Commercial Drone Services LLC Jonathan J Pascua 222 Raccoon Run RD Coventry, RI 02816 CommercialDroneServicesLLC@gmail.com
January 19, 2016
U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 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) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Commercial Drone Services LLC, developer and operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial electronic data collection c and aerial photography, videography for the use of real estate marketing, infrastructure inspection, news gathering, cinematography, advertising, agricultural inspection, landmark photography, environmental photography and inspection, search and rescue, fire and rescue operations and training hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, 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 described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the aerial filming and monitoring industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretaryof Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

( c Aerial Data Collection” which 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 )

The name and address of the applicant is:

Commercial Drone Services LLC Jonathan J Pascua Ph: 401-598-7562

Email: CommercialDroneServicesLLC@gmail.com

Address: 222 Raccoon Run Rd Coventry, RI 02816

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:
• The sUAS’s size, weight, speed, and operational capability; • Operation of the sUAS in close proximity to airports and populated areas • Operation of the sUAS within visual line of sight of the operator.

A Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the sUAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.
The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).
Commercial Drone Services sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover,and move in the vertical and horizontal plane simultaneously. They will operate only in line of sight and will operate only within the sterile area described in the Flight Safety Manual, attached as Exhibit B (hereinafter “the Manual”). Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public.” B

Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the sUASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing sUASs for commercial video operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY**
The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe commercial video filming operations conducted with conventional aircraft.These limitations and conditions to which Commercial Drone Services LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include:
1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 6. sUAS pilot will be an FAA licensed airman with at least a 3rd class medical certificate and a valid driver’s license. The observer will also hold a valid driver’s license. 7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present, that person can also be designated as PIC.
8. Pilot and observer will have been trained in operation of sUAS generally and received up- to-date information on the particular sUAS to be operated as required.
9. Observer and pilot will at all times be able to communicate by voice. 10. Written and/or oral permission from the relevant property holders will be obtained. 11. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.
12. If the sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a pre-determined location within the Security Perimeter and land. 13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.14. The sUAS will not be flown when there are other known aircraft in the vicinity (ie new helicopter or medical helicopter)

**14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)** 
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.
The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

**14 C.F.R. § 45.23 (b). Marking of the Aircraft**
The regulation requires:
When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.
Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be
impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).
The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the sUAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

**14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.** 
Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have aprivate pilot’s license rather than a commercial pilot’s license to operate this small sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

**14 C.F.R. §91.7(a): Civil aircraft airworthiness.**
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections C & D, an equivalent level of safety will be provided.

**14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.**
Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ...
(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.
The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

**14 C.F.R. § 91.103: Preflight action**
This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

**14 C.F.R. §91.109: Flight instruction:**
Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.
sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.
Safe simulation and practice flight will be carried out in controlled environments. All simulations will be carried out on a computer using the drone controls. Any practice flying will take place in a safe environment, with no risk to human life below.

**14 C.F.R. §91.119: Minimum safe altitudes**Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein the sUAS will never operate at higher than 400 AGL. It will however be operated in a
restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.
The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low- altitudeoperations of the sUAS will ensure separation between these smallUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

**14 C.F.R. §91.121 Altimeter Settings**
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Checklist, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.**14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**
Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”
The battery powering the sUAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.
Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small sUAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the exemption will be granted.
Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power 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 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration** The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it
has within it the following:
(1) An appropriate and current airworthiness certificate. . . .
(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.
The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS.
An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

**14 C.F.R. §91.405 (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 in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.
Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual.(See Sections B, D and G) An equivalent level of safety will be achieved because these small sUASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication 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); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) DJI Phantom 3 Advanced Drone.

**In summary, approving these exemptions and allowing Commercial Drone Services LLC to operate a small unmanned electric quad rotor drone will enhance safety, promote the local**  **economy and even save lives. The Commercial Drone Services LLC is Owned by Jonathan J Pascua, a Licensed FAA Private Pilot with extensive Drone experience and a Career**  **Firefighter/EMT. Commercial Drone Services LLC will be operating in many ways including but not limited too Public safety in conjunction with Fire/Rescue Departments in**  **various ways like Search and Rescue, Infrastructure inspection, Fire Scene safety monitoring, Fire load inspection and other various uses in Hazmat situations and water**  **rescue to name a few. These incidents would normally require putting Humans in harms way to get this information however, that would no longer be needed with the use of a** 
**drone from Commercial Drone Services LLC. Commercial Drone Services LLC will provide fire ground support and training in the use and operation of Drones at all types of**  **Fire/Rescue operations. Commercial Drone Services LLC will also be taking still pictures and video of Real Estate for various commercial reasons. Prior to this helicopters or other**  **low flying aircraft were used to do this and they were carrying humans and explosive fuel, creating more or a risk then a sUAS from Commercial Drone Services LLC. Commercial**  **Drone Services LLC will also take aerial photography and video for local news stations in for use in local media when all safety guidelines have been met that are listed in this**  **proposal. Other uses for Commercial Drone Services LLC include advertising, agricultural inspection, landmark photography and environmental photography. Commercial Drone**  **Services LLC has multiple business points and is not “Primary” in one particular area listed. I respectfully ask the FAA to review the Documents attached and ask for any**  **clarifying information on anything needed. All of these uses that Commercial Drone Services LLC will be using the drone for will ensure the public will benefit due to being in a**  **safer environment due to the fact you will not need larger, heavier Aircraft, carrying humans and flammable fuel on board, rather you will have a licensed medically current**  **pilot remotely flying a small under 55lbs quad rotor A/C with several fail safes that are**
**listed in this document.**

