faith, disclose a hazard or safety occurrence due to unintentional conduct.

c. Support for safety training and awareness programs.

d. Conducting regular audits of safety policies, procedures and practices.

e. Monitoring the UAS community to ensure best safety practices are

incorporated into the organization.

2. It is the duty of every member within the UAS flight crew to contribute to the

goal of continued safe operations. This contribution comes in many forms and

includes always operating in the safest manner practicable and never taking

unnecessary risks. Any safety hazard, whether procedural, operational, or

maintenance related must be identified as soon as possible after, if not before, an

incident occurs. Any suggestions in the interest of safety should be made to the

UAS Coordinator.

3. If any member observes, or has knowledge of an unsafe or dangerous act

committed by another member, the UAS coordinator is to be notified immediately

so that corrective action may be taken.

6.2 Operational Hazard and Occurrence Report (OHOR) and Investigations

1. Occurrences are unplanned safety related events, including accidents and

incidents that could impact safety. A hazard is something that has the potential to

cause harm. The systematic identification and control of all major hazards is

foundational to safety.

2. The OHOR concept provides a mechanism to report hazards and occurrences, real

and perceived, to those responsible for UAS operations.

3. There is no specific format for the OHOR as the information provided is what is

important, not the format and should be used without hesitation to report any

anticipated, current, or experienced safety hazard, or occurrence. Further, the

OHOR can be submitted anonymously, and to whatever level in the chain of

command, to get the matter proper attention, without fear of reprisal.

4. Written memorandums fully explaining the problem will be given to the UAS

coordinator for investigation.

5. Every hazard and/or occurrence is investigated, with the results and corrective

action taken communicated to all members. The investigation will be conducted

by the UAS coordinator or any other member of the company who has the

technical skill necessary to do it. The services of an independent subject matter

expert may be necessary in some cases to assure a thorough and complete

investigation.

6. Hazards requiring immediate attention will be brought to the attention of the UAS

coordinator, verbally, without delay.

7. ALL MEMBERS ARE AUTHORIZED TO TAKE ACTION TO CORRECT A

HAZARD if in that member's opinion delay will result in accident or injury. The

UAS coordinator will be notified immediately in such situations.

6.3 Safety Officer - Operator/Observer/Coordinator

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1. In regards to safety, all members of the UAS flight crew are responsible for the

following:

a. Ensuring all flight operations personnel understand applicable regulatory

requirements, standards and organizational safety policies and procedures.

b. Observe and control safety systems by monitoring all operations.

c. Review standards and the practices of company personnel as they impact

operational safety.

d. Communicate all reported safety related problems and the corrective

action taken. If there were any in-flight problems (or learned experiences),

the proper procedures for handling that problem should be discussed.

e. Copy and circulate pertinent safety information.

f. Copy and circulate emergency safety bulletins.

g. Place any electronic copies of safety information or bulletins in a

conspicuous location for all employees to access.

h. It is emphasized again that safety is the responsibility of ALL members of

the UAS unit.

6.4 Safety Training

1. All members shall receive training in the following subjects prior to operating the

UAS: 

a. Company commitment to safety

b. Company policy

c. UAS member's role in safety

d. Emergency safety procedures

2. All members shall review the company safety policy and procedures on an annual

basis and that review shall be noted in their training history.

6.5 Medical Factors

1. Operator and Observers shall only deploy the UAS when rested and emotionally

prepared for the tasks at hand.

2. Physical illness, exhaustion, emotional problems, etc., seriously impair judgment,

memory and alertness. The safest rule is not to act as an operator or observer

when suffering from any of the above. Members are expected to "stand down"

when these problems could reasonably be expected to affect their ability to

perform flight duties.

3. A self-assessment of physical condition shall be made by all members during preflight activities.

4. Performance can be seriously hampered by prescription and over-the-counter

drugs. The UAS Coordinator must be advised anytime such drugs are being taken.

If it is determined that the medication being taken could hamper an operator or

observer, that member shall be prohibited from the deployment or exercise.

