Operations & Training Manual 

Coole~ Drone Services 

Small Unmanned Aerial Svstems 

Aerial Photography & Videoqraphy 

2015 
Table of Contents 

1. Introduction 

2. Terms of Reference 

3. Authorizations, Permissions & Permitting 

4. Operations 

5. Aircraft (sUAS) Specifications and Design 

6. Flight Time & Duration of Flight 

7. Qualifications & Training 

8. Maintenance 

2 I >age 
Introduction 

This Operations and Training Manual is an integral part of the business plan of Cooley Drone 

Services and will guide the daily operations, training program and inspection program of this 

company. This manual is part of the Petition of Edward Cooley dba Cooley Drone Services for 

Exemption to Section 333 of the FAA Modernization and Reform Act of 2012 filed with the 

FAA on May 15, 2015. Cooley Drone Services (Operator), a small business to provide 

commercial aerial photography and videography primarily in theTampa Bay Area. The 

Operator will utilize the OJI Phantom 2 Vision Plus and the DJI Phantom 3 quadcopters in this 

business. These sUAS (small Unmanned Aerial Systems) represent the 11State of the art" in 

technically advanced, stable, safe and efficient aerial camera platforms to support 

professional aerial photography and videography enterprises. The technical guides and 

manuals for these sUAS provided by the manufacturer, DJI, are important resources to the 

Operator and will be followed in the use and operation of these quadcopters. These 

documents include: 

(1) Phantom 2 Vision+ User's Manual 

(2) Phantom 2 Vision+ Pilot Training Guide 

(3) Phantom 2 Vision+ Quick Start Guide 

(4) Phantom 3 Safety Guidelines 

(5) Phantom 3 Professional & Advanced User's Manuals 

(6) Phantom 3 Professional & Advanced Quick Start Guide 

These documents are included by reference to this Manual, attached to the hard copy of this 

Manual and attached to the electronic copy of this Manual which is submitted to the FAA as a 

part of the Part 333 Petition for Exemption of the Reform Act. 

The first priority of Operator is safety. Operator will provide safety and regulatory 

compliance in all of its operations, plans, procedures and activities. These goals and 

objectives will be attained by the execution of a detailed and systematic business plan 

structured around the details in this Manual and Petition. 
Terms of Reference 

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, 

United States Code (49 USC) § 40102) 

2. National Airspace System (NAS): the common network of U.S. airspace; air navigation 

facilities, equipment and services, airports or landing areas; aeronautical charts, 

information and services; rules, regulations and procedures, technical information, and 

manpower and material 

3. Operational Control: with respect to a flight, means the exercise of authority over 

initiating, conducting or terminating a flight (14 CFR § 1.1) 

4. Pilot in Command (PIC): the person who has final authority and responsibility for the 

operation and safety of the flight; has been designated as PIC before or during the flight; 

and holds the appropriate category class and type-rating, if appropriate, for the conduct 

of the flight (14 CFR § 1.1) 

5. Unmanned aircraft (UA or): any aircraft that is operated without the possibility of direct 

human intervention from within or on the aircraft (P.L. 112-95, Section 331) 

6. Unmanned Aircraft System (UAS): an unmanned aircraft and associated elements, 

including communication links and the components that control the unmanned aircraft, 

that are required for the pilot in command to operate safely and efficiently in the national 

airspace system (P.L. 112-95, Section 331) 

7. UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air Traffic 

Organization to an operator for a specific unmanned aircraft activity 

8. Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) visual 

contact between a pilot in command and an unmanned aircraft sufficient to maintain safe 

operational control of the aircraft, know its location, and be able to scan the airspace in 

which it is operating to see and avoid other air traffic or objects aloft or on the ground 

4 I • d ~ 
Authorizations, Permissions & Permitting 

All required authorizations, permissions and permits shall be obtained from federal, state and 

local agencies and jurisdictions prior to conducting operations under this exemption. 

If required by the COA, at least 3 days before a scheduled operational flight, Operator shall 

submit a written plan of activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of the proposed flight. The 3-day notification may be waived with the 

concurrence of the FSDO. 

The plan of activities shall include at least the following: 

Dates and times for all requested flights 

Name and phone number of Operator's Flight Operations 

Name, certificate, phone number of the PIC responsible 

Make, model, serial number, and N-number of the sUAS to be used. 

Operations 

Operator will utilize the Pre-Flight Checklist and Inspection Procedures contained in the 

manufacturer's documents to inspect the sUAS and all its peripheral equipment to insure that 

the sUAS is operationally airworthy and prepared for the flight operation, that the operational 

papers are with the PIC and available for inspection and that all weather conditions, site 

conditions and flight approvals are acceptable. 