**Commercial Drone Services LLC 222 Raccoon Run Rd**  **Coventry, RI 401-598-7562**  **Jonathan Pascua**

sUASs Details: See Appendix C
Safety Features:

● Emergency “Return-To-Home”

○ At the beginning of each flight a home point is set. This home point is set in accordance with the manual to allow for a safe take- off and return. Should the pilot’s control lose signal with the sUAS or manually request a return, the sUAS will return to the starting point. 

# Appendix A: No-Fly Zones

Commercial Drone Services LLC’s Pilots will not be operating within 5 nautical miles of any airport.
As a safety precaution, Commercial Drone Services LLC’s pilots will not be operating within 5 nautical miles of any airport similar to the permission granted in Exemption No. 11153 - Regulatory Docket No. FAA20140519, page 25, "20. The UA may not operate within 5 nauticalmiles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airports management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operators COA. The letter of agreement with the airport management must be made available to the Administrator upon request."
As well as in Exemption No. 11195 - Regulatory Docket No. FAA20140884, page 12, "19. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airports management is obtained, and the operation is conducted in accordance with a Notice to Airmen (NOTAM), as required by the operators Certificate of Waiver or Authorization (COA). The letter of agreement with the airport management must be made available to the Administrator upon request."
Commercial Drone Services LLC requests the same flexibility as exemptions 11153 and 11195 for acquiring agreement with the airports' management should operations fall within 5 nautical miles of an airport.

**A. Maintenance**

**Appendix B: Safety Manual**
a. The sUAS must be inspected by a factory trained technician at intervals required by the manufacturer . All maintenance records will be maintained for inspection as set forth in Section B.

b. If any maintenance is undergone, the sUAS must pass a flight test with Licensed FAA Pilot.

B. Record Keeping
a. A digital record will be kept for all flights, flight times, and maintenance records.b . Identify potential obstacles i. Before each flight, an inventory will be taken for all potential obstacles
that must be avoided while in flight. Including:

1. Powerlines

2. Cell Phone Towers

3. Trees

4. Flocks of birds that may take flight

5. Heavily traveled roadways

6. Utility wires

7. Elevated structures

8. At least 5 nautical miles from the nearest airport or helipad.

D. Pre-FlightChecklist

a. Take Off Location/ “Home”

i. The sUAS will mark its take off location as a safe area to return to should the sUAS lose signal with the control or if the pilot signals the craft to return to its “home” location.1. Take off location will be in an area with a 20 ft radius with no obstructions, maintaining said radius vertically 200ft.

2. The sUAS will take off and land in the same location.

3. GPS Altimeter will be marked as 0’ elevation

b. Flight Canceling Events
i. All flights will be cancelled for a minimum of 2 hours if any of the below occur:

1 . Low flying aircraft in the area

2 . Medical/News Helicopters active in the area

3 . Wind exceeding 10 mph

4 . PIC is unable to complete flight without losing visual of the sUAS

5 . Any precipitation

6 . Heavy bird presence in the area that could cause a mid-air collision.

7 . Any defects or damage found during preflight exam

c. Physical Inspectioni. Before flight. 1. 2.

3. 4. 5.

d. **Post Flight Inspections/Checklist** i. After each flight, the the sUAS will be thoroughly inspected for any
damage that occurred in flight.
1. Body inspected for any damage

2. Blades visually checked for any damage at all

3. Battery checked for damage

**E. Mid-AirSafetyProtocol a. Max Speed**

i. Accent 1. 10m/s

ii. Decent 1. 4m/s

iii. Flight Speed

1. The sUAS is never to exceed 10m/s

b. Altitude

i. The sUAS is never to exceed 400ft

c. Emergency
i. If it appears that the sUAS, any property or humans are at risk, the sUAS will be grounded immediately to a safe location.d. Sight
i. The pilot must keep the sUAS within eyesight at all times unassisted by any technology.

F. Participation by non-pilot staff
a. All staff involved in the production or filming using the sUAS will consent to maintain a safe distance of at least 30 ft during the filming.

G. Pilot/Spotter Training
a. Before flying, both the Pilot and spotter will receive updated information on the sUAS and its firmware.
i. The controller allows for a simulator training, both the pilot and spotter are allowed to run through the simulator training