July 22, 2015
U.S. Department ofTransportationDocket Management System 1200NewJerseyAve., SE Washington, DC 20590
Dear Sir orMadam: 

## 11

Attached please find The Illth Group Inc. (The Illth) request, as a member ofthe Professional Aerial Photographers Association, International (PAPA), for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Systems ("sUAS") for aerial imaging to include video and still photography. This exemption request is initially for the use ofthe Phantom 3 sUAS manufactured by DJI Innovations, an established sUAS company and in accordance with the sUAS training and certification program as administeredby PAPA. Also attached to this letteris the equipment "The IllthFlightManual" (Manual), which outlines the operating requirements, limitations, and technical specifications for the DJI System as used by The Illth. The Illth has reviewed this Manual and has found it to be acceptable for sUAS operations. Applicant submits this manual as a Confidential document under 14 CFR 11.35 (b) as the entire Manual contains proprietary information that the applicant has not and will not share with others. The Manual contains operating conditions and procedures that are not available to the public and areprotected from release underthe Freedom ofInformationAct 5USC 552 et. seq. Thankyoufor yourtime and consideration, andplease letme knowifyouhave any questions.
Sincerely,

PatrickB anger The Illth Group Inc. Corporate Officer

Professional AerialPhotographersAssociation-InternationalSection333 Doc 15-006July22, 2015 U.S. DepartmentofTransportation DocketManagement System 1200NewJerseyAve., SE Washington,DC 20590 

### Pagel2

Re: ExemptionRequest Section333 oftheFAAReformAct andPart 11 oftheFederalAviation Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119;91.121; 9.151(a); 91.405 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). DearSirorMadam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, The 111th, an aerial photography and digital imaging company, onbehalf ofitselfand its related affiliates under common ownership and control, hereby applies for an exemptionfrom the listed Federal AviationRegulations ("FARs") to allow commercial operation of its Small Unmanned Aircraft Systems ("sUAS") for aerial imaging for video and still photography, so long as such operations are conducted within andunder the conditions outlined hereinoras maybe establishedbythe FAAas requiredby Section333. As detailed in this document and the attached Flight Manual, the requested exemption would permit the operation of 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 best practices safety protocols followed by The 111th during aerial photography operations in accordance with the training and certification provided by the Professional Aerial Photographers Association, International (PAPA). The 111th is a member ofthe Professional Aerial Photographers Association-International (PAPA) and has a demonstrated record of safe operations in the National Airspace System (NAS). Principal employees have received ground school training and have logged well over 25 hours of sUAS flight operations. The Pilot In Command (PIC) proposedbyThe 111this aFAA licensedpilotwithyears ofsafe and successful aerial photography operations. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "
...establish requirements for the safe operation ofsuch aircraft systems in the National Airspace System." Section333(c) oftheReformAct.

ProfessionalAerialPhotographersAssociation-InternationalSection333Doc 15-006Thename and address ofthe applicant is: The 111thGroupInc. 13025 MurphyAvenue, Ste 100 SanMartin, CA95046 PatBelanger,FAALicensedPilot#1879650 JulieBelanger, FAALicensedPilot#3791637 Tayler Schmitt,FAALicensedPilot#3795690 PH: 408-683-9111 Email: 111thaerials(a{gmail.com Regulations from whichthe exemptionisrequested: 14 C.F.R. Part21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 109 14 C.F.R. 119 14 C.F.R. 121 14 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.P.R. 417 (a) & (b)
I. STATUTORYAUTHORITYFOREXEMPTIONS 

### Pagel3

The Federal AviationAct expressly grants the FAA authorityto issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title iftheAdministrator finds the exemption in the public interest. 49 U.S.C. §4470l(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).



