Date: June 2016 Revision: Original Page 1 of 14 Copyright protected, Traverse Legal, PLC. All Right Reserved.



# Unmanned Vehicle System Flight Operations Manual For Flying Within 500 Feet of People, Structures & Vehicles

University of Southern California – Institute for Creative Technologies

12015 Waterfront Drive, P laya Vista, CA 90094

310-574-5700

[Prepared in coordination with http://www.dronelaw.pro ]
Contact Enrico Schaefer, enrico@dronelaw.pro.

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## Table of Contents

1. Introduction

A. Purpose 3
B. Contact Information 3 C. Flight Operations within 500 Feet of People, Structures or 4
D. Plan of Activities 6 E. Security 7 F. Pre-Flight Briefing 7
G. Communications 8
H. Accident Notification 8 I. Recall/Stop Procedures 8



### 2. Operational Responsibilities

A. UAS Operations Manager 9
B. Pilot in Command 9
C. Visual Observer 10



### Appendixes
1. A. 1 - Permission Acquisition Form (sample) 11

2. A. 2

– Revision / Distribution Log 13Date: June 2016 Revision: Original Page 3 of 14

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## 1. Operations Manual For Flying within 500 Feet of People, Structures and Vehicles.

A. Purpose

This manual has been developed b y "University of Southern Calif ornia-Institute for Creative Technologies", hereafter referred to as "USC-ICT", in conjunction with an application for a Certificate of Waiver of Authorization of the provisions of FAR 91.119 (b) and (c) for the purposes of drone operation under its Section 333 Exemption, and specifically para graphs 28, 31 and 32 (the “500 Foot Rule”).

USC-ICT’s operators, pilots, cont ractors and other personnel wh en applicable will comply with the policies, procedures and conditions of this man ual, whenever flight operations within 500 feet of people, structures and veh icle are performed.

For the purposes of this manual, the following abbreviations sh all apply under definitions consistent wit h FAA interpretation:

i. FAA – Federal Aviation Association

ii. FSDO – Flight Standards District Office

iii. PIC – Pilot In Command.

iv. UAS – Unmanned Aerial System.

v. UAV- Unmanned Aerial Vehicle.

vi. VO – Visual Ob server.



### B. Contact Information

Contact Information: If any FAA r epresentative, police or othe r government authority has questions concerning a flight operation being con ducted under this manual, they should contact the 333 exemption owner and the ope rator at the information below.

Exemption Owner: University of Southern California 12015 E. Waterfront Drive, Playa Vista, CA 90094 Ryan McAlinden, Director for M odeling, Simulation & Training 310-448-5387 mcalinden@ict.usc.eduDate: June 2016 Revision: Original Page 4 of 14

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Operations Manager (if different): Operator Company Name : _______________________

____________ Address: __________

_____________________ __________________ Contact Person: ________________

____________________________ Contact Numbers: _________

_____________________ ____________ Contact Email: __________

_____________________ ______________



### C. Flight Operations within 500 Feet of People, Structures or Vehi cles

All flight operations must be conducted at least 500 feet from all persons, vessels, vehicles, and structures unless the following conditions are met:

1. Operation of a UAV over or near people direct ly participatin g in the operation of the UAS is allowed.

i. People directly participati ng in the operation of the UAS in clude the PIC, VO, and other consenting personnel that are directly participating in the safe operation of the UAV.

ii. The Operations Manager or PI C is responsible for determinin g and identifying all people directly participating in the flight, an d to identify those people at the pre-flight briefing.

iii. Criteria for identifying peopl e directly participating in the flight beyond the PICs and VOs, shall in clude, but not be limited to:

1. The person’s primary purpose at the operations (i.e. flight operations, ground crew, managem ent responsibility, safety).

2. The person’s experien ce in UAS operations.

2. Operation of a UAV near, but not over, people directly parti cipating in the intended purpose of the UAS operat ion is allowed only if all of the following conditions are met.

i. People directly participati ng in the intended purpose of the UAS must be briefed on the potentia l risks and acknowledge and cons ent to those risks.

ii. Operators must not ify the local Fligh t Standards District O ffice (FSDO) with a plan of activitie s at least 72 hours prior to fli ght operations. See Section D.Date: June 2016 Revision: Original Page 5 of 14

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3. Operation near, and potentially over, nonparticipating perso ns is allowed only if all of the following conditions are met.

i. When barriers or structures ar e present that sufficiently pr otect that person from the UAV and/or debris or hazardous materials such as fuel or chemicals in the event of an accident.

ii. When the Operator/PIC ensur es that all non-participating pe rsons remain under such protection fo r the duration of the operation.

iii. When the Operator/PIC ensur es that when a person leaves su ch protection and is wit hin 500 feet of the U AV, flight operations immediately ceases in a manner that does not cause undue hazard to any person.

