Date: June 2016 Revision: Original Page 1 of 14

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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, Playa Vista, CA 90094 

310-574-5700 

[Prepared in coordination with http://www.dronelaw.pro] 

Contact Enrico Schaefer, enrico@dronelaw.pro. 

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Date: June 2016 Revision: Original Page 2 of 14

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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 13 
Date: June 2016 Page 3 of 14 Revision: Original

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1. Operations Manual For Flying within 500 Feet of People, 

Structures and Vehicles.

A. Purpose

This manual has been developed by "University of Southern California-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 paragraphs 28, 31 and 32 (the “500 Foot Rule”). 

USC-ICT’s operators, pilots, contractors and other personnel when applicable will 

comply with the policies, procedures and conditions of this manual, whenever 

flight operations within 500 feet of people, structures and vehicle are performed. 

For the purposes of this manual, the following abbreviations shall apply under 

definitions consistent with 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 Observer. 

B. Contact Information

Contact Information: If any FAA representative, police or other government 

authority has questions concerning a flight operation being conducted under this 

manual, they should contact the 333 exemption owner and the operator at the 

information below. 

Exemption Owner: 

University of Southern California 

12015 E. Waterfront Drive, Playa Vista, CA 90094 

Ryan McAlinden, Director for Modeling, Simulation & Training 

310-448-5387 

mcalinden@ict.usc.edu 
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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 Vehicles

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 directly participating in the operation of 

the UAS is allowed. 

i. People directly participating in the operation of the UAS include the 

PIC, VO, and other consenting personnel that are directly 

participating in the safe operation of the UAV. 

ii. The Operations Manager or PIC is responsible for determining and 

identifying all people directly participating in the flight, and to identify 

those people at the pre-flight briefing. 

iii. Criteria for identifying people directly participating in the flight 

beyond the PICs and VOs, shall include, but not be limited to: 

1. The person’s primary purpose at the operations (i.e. flight 

operations, ground crew, management responsibility, 

safety). 

2. The person’s experience in UAS operations. 

2. Operation of a UAV near, but not over, people directly participating in the 

intended purpose of the UAS operation is allowed only if all of the following 

conditions are met. 

i. People directly participating in the intended purpose of the UAS 

must be briefed on the potential risks and acknowledge and consent 

to those risks. 

ii. Operators must notify the local Flight Standards District Office 

(FSDO) with a plan of activities at least 72 hours prior to flight 

operations. See Section D. 
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3. Operation near, and potentially over, nonparticipating persons is allowed only if 

all of the following conditions are met. 

i. When barriers or structures are present that sufficiently protect 

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 ensures that all non-participating persons 

remain under such protection for the duration of the operation. 

iii. When the Operator/PIC ensures that when a person leaves such 

protection and is within 500 feet of the UAV, flight operations

immediately ceases in a manner that does not cause undue 

hazard to any person. 

4. Operation within 500 feet of vessels, vehicles and structures 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 by the Operator/ PIC prior to 

operations. 

2. The form of permission, whether written or oral, shall be 

determined based on the circumstances 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 assessment of the risk of operating within 

500 feet of those objects and determined that such operation does 

not present an undue hazard. 

5. No operations shall occur at a distance or proximity from any person, vehicle or 

which creates an undue risk of harm to person or property assessing all 

circumstances and factors for each specific operation. Factors to be assessed 

include, but are not limited to: 

i. Weather. 

ii. Airspace. 

iii. Obstructions. 
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iv. Visibility. 

v. Number and classification of people (spectators, safety personnel, 

etc.), structures and vehicles. 

vi. Weight, speed and other factors related to the UAV being 

operated as it affects the potential risk of injury. 

6. The PIC shall establish the minimum distance from people, structures and 

vehicles as part of the PIC’s responsibility for safe operations and disclose the 

minimum distances at the pre-flight briefing. Flight operations 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 Operator and/or PIC will 

submit a written plan of activities to the local FSDO having jurisdiction over that 

area. The plan of activities must include the following: 

1. Dates and times for all flights. 

 

i. For seasonal or long-term operations, this can include the 

beginning and end dates of the timeframe, the approximate 

frequency (e.g. daily, every weekend, etc.), and what times of the 

day operations will occur. A new plan of activities must be 

submitted prior to each season or period of operations. 

2. Name and phone number of person responsible 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 certificate number of the pilot, or pilots, acting as the PIC(s) 

involved in the operations. 

5. A statement that the Operator/PIC has obtained permission from property 

owners. Upon request, the Operator will make available a list of those who 

gave permission. 

6. Signature of exemption holder or representative stating the plan of activities is 

accurate. 

7. A description of the flight activity, including maps or diagrams of the area over 

which operations will be conducted and the altitudes essential to accomplish 

the operation. 
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The 72 hour notification requirement 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 why the 72 hour notification is not practical. 