### ProfessionalAerialPhotographersAssociation-InternationalSection333Doc 15-006

### Pagel4 Section 333(b) of the Refonn Act assists the Secretary in determining whether sUAS may operate inthe National Airspace System (NAS) without creating a hazard to the user, the public, orathreatto national security. Inmakingthis determination, the Secretarymustconsider:
• • • The sUAS's size, weight, speed, and operational capability; Whetherthe sUAS operateswithinthevisualline ofsightofthe operator Whether the sUAS operates outside of highly populated areas and away from closeproximityto airports Reform Act §333(a). Ifthe Secretary determines that a sUAS "may operate safely inthe national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft inthenational airspace system." Id. §333(c) The 111th's sUAS are multi-rotor vehicles, weighing 20 or fewer lbs. including payload. They operate under normal conditions at a speed ofno more than 70 knots and have the capability to hover, and move inthe vertical andhorizontal plane simultaneously. The sUAS will operate only inthe Pilot's visual line ofsight at all times and will operate only withinthe controlled "Area of Operations" described in the Confidential The 111th Manual (Manual), attached as Exhibit 1 (hereinafter "Manual"). Such operations will ensure that the sUAS will "not create a hazard to users oftheNationalAirspace System orthepublic." ReformAct Section 333 (b). Given the small size ofthe sUAS involved and the restricted and controlled environment within which they will operate, our application falls squarely within the zone ofsafety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to commence immediately. Also, due to the small size ofthe sUAS, altitudes, and controlledareas inwhichthe sUAS will operate, approval ofthe application presents no national securityissue. Giventhe cleardirection in Section 333 oftheReformAct, the authoritycontainedintheFederal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant of the requested exemptions is in the public interest. Accordingly, The 111th respectfully requests that theFAAgranttherequestedexemptionwithout delay.
IT. PUBLICINTEREST 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 NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. By granting an exemption the FAA will fulfill Congress's intent ofallowing sUAS to operate with significant safetyprecautions inlowrisk environments.

ProfessionalAerialPhotographersAssociation-InternationalSection333Doc 15-006

## IS The use ofss on aerial photography operations can significantlyreduce the risk to photographers and participants. sUAS can inspect, photograph, and collect data on hard to get to areas that otherwise wouldrequire directaccess ormanned aircraft. Additionally, sUAS could compliment the use of helicopters and small aircraft to produce imagery for various purposes. The sUAS we propose to fly in this application are less than 20 pounds, and carry no combustible material on board, as opposed to the much larger conventionallypowered small aircraft. Shifting to sUAS from manned aircraftpresents a marked safety increase for ourworkers andthe public. Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection. The sUAS used by The 111th uses rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation ofsmall aircraft that are many hundreds oftimes heavier.
III. EQUIVALENTLEVEL OF SAFETYAND SECURITY The lllth proposes that the exemption requested herein apply to sUAS that have the characteristics and that operate withthe 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 protocols followed onimaging andphotography operations conductedwithconventional aircraft. The 111thwillbeboundbythe following limitations when conductingits sUAS operationsunder anFAAissued exemption: 1. The sUAS will beless than20pounds. 2. Flights willbe operatedwithinvisual line ofsight ofapilot. 3. Maximum total flight time for each operational flight will be 20 minutes. The operator calculates battery reserve, and will return the sUAS to the "Designated Safety Zone" with at least 20%batterypowerreserve shouldthat occurpriorto the 20 minute limit. 4. Flights will normally be operated at an altitude ofnotmore than 400 feet AGL, butnever in controlled airspace withoutpriorcoordinationand approval ofATC. 5. Flights will not be conducted within the surface area ofcontrolled airport airspace without prior coordinationand approval ofATC. 6. Flights will not be conducted within 5 miles of any uncontrolled airport without prior coordination and approval ofthe airport authority. 7. Crew for each operation will consist ofthe sUAS Operator who will keep the sUAS within his visual line ofsight at alltimes and a qualified Observer. 8. The sUAS operator will be trained in flight, operations, and safety procedures as detailed in the FlightManual. 9. The sUAS will only operate within a confined "Area of Operations" as defined in the Manual, including but not limited to evaluation of the airspace by reference to a current ProfessionalAerialPhotographers Association-InternationalSection333 Doc 15-006