4. Operation within 500 feet of v essels, vehicles and structure s is allowed only if all of the following conditions are met.

i. Prior to conducting operations the operator/PIC must obtain permission from a person with the legal authority over any such vessels, vehicles and/or structures.

1. Permission shall be obtained b y the Operator/ PIC prior to operations.

2. The form of permission, whether written or oral, shall be determined based on the circ umstances presented by the flight operation.

3. Permissions obtained shall be reviewed and disclosed as part of the pre-flight briefing.

4. A sample permission form is included as Appendix A-1.

ii. The PIC makes a safety asse ssment of the risk of operating within 500 feet of those objects and det ermined that such operation do es not present an undue hazard.

5. No operations shall occur at a distance or proximity from an y person, vehicle or which creates an undue risk of ha rm to person or property asses sing all circumstances and factors for eac h specific operation. Factors to be assessed include, but are not limited to:

i. Weather.

ii. Airspace.

iii. Obstructions.Date: June 2016 Revision: Original Page 6 of 14

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iv. Visibility.

v. Number and classification o f people (spectators, safety pers onnel, etc.), structures and vehicles.

vi. Weight, speed and other factor s related to the UAV being operated as it affects the pot ential risk of injury.

6. The PIC shall est ablish the minimum distance from people, st ructures and vehicles as part of the PIC’s r esponsibility for safe operation s and disclose the minimum distances at the pre-flig ht briefing. Flight operation s shall be stopped if minimum distances cannot, or are not, being achieved.



### D. Plan of Activities

At least 72 hours prior to any scheduled operation, the Operato r and/or PIC will submit a written plan of activiti es to the local FSDO having ju risdiction over that area. The plan of activities must include the following:

1. Dates and times for all flights.

i. For seasonal or long-term oper ations, this can include the beginning and end dates of the ti meframe, the approximate frequency (e.g. daily, every week end, etc.), and what times of the day operations will occur. A new plan of activities must be submitted prior to each seas on or period of operations.

2. Name and phone number of person re sponsible for the on-site person responsible for the operation.

3. Make, model, and serial or N-number for each aircraft to be used for the operation.

4. Name and certific ate number of t he pilot, or pilots, acting as the PIC(s) involved in the operations.

5. A statement that the Operator /PIC has obtained permission fr om property owners. Upon request, the Operat or will make available a list o f those who gave permission.
6. Signature of exemption holder or representative stating the plan of activities is accurate.
7. A description of the flight a ctivity, including maps or diag rams of the area over which operations will be conduc ted and the altitudes essential to accomplish the operation.Date: June 2016 Revision: Original Page 7 of 14

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The 72 hour notification requirem ent may be waived by the FSDO; however, the Operator should contact the FSDO as soon as possible with this request and be prepared to explain in detail wh y the 72 hour notification is n ot practical.



### E. Security

Prior to any flight operation t he Operator and/or PIC will coor dinate with appropriate personnel to devise a plan of securing the area(s) of operation from all unauthorized perso ns and vehicles. The a rea of operation sh all be generally defined as adding 500 f eet from the UAV on its expected flight path from all people, structures and vehicles , but may be increased depending on the flight operation to be conducted.

i. The Operator and/or PIC sha ll coordinate with appropriate personnel to ensure the safety of nonparticipating persons with in 500 feet of the UAS an d discuss this plan at the pre-flight briefing.

ii. The Operator and/or PIC shall coordinate with appropriate personnel to ensure the safety of persons directly participating in the intended purpose of the UAS operation persons within 500 feet of the UAS and discuss this plan at the pre-flight briefing.

iii. Provisions will be made to immediately discontinue operati ons should the area(s) become unsecur ed or for any other reason in the interest of safety.



### F. Pre-Flight Briefing

The Operator and/or PIC will ensur e that the person’s participa ting in the operations are thoroughly briefed . No person may participate in any event unless that person has received a brie fing to include, but not be limi ted to, the following items:

i. A summary review of the doc umentation authorizing the UAS operation including any applicab le Section 333 exemptions, amendments and COAs.

ii. A review of all flight condi tions and limitations under the applicable Section 333 exemption and COAs.

iii. A summary review of this O peration Manual and a detailed review of all mandatory items co ntained herein. The Operation Manual shall be available to all participating personnel.Date: June 2016 Revision: Original Page 8 of 14

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iv. A detailed review of the Plan of Activities filed with the FSDO.

v. UAV takeoff, landing and return to home location and procedures.

vi. Flight termination criteria and procedures.

vii. Expected UAV flight path, altitude and duration.

viii. Radio communications procedures, if any.

ix. Emergency procedures.

x. Identification of the risks in volved of the specific operati on to all participating and non-participating persons, vehicles and structures.

xi. Procedures for controlling the location and safety of nonparticipating persons, and co mpliance with all safety requirements for non-participat ing persons, during flight operations.

xii. Personnel will also be brie fed on additional provisions th at may be issued by the FSDO in response to the flight plan.