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5. No member shall act as an operator or observer within eight hours after

consumption of any alcoholic beverage, while under the influence of alcohol, or

while having an alcohol concentration of 0.04 (FAR 91.17)

7. Training

7.1 Objective

1. The key to continued safe operations is by maintaining a professional level of

competency. The first step in this process is establishing minimum qualifications

for selecting members, and the second step involves training those personnel.

7.2 Instructors

1. If any members are FAA certified flight instructors, they are given instructor

duties. Such duties can include developing training courses, provide training, and

student evaluation and documentation.

2. Duties of instructing new members shall fall upon those who have the most flight

time and knowledge of UAS operations. Instructors are designated by those

within the unit and approved by the UAS Coordinator.

7.3 Training Plans

1. All members have a training plan on file that outlines training objectives for the

upcoming year. This training plan will be held in conjunction with the member's

normal training file per company policy.

2. The approved training plan is developed by the UAS coordinator.

3. All deployments or exercises are documented and count toward a member's

training.

4. It is the member's responsibility to verify their training file contains all pertinent

information.

7.4 Initial Training

1. Observers and Operators must have completed sufficient training to communicate

to the pilot any instructions required to remain clear of conflicting traffic. This

training, at a minimum, shall include knowledge of the rules and responsibilities

described in 14 CFR 91.111, Operating Near Other Aircraft; 14 CFR 91.113,

Right-of-Way Rules: Except Water Operations; and 14 CFR 91.155, Basic VFR

Weather Minimums; knowledge of air traffic and radio communications,

including the use of approved ATC/pilot phraseology; and knowledge of

appropriate sections of the Aeronautical Information Manual.

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2. In conjunction with fulfilling all training requirements for operator/observer

duties, the new member must also become familiar with UAS operations, the

aircraft and its equipment.

3. Any new member who fails to successfully complete the initial training may be

denied as a member of the UAS flight crew.

4. Before a member can fly as an operator, they must complete at least 40 hours of

flight training with the UAS instructors to show proficiency of the flight training

exercises and the airframe. This must be accomplished to show their ability and

knowledge of the UAS.

7.5 Recurrent Training

1. All members within the unit shall maintain proficiency in their operator/observer

abilities. Members who do not have any documented training or flight time within

a span of 90 days will have to show proficiency before being an operator/observer

during a deployment or exercise.

2. Recurrent training is not limited to actual operating/observer skills but includes

knowledge of all pertinent UAS/aviation matters.

3. Failure to prove proficiency can result in removal from UAS responsibilities.

7.6 Miscellaneous

1. Depending on the nature of the training request, all efforts are made to

accommodate the hours of training so as little impact is made to staffing levels.

2. All requests for training shall be approved through the member's chain of

command and timekeeping during those training hours are marked by the UAS

coordinator.

3. Members are encouraged to attend, and forward information on FAA sponsored

safety seminars.

4. Training shall only be conducted at approved locations and follow the provisions

within the approved FAA regulations.

8. General Operating Procedures

8.1 Request for UAS Support

1. Requests for UAS support shall be made through the UAS coordinator who has

the most current list of UAS operators and observers to contact.

2. Requests for UAS support can be made at any time during the day or night.

3. The UAS coordinator will submit a written Plan of Activities to the local FAA

FSDO three days before the proposed mission.

4. If a request is made for UAS support during the night, DOW'S AERIAL

PHOTOGRAPHY must contact the local FAA FSDO for approval.

8.2 Call-out Procedure

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1. The UAS coordinator will screen all initial requests to use a UAS. 

2. The UAS coordinator will then contact the PIC to request the deployment of the

UAS.

3. The UAS Coordinator will also contact the UAS flight crew who will screen the

request using the following factors:

a. Is the proposed use of UAS within the capabilities of the UAS equipment

and personnel to perform?

b. Does the proposed use of the UAS fall within the FAA and department

policies and regulations for UAS usage?

c. Can the UAS be deployed safely given current weather conditions?

d. If the UAS deployment requires a warrant has one been requested and

approved? 

e. Are sufficient trained and qualified personnel available to safely operate

the UAS?