## 16 1:500,000 scale FAA Sectional Aeronautical Chart. The Manual also reqmres the establishment ofa "Designated SafetyZone" for the flight operations area. 10. A briefing will be conducted regarding the planned sUAS operations prior to each day's production activities. It will be mandatory that all personnel who will be performing duties withinthe boundaries ofthe Designated SafetyZonebe presentfor this briefing. 11. All onsite personnel will consent to the sUAS flyover on site by waiver, and the Operator will obtain additional verbal orwritten consent ofall persons who will be allowed within 100 feet ofthe flight operation. 12. Operator will have beentrainedinoperation ofsUAS generally and will have received up-todate information onthe particular sUAS to be operated as requiredby theThe 111thManual. 13. Necessarywritten and/or oral permissionfrom the relevantpropertyholders will be obtained. 14. All required permissions and permits will be obtained from territorial, state, country, or city jurisdictions, including local law enforcement, fire, or other appropriate government agenc1es. 15. Ifthe sUAS loses communications or loses its GPS signal, it will have the capabilityto enter "loiter mode" and hover, reestablish satellite connection, and return to a predetermined locationwithinthe "Designated SafetyZone" and land. 16. The 111th personnel will be easily identified by law enforcement personnel and the Public through wearing a green fluorescent or blaze orange vest with Section 333 Grant and PAPA credentials prominently displayed within aweatherproofcontaineronthepersonsback. IV. DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR61.113 (a) & (b): Private pilot privileges and limitations: Pilotin 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 ofcurrent operations by requiring the Operator operating the aircraft to have completed a sUAS flight training course of25 hours before flying a sUAS (See the The 111th Manual for details) or meeting any FAA pilot licensing requirement. Unlike a conventional aircraft that carries the pilot andpassengers, the sUAS is remotely controlled withno living thing or cargo on board. The area of operation is controlled and restricted per prior planning and necessary coordination with the local FSDO ifapplicable, and all flights are planned and coordinated in advance as set forth inthe The 111thManual. The sUAS to be operated hereunder is less than 20 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a controlled Area ofOperation as set out in The 111th Manual. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the Operator, pursuant to the The 111th Manual requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the Area of Operation as is currently done on aerial photography operations. The FAA will have advance notice of all operations as required.

Professional AerialPhotographersAssociation-InternationalSection333 Doc 15-006

## 17 The risks associated with the operation ofthe sUAS are therefore diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, and allowing operations ofthe sUAS as requested, with an operator who has met the minimum requirements stated in The lllthManual, achieves the level ofsafety contemplated by 14 C.F.R. §61.113 (a) & (b). 14 C.F.R. 91.103: PreflightAction This regulation requires that each Operator in Command take certain actions before flight to ensure the safety offlight. An exemption is needed from this requirement as the Pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklistinthe The IllthManual. These actions will provide an equivalentlevel ofsafety.
14 C.F. R. 91.119: Minimum/Maximum SafeAltitudes Section 91.119 establishes safe altitudes for operation ofcivil 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. This exemption is for a multi-rotor craft that flies similarly to a helicopter, with vertical takeoffand vertical landing, which will typically operate at altitudes ofless than 400 AGL, so an exemption maybe neededto allow such operations. The sUAS will never operate at altitudeshigherthanthe base ofcontrolled airspace without prior approval and coordination with ATC and will be in a Controlled Area with a "Designated Safety Zone", where buildings and people will not be exposed to operations without the specified pre-obtained consent. (See The Illth Manual for detailedprocedures.) The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the locationwhere itis operated. No flight will be takenwithouttherequiredpermission ofthe property owner or local officials. Because ofthe advance notice to the property owner and any onsite personnel, as outlined in the The Illth Manual, all affected individuals will be aware of the planned flight operations. Unlike flight operations with aircraft or rotorcraft weighing far more than the maximum 20 lbs. proposed herein, our sUAS will not carry flammable fuel. In addition, the low-altitude operations of the sUAS will ensure separation between sUAS operations and the operations ofconventional aircraftthatmust comply with Section 91.119. 14 C.F.R. 91.121: AltimeterSettings This regulation requires each person operating an aircraft to maintain crmsmg altitude by reference to an altimeter that is set "
...to the elevation ofthe 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 ofsafety