### G. Communications

Prior to the start of any operat ion covered by this manual, the Operator and/or PIC will formulate a plan for co mmunications between all partic ipating persons during the operation. Oral, visual or radio communications may be used as long as it is effective and is capable of keeping participating pers ons continuously appraised of the current status of the specific operation, and is otherwise consistent with the applicable S ection 333 Exemption and COA. The communications plan will be discl osed and reviewed at the pre-f light briefing.



### H. Accident Notification

Should an accident or incident requiring notification of the NT SB occur, the operator must comply with the not ification requirements of the applicable Section 333 exemption, the CO A and NTSB Part 830.



### I. Recall/Stop Procedures

Radio communication, oral, visual or a combination will be util ized to keep the participants continuously apprised of the current status of ope ration.Date: June 2016 Revision: Original Page 9 of 14

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## 2. Operational Responsibilities

A. UAS Operations Manager

Duties and Responsibilities:

• Final word in the formulation of policy and procedures concer ning this manual.

• Ensure all revisions to this manual are kept current and that all revisions comply with the applic able conditions and limitations in the applicable Section 333 exemption(s) granted by the FAA. The Revision sheet is incl uded as Appendix A-2.

• Specify criteria for designatin g individuals as directly part icipating in

the safe operation of the UAS.

• Act as liaison between the Exem ption Owner, if different, and the FAA on matters concerning this manual.

• Assure that each approved pilot is issued a copy of this manu al and obtain a

signed statement from each that they have read and understand i ts contents.

• Maintain a current copy of this manual at the main base of op erations for USCICT.

• Responsible for assuring that all revisions to this manual ar e distributed and processed properly.

• Must approve or disapprove eac h proposed job or operation per formed by USC-ICT under the prov isions of this manual.

• The Operations Manager may also be the PIC.

• May delegate functions to other personnel but retains respons ibility.



### B. Pilot in Command

Duties and Responsibilities:

• Assure that aircraft to be flow n is in airworthy condition an d all inspections and required maintenance have been per formed as per appropriate FAR 's.

• Acquire permission from the Ex emption owner before any operat ion under the provisions of this manual.Date: June 2016 Revision: Original Page 10 of 14

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• Be very knowledgeable of the contents of this manual and abid e by the procedures, policies and condi tions contained herein.

• Coordinate with personnel to formulate plans, routes, locations, etc. with

safety of all persons involved in the primary concern.

• Maintain their copy of this manual in current condition and h ave it on site at any

job or operation r equiring the waiver.

• Follow all conditions and limit ation in the applicable Sectio n 333 exemption, all

COA requirements and a ll non-exempted Federal Aviation Regulati ons.

• The PIC may also be the Operations Manager.

• The PIC may delegate functions to other personnel, but retain s responsibility.



### C. Visual Observer

The VO shall be responsible for wa tching the UAV at all times d uring flight, in coordination with the PIC. The V O must have the ability to visu ally see the UAV during all aspects of the fligh t operations and communicate wit h the PIC. The VO will communicate directly with t he PIC on issues, which include , but are not limited to:

1. Keeping the UAV within Visual Line of Sight (VLOS) at all ti mes.

2. Identifying obstruc tions and hazards.

3. Identifying changes in weather or visibility.

4. Helping the PIC maintain min imum distances from people, stru ctures and vehicles, including any minimum d istances identified in the pre -flight briefing.

5. Identifying any non-pa rticipating persons who are not in the appropriate or designated safe locations.

6. Effectively communicating wit h the PIC on the location of th e UAV as the operations occur.

7. Identifying any safety issues w hich arise during the operati on.Date: June 2016 Revision: Original Page 11 of 14 

## A ppendix A .1

Permission Acquisition Form

In signing this form, I am givi ng the Operator/PIC Permission t o operate their aircraft at less than 500 feet from one or more of the following:

myself property I own or control a structure I own or control a vehicle I own o r control Children or minors I have responsibility for

I warrant that I have the author ity to grant this permission, a nd understand the risks involved.

My Full Name (prin ted): _____________

_____________

My Signature

Date

Operations Manager, PIC or Represent ative Receiving Permission:

Flight Location: _____

________________________ _________________ _______ Date of Operati on: ___________

____________ Name of Operator : ________________

________ Representative’s Full Nam e (printed):

_________________________ _Date: June 2016 Revision: Original Page 12 of 14 

## Appendix A .2

Revision/Distribution Log

Rev# Section Page Action Remarks InitialsDate: June 2016 Revision: Original Page 13 of 14 

## Appendix A .2

R  Remove & Replace D  Delete & Destroy N  Insert New Page ND  New Distribution

Revised By

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