The sUAS shall not operate within the following distances from airports or heliports, or as 

specifically directed by the FAA in a COA: 

Sl 

Five (5) nautical miles (NM) from an airport having an operational control tower; or 

Three (3) NM from an airport with a published instrument flight procedure, but not an 

operational tower; or 

Two (2) NM from an airport without a published instrument flight procedure or an 

operational tower; or 

Two (2) NM from a heliport with a published instrument flight procedure, 
unless a letter of agreement with the airport's management is obtained, and the 

operation is conducted in accordance with a NOT AM as required by the Operator's 

Certificate of Waiver or Authorization ("COA''). 

The sUAS will only operate within the lateral boundaries of property for which the Operator has 

received written approval to operate. An Operations Area within those boundaries will be 

established for each flight. These areas will be free of unnecessary hazards or risks and nonparticipating personnel. 

The sUAS shall only operate within a pre-defined Operations Area that shall be 

thoroughly inspected by the PIC for buildings, overhangs, obstacles, wires, poles, 

people, animals, vehicles, sun angle, shadows, glare, reflective surfaces, clouds, smoke 

and terrain among other potential hazards. 

Flights will be conducted under day (official sunrise to official sunset) visual meteorological 

conditions {VMC}. 

In addition, the sUAS shall not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than three {3) statute miles from 

the PIC. 

Flights shall not be conducted under special visual flight rules {SVFR). 

Flights shall be operated at an altitude at or below 400 feet above ground level (AGL), as 

indicated by the sUAS equipment described in the manufacturer's user' s manual. 

The PIC shall be prohibited from operating the sUAS from any moving device or vehicle. 

The sUAS shall be operated within visual line-of-sight (VLOS) of the PIC and Visual Operator 

(VO). 

The PIC and VO shall maintain VLOS without the aid of telescopes, binoculars, cameras 

or other devices and shall maintain unaided voice contact. 

The PIC and VO will maintain VLOS with their own vision, which includes the use of 

eyeglasses or corrective lenses as specified on the PIC's medical certificate or the VO's 

driver's license. 

The sUAS will not operate at a speed exceeding 87 knots (100 miles per hour). 

The required operating documents as defined in the exemption and this Manual must be 

accessible during the sUAS operations and made available to the Administrator upon request . 

6 I g E 
The conditions and limitations in the exemption shall take precedence over the provisions of 

the operating documents. 

The PIC will not begin a flight (considering wind and forecast weather conditions) unless there is 

enough available power for the sUAS to conduct the intended operation and to operate after 

that for at least 5 minutes or with the reserve power recommended by the manufacturer or 

greater. 

The sUAS shall remain clear and yield the right of way to manned operations and activities at all 

times including, but not limited to, aircraft, rotorcraft, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, balloons and gliders. 

The PIC's primary responsibility while the sUAS is in flight is the safe operation of the aircraft. 

Once a request for commercial photography or videography is received by Operator, the 

Operator will evaluate the request based on the parameters and restrictions contained in 

Operator's Grant of Exemption, Certificate of Waiver or Authorization and other approval 

requirements. In doing so, Operator will do a thorough evaluation of the proposed site, its 

proximity to airports, heliports, and other high risk factors like power lines, tall structures and 

congregations of people. The risk analysis will also consider the nature of the operation in 

terms of protection of perimeter boundaries, line-of-sight issues and other risk mitigation 

factors. Environmental factors such as forecast weather, operations over environmentally 

protected lands or habitats, etc. will be evaluated. All of the required evaluations and 

approvals will be completed prior to a commitment to perform the work. 

Aircraft (sUAS) Specifications and Design 

All sUAS flown under this exemption shall be less than 10 pounds including aircraft and payload. 

The sUAS that will be utilized will be the DJI Phantom 2 Vision Plus and the Phantom 3 

quadcopters, which weigh less than 10 pounds including payload. Detailed specifications for 

these sUAS models are contained in the manufacturer's user's manuals attached hereto. 

The radio frequency spectrum used for operation and control of the sUAS shall comply with the 

Federal Communications Commission (FCC) or other appropriate government agency 

requirements. Detailed frequency specifications for these sUAS models are contained in the 

manufacturer's user's manuals attached hereto. 

Maximum speed of the sUAS shall be less than 87 knots. 

The sUAS shall be equipped with a Compass (magnetometer/heading source). 

The sUAS shall be equipped with a Global Positioning System (GPS) guidance system. 

7 I , e 
The sUAS shall be designed with a Return-To-Home. Should it lose contact with the radio 

controller, it will return to a pre-determined location within the Operations Area and make a 

controlled descent and landing. 