ProfessionalAerialPhotographersAssociation-InternationalSection333 Doc 15-006

### IS will be achieved by the operator, pursuant to The Illth Manual and Safety Check list, confirmingthe altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight. 14 CFR91.151 (a): Fuel requirements for flight in VFRconditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited to operations in controlled environments as outlined in the The Illth Manual, andhas alimitedrange and flight time whichrequire an exemptionfrom 14 CFR91.151 (a) The battery powering the sUAS provides approximately 20 minutes ofpowered flight. To meet the 30 minutereserve requirement in 14 CFR §91.151, sUAS flights wouldnecessarilybe limited to approximately 5 minutes in length. Given the limitations on the sUAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight indaylight ornightVFRconditions is reasonable. The lllth believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). Operating the small sUAS, in a 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 ofthe small sUAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for whichthe exemption will be granted. An equivalentlevel ofsafety canbe achievedbylimitingflights to 20 minutes, orenoughbattery reserve to ensure thatthe sUAS lands atthe ground stationwith at least 20% ofbattery power (as determined by the onboard monitoring system and the operator), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere inits limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673,an d 10808. 14 CFR91.405 (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 inthe subpartE ofthis part and shall betweenrequired inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 ofthis chapter.
..," and others shall inspect ormaintainthe aircraft in compliance withPart43. Giventhatthese sections and Part43 apply onlyto aircraft with an airworthiness certificate,these sections will not apply to The Illth. Maintenance will be accomplished by the operator and pursuantto the flight manual and operatinghandbook as referenced inthe The IllthManual. An ProfessionalAerialPhotographersAssociation-InternationalSection333 Doc 15-006

## 19 equivalent level ofsafety will be achieved because these small sUAS are very limited in size and will carry a small payload and operate only in controlled areas for limited periods oftime. If mechanical issues arise, the sUAS can land immediately even ifoperating at amaximum of1200 feet AGL. As provided in the The Illth Manual, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

### ******* Pursuant to C.P.R. Part 11, the following summary is provided for publication in the Federal Register, shoulditbe determinedthatpublicationis needed: Applicant seeks an exemptionfrom the following rules: 14 C.P.R. §21, subpartH; 14 C.P.R. 45.23(b); 14 C.P.R.§§ 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.15l(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs orless) in aerial photography operations. Approval of exemptions allowing commercial operations of sUAS in the aerial photography industry enhances safety while reducing risk. Manned aircraft still photography and video may create a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 20 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose themto the risks associated withmanned aircraftflights. The operation of small sUAS, weighing less than 20 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional operations conducted with manned aircraft operating in close proximity to the ground and people. Privacy All flights will occur overprivate orpublic property with the property owner's prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise having agreedto be inthe area where aerial photographywill takeplace. 

### ******* ProfessionalAerialPhotographersAssociation-InternationalSection333 Doc 15-006110
Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security

- provide more than adequatejustificationfor the grant ofthe requested exemptions allowing commercial operation ofapplicant's sUAS in construction industrypursuantto the Manual appendedhereto.

Professional AerialPhotographersAssociation-InternationalSection333 Doc 15-006

# sUAS OperationsManual The 111 th

# Group} Inc.

22July2015This manual contains standard operating procedures and guidelinesforsUAS operations.