4. The UAS flight crew will either accept or decline the request for UAS support. If

the request is denied the UAS flight crew will provide a reason for declining the

support request to the UAS Coordinator who will provide the requester this

information along with the reason for declining. If the UAS Coordinator accepts

the support request they will contact a UAS operator who will be provided all

available mission information.

5. The UAS operator will contact a certified observer from the list of available

trained observers. The UAS operator is responsible for transporting the UAS and

all required equipment to the scene. Upon arriving at the requested location the

UAS operator will contact the requester to check in and receive a briefing on the

mission requested. The UAS operator will make an on scene determination of the

ability of the UAS to perform the requested mission safely and within company

and FAA policies and procedures.

6. If the UAS operator determines that the use of the UAS would violate company

policy or directives then the UAS operator will inform the requester of the

potential conflict along with recommendations for modifying the requested

mission to conform to company policies and procedures. As this is a change from

the original approved mission the UAS operator will contact the UAS coordinator

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

mission, the UAS operator will make a full report of the circumstances and their

concern through the UAS coordinator.

7. UAS operators will have sole discretion for declaring safety or violation of FAA

rules. If the UAS operator determines that a requested mission would violate FAA

rules or endanger person or property, then the UAS operator will respectfully

inform the requester of the reasons for refusing to operate the UAS and contact

the UAS coordinator immediately. The UAS will not be flown in this

circumstance and the authority of the UAS operator is absolute.

8. If the UAS operator determines that the requested mission will potentially damage

the UAS or its associated equipment the UAS operator will inform the requester

of their concerns. The UAS operator will fully document and send a report to the

UAS coordinator.

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8.3 Deployment Priorities

1. The UAS shall not be used for the purpose of random surveillance.

2. If several separate requests for UAS support are received simultaneously, they

shall be prioritized.

3. In general terms, requests for UAS support are prioritized as:

a. .Land Surveying.

b. Action Sports Videography.

c. General Aerial Photography.

8.4 Flight Boundaries

1. Although there may be requests for UAS support in restricted airspace, FAA

regulations for UAS restrict UAS deployment inside restricted airspace.

2. At no time shall UAS support be granted inside restricted airspace without first

obtaining permission from the local FAA FSDO and approval by local authorities.

3. Maximum altitude shall not be set more than 400 feet per the FAA regulatory

standards.

4. The operator will obtain the consent of all persons involved in the mission and

ensure that only consenting persons will be allowed within 100 feet of the flight

operation, and this radius may be reduced to 30 feet based upon an equivalent

level of safety determination.

8.5 Minimum Personnel Requirements

1. Due to the nature of the mission, the minimum personnel required on ALL

missions will be an operator and observer. Under no circumstances will an

operator attempt to complete a deployment alone.

2. Although training is not considered a mission, an observer shall be used.

8.6 Personnel Responsibilities for Deployments 

OPEN COMMUNICATION ACHIEVES SAFE OPERATIONS

1. Operator

a. The operator is directly responsible for, and is the final authority over the

actual operation of the UAS.

b. Operators have absolute authority to reject a flight based on personnel

safety or violation of FAA regulations. No member of DOW'S AERIAL

PHOTOGRAPHY, regardless of status, shall order an operator to make a

flight when, in the opinion of the operator, it poses a risk to personnel or is

in violation of FAA regulations.

c. Operators are responsible for compliance with this manual, company

policy and procedure and FAA regulations.

d. The operator's main duty during the deployment of the UAS is to operate

the UAS safely while accomplishing the goals of the deployment.

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e. Operators shall see-and-avoid any obstacle that will lessen safety during

the mission.

f. Operators shall be responsive to the requests of the observer in order to

accomplish the deployment.

g. Operators shall be responsible for documentation for mission training and

updating of flight books.