Flight Time and Flight Duration 

The flight times and durations for the DJI Phantom 2 Vision Plus and the DJI Phantom 3 will be 

completed within 25 minutes or with 25% battery power remaining, whichever occurs first. 

Qualifications and Training 

The sUAS Pilot in Command (PIC) shall possess at a minimum, a private pilot's certificate and 

current third-class medical certificate. 

The PIC shall also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an 

aircraft in which the PIC is rated on their pilot certificate. 

The PIC shall be trained in the operation of the specific make and model of the sUAS being 

piloted, which will include the DJI Phantom 2 Vision Plus and the Phantom 3, and have 

successfully completed and mastered all the flight operations and procedures contained in the 

DJI Phantom Pilot's Training Guide. Specifically these flight operations and procedures include: 

Basic Flight Maneuvers 

1. Take off and landing 

2. Hovering in place 

3. Rotate left and rotate right while hovering in place and keeping the rear of the aircraft 

pointed at pilot. 

4. Slowly fly left, right, forward and backward while returning to the beginning point. 

5. Fly forward 20 feet away and return to the beginning point without rotating the aircraft. 

6. Mark a landing zone 10 feet away, take off, hover, then move forward to the landing 

zone and land. Then take off from that point, hover and return to the original point of 

take off, hover and land. 

7. Take off, hover and then fly left 10 feet, then fly right to the starting point without 

rotating the aircraft. Hover, then fly right 10 feet then fly left to the starting point 

without rotating the aircraft. Then hover in place and land. 

8. Take off, hover, move forward 10 feet, hover, move right 10 feet, hover, move 

backward 10 feet, hover and move left 10 feet to the point of beginning, creating a box 

maneuver all while keeping the aircraft oriented forward. Clockwise formation. 

9. Perform the same box maneuver as Number 8 above, but in the opposite, 

counterclockwise direction. 

8 I a 
Skilled Flight Maneuvers 

1. Take off and hover. Rotate the aircraft 360 degrees to the right, clockwise. 

2. Take off and hover. Rotate the aircraft 360 degrees to the left, counterclockwise. 

3. Take off and hover. Rotate the aircraft 90 degrees to the left. Proceed for 10 feet. 

Hover. Then fly a four point box clockwise, keeping the nose of the aircraft in the same 

fixed orientation around the box. 

4. Take off and hover. Rotate the aircraft 90 degrees to the right. Proceed for 10 feet. 

Hover. Then fly a four point box counterclockwise, keeping the nose of the aircraft in 

the same fixed orientation around the box. 

5. With the battery (rear of aircraft) pointed at pilot, fly a circle as uniformly as possible in 

a counterclockwise direction, keeping the battery pointed at pilot. 

6. Take off and hover with the camera (nose) of the aircraft pointed at pilot. By 

manipulating both control sticks, keep the aircraft in a hover for a period of time in a 

constant direction and altitude. 

Advanced Flight Maneuvers 

1. Take off and hover with the camera (nose) facing pilot. Fly the aircraft in a circle 

clockwise keeping the camera facing pilot. Keep the circle and altitude constant. 

2. Take off and hover. Fly a 4 point box clockwise, keeping the camera facing pilot at all 

times. 

3. Take off and hover. Fly a 4 point box counterclockwise, keeping the camera facing pilot 

at all times. 

4. Take off and hover. Fly a 4 point box clockwise, keeping the camera facing the direction 

of travel at all times. 

5. Take off and hover. Fly a circle counterclockwise, keeping the camera facing pilot at all 

times. Keep the radius and altitude constant. 

6. Take off and hover. Fly a circle counterclockwise, keeping the camera pointed to the 

center of the circle at all times. Keep the radius and altitude constant. 

7. Take off and hover. Fly a figure 8 counterclockwise, without rotating the aircraft. Keep 

the radius and altitude constant. 

8. Take off and hover. Fly a figure 8 clockwise, keeping the camera pointed in the direction 

of travel. Keep the radius and altitude constant. 

9. Take off and hover. Fly a figure 8, and experiment with different camera orientations. 

Keep the radius and altitude constant. 

9 I 'a g 
Emergency Procedures 

1. Return Home and Land Mode- Be sure pilot is in a large open area. Before take off, 

make sure pilot has a good GPS lock by ensuring GPS indicators are flashing green. Fly 

the aircraft at least 50 feet away from take off point. Turn off the remote controller. 

The aircraft will enter its failsafe, Return-To-Home mode. Let the aircraft finish its 

programmed routine and return itself to a landing spot within two (2) meters of its 

takeoff point. 