## Table ofContents 

## The lllth Group Inc. sUAS Operations Manual

PURPOSE, SCOPE, AND MISSION STATEMENT

.......................................................5 DEFINITIONS

......................................................................................................6-7 PERSONNEL RESPONSIBILITIES

..............................................................................8

Visual Observer

............................................................................................................8 PIC
................................................................................................................................8 Flight Team Composition

............................................................................................. 8 Qualification Requirements
..........................................................................................8 OPERATING LIMITATIONS AND CONDITIONS

...............................................................9 MAINTENANCE PROCEDURES

.................................................................................... 10 ROUTINE MAINENANCE

............................................................................................. 10 FullFlightMaintenance
............................................................................................. 11 Software Firmware Update Policy
.............................................................................. 12 LOGS AND RECORDS

..................................................................................................... 12

PilotandAircrafthours
.............................................................................................. 12
BATTERYLOGBOOK

.......................................................................................................... 12 FLIGHT PLANNING

......................................................................................................... WEATHER
.......................................................................................................................... 12

2SITEPERMISSIONS••••••..••••••••••••••••.•••••••••••••••••••••••••.•••••••••••••.•••••••••••••••••••••••••••••••••.•••.•••••••• 12 PRE-FLIGHTINSPECTIONSAND CHECKS ••••••••••.••.•.•••.•••••••••.•.•••••.•.••••••••••••••••..••••••••.••••••••••••••••• 13 DOCUMENTATION•.••.•••••••••••••..•.••.••••••••••.•.••.•••••.••••••••••••••••..•.•.•••.••••••••••••..••.•••.•...••••••••••••• 13 PRE-FLIGHT AREAAND PERSONNEL CHECKS•••.•••••••••••.•.•.•.•.•.•••••.••..•.•.•.••••.••••••••.•••••.•••.•.•.••.•••••• 14 CLOSED-SETOPERATIONS••.••••••••••••.•••••..•••.•••••••••••••••••••••••••••••.•••••.•••.•.•••••••••••••••••••.•••.••••••••. 14 ON-SITEPROCEDURES •••••.••••••••••••••••••.•••••••.••••••••••••.•••••••••••••••.••.•••.•.•••.•••••••••••••••••.•••••••• 14-15 SITESURVEY ••••••••••••••••••••.••••••••••••••.•.••••••••••••••••••••••••••••••••••••••••••••••••••••••••.••••••••••••••.••.•••••• 16 SELECTION OFOPERATINGAREASANDALTERNATIVES•.•••••••••••••••••••.••.•••••••••••••••••.••.••••••.••••••••••••• 16 BOUNDARIES.••.••••••••••••.•••.••••••••••••••••.•.••••.•••.••••••.••••••.•••••••••••••••.•••.••.•••••••••••••••••••••.•..••••.•• 17 ANEMOMETER WEATHER CHECK••••.••••.•.•••.••••••••••.••••.•.••••••••••••..••.•.•.•.•••••••••.••.•••.•.•••.•..•.•.•17-18 CREWBRIEFING..•.•••••••••.•••...••••••••••••••.•.•.••.•.••••••••••.••..••.••.•••....••.••..•..•.•..•.••••••••.•.•.••.•...••..•• 18 COMMUNICATIONS•••••••••••.•.••••.•.•••.•••••.••••••.•••.•••••••••••.•.•.••••••••.•.•.•.•...•.••..•••••••••••.•.••••••.•18-19 FREQUENCYSCANS .•.•••••••••.•..•••.••.•••••••••••.•••••••••••••••••.•.•.••••••••••••••.•.••.•.•.•••••••••••••••••••••••••••.• 19
BATTERYUSAGEAND CHARGING••..•••••••••••••••••••.•.•••••••••.••••••..•••••••••.•••••.•.•.•••••.•••••••••••••••••.••.•• 19 LOAD-OUTSAND EQUIPMENT••••••.••.••••••••.•••••••••••..•.•••••••••••••.•.••.•••••••••••••.••••.••.••••••••••••••••••••• 19 FLIGHT PROCEDURES.................................................................................................20 Motorstart............................................................................................................20-21 Take-off
...................................................................................................................... 21 In-Flight
.................................................................................................................21-22 Let-down/Landing