2. Observer

a. Observers shall see-and-avoid any obstacle that will lessen safety during

the mission.

b. Observers are responsible for the operational aspect of the deployment.

c. Observers shall operate any attachments to the UAS, allowing the operator

to maintain complete focus on the operation of the UAS.

d. Observers shall remain alert for suspicious persons or activities on the

ground and coordinate response by other UAS flight crew members.

e. Observers shall assist the operator in the main objective of safe operations

of the UAS.

f. Observers shall be responsible for documentation for mission training and

updating of flight books.

8.7 Personal Equipment

1. Operators/Observers shall wear eye protection at all times while the UAS is in

flight. 

2. Although there is no specific uniform for the UAS unit or required for proper

operation of the UAS, the operator/observer should take necessary measures to

deploy in a professional matter, wear Hi-Visible vests when appropriate, and take

into consideration that all deployments are subject to media requests.

3. Operators/Observers will take into consideration the current weather conditions

when planning to deploy, and wear appropriate clothing to deploy comfortably.

4. There are no documented issues with the use of the radio or cellular phones

during the deployment of the UAS, but the operator/observer should at all times

take into consideration safe operation of the UAS when using a radio or another

device (use of the radio or other device is strictly prohibited by the operator

during flight).

5. Operators/Observers shall wear clothing that easily identifies them as DOW'S

AERIAL PHOTOGRAPHY UAS Flight Crew members.

9. Pre-Flight/Post-Flight Actions

9.l Inspections

1. Operators/Observers are both responsible for a thorough pre-flight inspection of

the UAS.

2. Before and after each deployment (whether a mission or training), the operator

and observer shall conduct a thorough inspection of the UAS in accordance with

the instructions contained in the manufactures user's manual.

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3. Any issues found that will put in jeopardy the safe operation of the UAS shall be

documented and resolved immediately prior to flight.

4. It has been recognized that the use of a checklist is a significant method to combat

UAS accidents. A pre-flight checklist is contained with each UAS Base Station

and is utilized prior to each flight.

5. Any physical equipment that cannot be resolved on-site, and which have an

impact on safety or the mission, will override the deployment. These issues will

be resolved before flight.

9.2 Weather

1. Before each deployment the operator/observer will ensure that he/she gathers

enough information to make themselves familiar with the weather situation

existing throughout the area of deployment. The operator shall utilize FAA

approved weather resources to obtain the latest and most current weather

conditions.

2. An anemometer should be utilized in order to better estimate the wind speed and

determine if it is within the capabilities of the airframe being flown.

3. Operators/Observers should use the Beaufort Scale when making deployment

decisions in regards to wind conditions. 

4. The weather conditions reported for the operation shall be recorded in the preflight checklist.

5. The operator shall ensure that the flight will occur within FAA VFR weather

requirements.

9.3 Documentation 

1. Inspection and weather will be documented prior to flight within the log book.

2. After each flight, the operator will complete a statement documenting the UAS

operations.

9.4 Planning

1. The operator/observer shall familiarize themselves with all available information

concerning the deployment including, but not limited to, the weather conditions,

hazards, description of the incident, deployment goals, etc.

2. Operators will ensure that the location for take-off and emergency landing is

adequate for a safe deployment.

a. The take-off/landing area should be clearly marked and identifiable with

short cones.

b. At least one emergency landing area should be identified per deployment.

3. Operators will ensure that they are aware of their surroundings in the event that an

emergency landing is necessary. This includes the ability to recover the UAS.

9.5 Checklists

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1. Operators shall utilize pre-flight checklists to ensure the highest level of safety for

deployment.

2. Prior to flight, the flight log shall be initiated.

9.6 Maintenance

1. Although there are few parts on the UAS that need servicing, it is necessary that

the manufacturer's maintenance schedule is followed and properly documented.

2. Any issues that arise during maintenance that cannot be resolved by routine

methods shall be forwarded to the manufacturer for further technical support.

9.7 Other

1. Operators/Observers will ensure that no items are attached to the UAS prior to

flight that are not required for safe operation and to complete the mission goal.

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