E. Security

Prior to any flight operation the Operator and/or PIC will coordinate with 

appropriate personnel to devise a plan of securing the area(s) of operation from 

all unauthorized persons and vehicles. The area of operation shall be generally 

defined as adding 500 feet 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 shall coordinate with appropriate 

personnel to ensure the safety of nonparticipating persons within 

500 feet of the UAS and 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 operations 

should the area(s) become unsecured or for any other reason in 

the interest of safety. 

F. Pre-Flight Briefing

The Operator and/or PIC will ensure that the person’s participating in the 

operations are thoroughly briefed. No person may participate in any event unless 

that person has received a briefing to include, but not be limited to, the following 

items: 

i. A summary review of the documentation authorizing the UAS 

operation including any applicable Section 333 exemptions, 

amendments and COAs. 

ii. A review of all flight conditions and limitations under the

applicable Section 333 exemption and COAs. 

iii. A summary review of this Operation Manual and a detailed 

review of all mandatory items contained herein. The Operation 

Manual shall be available to all participating personnel. 
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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 involved of the specific operation to all 

participating and non-participating persons, vehicles and 

structures. 

xi. Procedures for controlling the location and safety of nonparticipating persons, and compliance with all safety 

requirements for non-participating persons, during flight 

operations. 

xii. Personnel will also be briefed on additional provisions that may 

be issued by the FSDO in response to the flight plan. 

G. Communications

Prior to the start of any operation covered by this manual, the Operator and/or 

PIC will formulate a plan for communications between all participating persons 

during the operation. Oral, visual or radio communications may be used as long 

as it is effective and is capable of keeping participating persons continuously 

appraised of the current status of the specific operation, and is otherwise 

consistent with the applicable Section 333 Exemption and COA. The 

communications plan will be disclosed and reviewed at the pre-flight briefing. 

H. Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the 

operator must comply with the notification requirements of the applicable Section 

333 exemption, the COA and NTSB Part 830. 

I. Recall/Stop Procedures

Radio communication, oral, visual or a combination will be utilized to keep the 

participants continuously apprised of the current status of operation. 

  
Date: June 2016 Page 9 of 14 Revision: Original

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2. Operational Responsibilities

A. UAS Operations Manager 

Duties and Responsibilities: 

• Final word in the formulation of policy and procedures concerning this 

manual. 

• Ensure all revisions to this manual are kept current and that all 

revisions comply with the applicable conditions and limitations in the 

applicable Section 333 exemption(s) granted by the FAA. The 

Revision sheet is included as Appendix A-2. 

• Specify criteria for designating individuals as directly participating in 

the safe operation of the UAS. 

• Act as liaison between the Exemption Owner, if different, and the FAA on 

matters concerning this manual. 

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

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

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

• Responsible for assuring that all revisions to this manual are distributed and 

processed properly. 

• Must approve or disapprove each proposed job or operation performed by 

USC-ICT under the provisions of this manual. 

• The Operations Manager may also be the PIC. 

• May delegate functions to other personnel but retains responsibility. 

B. Pilot in Command

Duties and Responsibilities: 

• Assure that aircraft to be flown is in airworthy condition and all inspections and 

required maintenance have been performed as per appropriate FAR's. 

• Acquire permission from the Exemption owner before any operation 

under the provisions of this manual. 
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• Be very knowledgeable of the contents of this manual and abide by the 

procedures, policies and conditions 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 have it on site at any 

job or operation requiring the waiver. 

• Follow all conditions and limitation in the applicable Section 333 exemption, all 

COA requirements and all non-exempted Federal Aviation Regulations. 

• The PIC may also be the Operations Manager. 

• The PIC may delegate functions to other personnel, but retains 

responsibility. 

C. Visual Observer

The VO shall be responsible for watching the UAV at all times during flight, in 

coordination with the PIC. The VO must have the ability to visually see the UAV 

during all aspects of the flight operations and communicate with the PIC. The VO 

will communicate directly with the PIC on issues, which include, but are not limited 

to: 

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

2. Identifying obstructions and hazards. 

3. Identifying changes in weather or visibility. 

4. Helping the PIC maintain minimum distances from people, structures and 

vehicles, including any minimum distances identified in the pre-flight briefing. 

5. Identifying any non-participating persons who are not in the appropriate or 

designated safe locations. 

6. Effectively communicating with the PIC on the location of the UAV as the 

operations occur. 

7. Identifying any safety issues which arise during the operation.
Date: June 2016 Page 11 of 14 Revision: Original

Appendix A .1 

Permission Acquisition Form 

In signing this form, I am giving the Operator/PIC Permission to 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 or control Children or minors I have responsibility for 

I warrant that I have the authority to grant this permission, and understand the risks 

involved. 

My Full Name (printed): __________________________ 

My Signature 

Date 

Operations Manager, PIC or Representative Receiving Permission:

Flight Location: _____________________________________________________ 

Date of Operation: _______________________ 

 Name of Operator: ________________________ 

Representative’s Full Name (printed): __________________________ 
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Appendix A .2 

Revision/Distribution Log 

Rev# Section Page Action Remarks Initials 
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Appendix A .2 

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

Revised By 

Date 
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