......................................................................................................22 Shutdown

..............................................................................................................22-23 EMERGENCY PROCEDURE ..........................................................................................23 Motor ThrustLoss
....................................................................................................... 23 3BatteryFailure
........................................................................................................... 23 BatteryFailure Failsafe

...............................................................................................24 Transmitter/ControllerBatteryFailure
...................................................................... 24 Loss ofControl Frequency
..........................................................................................25 Loss ofFrequency Failsafe

..........................................................................................25 Malicious orAccidentalInterference with ControlFrequency
..............................25-26 PilotIncapacitation
.................................................................................................... 26 AircraftIncursion
........................................................................................................ 26 FLY AWAY PROCEDURE

............................................................................................. 26 Crash andIncident Response
.....................................................................................26 APPENDIX A-CHECKLISTS

........................................................................................... 27 Site Selection Checklist

............................................................................................... 28 Pre-FlightStart-up Checklist

....................................................................................... 28 Pre-Flight Inspection Checklist

................................................................................... 29 In-flight

....................................................................................................................... 30 Landing Checklist

...................................................................................................30-31 APPENDIX B
.............................................................................................................. 32 Maintenance Logbook
................................................................................................ 33 APPENDIX C

.............................................................................................................. 34 Incident/AccidentLogbook
......................................................................................... 35 APPENDIX D
.............................................................................................................. 36 FlightRecordLogbook
................................................................................................ 37 APPENDIX E
.............................................................................................................. 38 Phantom 3 UserManual

4

### PURPOSE, SCOPE, AND MISSION STATEMENT The 111th Group Inc. (The 111tht a member of the Professional Aerial Photographers Association, International (PAPA) intends as the Operator to promote safe operation of sUAS in the National Airspace System (NAS) in a manner that is consistent with a long history of safe and professional flight operations in close cooperation with the Federal Aviation Administration (FAA). The Operators are experienced licensed pilots. The sUAS Pilot In Command (PIC) that will operate systems according to the approach outlined in this Manual of Procedures (Manual) are trained in accordance with this Manual and FAA regulations and have years of successful experience on Aerial Photographic flight missions. The intent ofthe Manual is to provide the outline ofa system to conduct safe and successful sUAS operations in accordance with the applicable FAA regulations and consistent with the Section 333 waiver that this Manual is based upon. It is expected that the Operator will continue to apply the skills and experience they have employed in manned aircraft operations under FAA regulations. This combination of prior successful flight experience and sound sUAS flight operational procedures is intended to promote the highest levels of professionalism in safe aerial photographicflight missions.

5

### DEFINITIONS The following definitions of words and terms apply to the information contained in this Manual and are specific to procedures and operations that are outlined herein. In the case of a conflict with an official FAA definition, the FAA definition will be the rule.
Anemometer- An instrument to measure the velocity of the wind in the Area of Operations. Area of Operations - Defined as the area where sUAS operations will be carried outfora specific flight orseries offlights on agiven mission. Checklists - Procedural checklists used by the PIC to verify proper and safe procedures during all phases ofsUAS operations. Designated Safety Zone- Defined and marked area ofground operations used for safe takeoffs and landings ofthe sUAS at agiven Area ofOperations. Flight Control Systems- The combination oftelemetry, PIC operated controls, and onboard control mechanisms that are employed to control theflight ofthe sUAS. Frequency Analyzer - A device used to scan the Area of Operations for possible interference from radio waves. 

### GPS- Global Positioning System. Handheld Radio- A radio transceiver capable of communication with other Pilots or FAA personnel in the Area ofOperations. Loiter Mode- A default recovery mode the sUAS goes into when communications are lostfrom the PIC. Maintenance Recommendations - Periodic maintenance recommendations for each ofthe sUAS components that have a usable life.