2. Intercepting Return Home and Land Mode- Be sure pilot is in a large open area. Before 

take off, make sure pilot has a good GPS lock by ensuring GPS indicators are flashing 

green. Fly the aircraft at least 50 feet away from the take off point. Turn off the remote 

controller. The aircraft will enter its failsafe, Return-To-Home mode. When the aircraft 

is returning home, intercept the RTH Mode by switching the 51 switch from the top 

position to the middle or lower position, then continue flying the aircraft. 

The PIC will enter the completion of these flight procedures and time logged in his/her Logbook 

as part of the official record keeping of the training program. 

The PIC shall have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), a 

minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at least 

five (5) hours logged as a sUAS pilot with a similar sUAS type (multirotor or helicopter). Prior 

documented flight experience that was obtained in compliance with applicable regulations may 

satisfy this requirement. 

The PIC shall have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), a 

minimum five (5) hours as a sUAS pilot, operating the make and model of sUAS to be utilized for 

operations under the exemption and three (3) takeoffs and three (3) landings during the 

preceeding 90 days. 

Training, proficiency and experience-building flights can also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During training, proficiency 

and experience-building flights, all persons not essential for flight operations are considered 

non-participants, and the PIC must operate the sUAS with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

All commercial flight missions under this exemption will include a minimum crew of a PIC and a 

Visual Observer (VO). The VO is a trained person who shall assist the PIC in the duties of 

operational safety and collision avoidance. The VO will attend the mission briefing and will be 

aware of the mission objectives, flight parameters, weather conditions, site conditions, 

participants and coordination requirements. The VO will continuously monitor the progress of 

the flight operation and will be in continuous visual contact and voice contact with the PIC to 

10 I I d g L 
alert him/her of any developing hazards, conditions, deviations from mission profile or 

perimeter incursions by non-participating personnel. 

The training for VO shall consist of at least five (5) hours oftraining with a PIC in a training 

environment to include all of the situations included in the paragraph above. Following the 

completion of this training, the PIC will sign-off the VO as mission ready. The PIC and VO will 

always be within visual line of sight (VLOS) with each other and the sUAS and in direct verbal 

communications at all times. 

Safety briefings shall be conducted before each day' s activities to include, but not be limited to: 

Designated roles of the PIC and VO 

Risk management and mitigation (essentially a Safety Management System process) 

Maintenance 

The Operator has been an aircraft owner for over 30 years and is intimately familiar with proper 

routine, periodic and scheduled maintenance for a certificated aircraft. The same attention to 

detail will be applied to the maintenance of the sUAS under this operation. Prior to each flight 

operation, and following the flight operation, the sUAS will be inspected to insure that it is in 

proper operating order and in an airworthy condition. Any discrepancies will be noted in the 

maintenance log, which will be part of the permanent record of the aircraft documents. Any 

discrepancy which would render the sUAS unairworthy will require that the sUAS be taken out 

of service until the discrepancy is corrected and the correction so noted in the maintenance log. 

The maintenance log will be a part of the aircraft operating documents and available for 

inspection at the principle base at any time by appropriate governmental officials. 

Pursuant to this requirement, the operator will document and maintain a record of the sUAS 

maintenance, preventative maintenance, alterations, and status of replacement, overhaul, 

component parts and the total time in service of the sUAS. 

The operator will comply with all manufacturer's Safety/Service Bulletins or equalivant 

pertaining to the sUAS aircraft. 

The sUAS will only be operated if all systems are operating per manufacturer's specifications 

and in a discrepancy-free condition. 

Maintenance or repairs that may affect the sUAS operation or flight characteristics shall 

undergo a functional flight test. The functional flight test shall be recorded in the sUAS records. 

111 3r:-
If the functional flight test is completed successfully, the sUA$ can be returned to service by the 

PIC. 

The operator shall follow the manufacturer's sUA$ maintenance, overhaul, replacement, 

inspection, and life limit requirements. When not provided by the manufacturer, aircraft 

maintenance, component, overhaul, replacement and inspection maintenance requirements 

shall be established by industry standards and Operator's own experience, based on years of 

maintaining certificated aircraft. 

All sUA$ shall be identified by serial number, registered in accordance with 14 C.F.R. Part 47, 

and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C, 

except with respect to the size of the markings. Markings shall be as large as practicable. 

Coolev Drones Services has produced this Operations and Training Manual as a confidential 

document under 14 C.F.R. § 11.35(b}, the entire content of this Manual contains confidential 

commercial and proprietary information that Cooley Drone Services has not and will not share 

with others. This Manual contains operating procedures and training procedures that are not 

available to the public and are protected from release under the Freedom of Information Act, 

5 u.s.c. § 552lbll4J. 

12 I I g c