6Manual -This flight manual that combines the Operator specific procedures with the sUAS manufacturers' manual. Manufacturers Recommendations - Written recommendations provided by the manufacturers ofthe various components ofthe sUAS. NAS- National Airspace System. Non Participants - Persons who have not agreed to participate in sUAS operations. Operator - The entity submitting as the applicant on this waiver request to the FAA who will be responsible for all sUAS operations and procedures. PAPA- Professional Aerial Photographers Association, International. Participants- Persons who have agreed to participate in sUAS operations. Pilot In Command- Person who will flythe UA during sUAS operations and who is responsible for all safety related oroperational decisions underthe direction of the Operator in accordance with this Manual and FAA requirements. SOP- Standard Operating Procedures. sUAS

- Small Unmanned Aerial Systems as contemplated under the FAA guidelines, notto exceed 55 pounds in weight or 100 miles per hour in speed. Telemetry- Electronically transmitted data that provides control and information transmissions to and from the PIC and the sUAS. UA- Unmanned Aircraft. Visual Observer- An individual who is designated to observe flight operations and to maintain visual contact with the UA duringflight operations while maintaining communications and coordination with the PIC.

7

## PERSONNEL RESPONSIBILITIES VISUAL OBSERVER All operations will utilize aVisual Observer. The main responsibilities ofthe Visual Observer will be to ensure thatthe UA is operated within the visual line ofsight of both the PIC and Visual Observer at all times. The Visual Observer will maintain verbal communication with the PIC at all times. Prior to flight, the PIC will ensure that the Visual Observer understands and can perform all the duties required of the Visual Observer. PIC Pilot in Command is responsible for the safe operation ofthe sUAS at all times in accordance with this Manual and the applicable FAA regulations. Pilot in Command will be responsible for: • All support personnel. • Performing all pre-flight, flight phase, and post flight inspections, air worthiness, diagnostics, and testing. • Manufacturer recommended maintenance operations. • Weather condition assessments and forecast reviews. FLIGHTTEAM COMPOSITION The onsite flight team is composed of a Pilot in Command (PIC} and a Visual Observer (VO). The PIC is responsible for all flight operations and decisions to proceed. The VO is responsible to maintain visual contact with the UA and to provide constant communication with the PIC regarding aircraft status and surrounding conditions within the Area ofOperations. QUALIFICATION REQUIREMENTS The PIC must be a licensed pilot and must have completed the PAPA sponsored ground school with at least 25 hours of sUAS flight time. The VO must have completed sUAS ground school training and must demonstrate experience with FAA procedures and the standard procedures ofthis Manual.

8

### OPERATING LIMITATIONS AND CONDITIONS Operational Ceiling- Maximum 400ftAGL, per regulations. Operational Endurance- 23 minutes (average max) Maximum Speed - 100 MPH Maximum OperatingTemperature - 40 degrees C Minimum OperatingTemperature - 0 degrees C Maximum Operational Wind Speed- 15 MPH (gusts to 20 MPH}

9

## MAINTENANCE PROCEDURES Only The 111th personnel or an appointed service technician may carry out maintenance on the sUAS aircraft systems described in this operations manual. In all cases a Maintenance Logbook (see Appendix B) is completed to reflect any work undertaken and a flight 

### test, testing all functions (including the return-tohome failsafe facility}, is subsequently carried out by the PIC. ROUTINE MAINTENANCE The Pre-Flight and Post-Flight checklists shown in Appendix A are completed by the PIC every time a The 111th sUAS aircraft is operated. Every six months (or fifty hours of flight time - whichever comes first} the following inspection is carried out by the PIC. The inspection is recorded in the Maintenance Logbook along with any findings. Any issues identified are remedied and the aircraft undergoes afull flight-test beforethe aircraft is returned to Operational Status: • Inspection ofthe airframe for any damage, unusual marks and tightness of fixings; • Inspection ofthe motor mountingsfor correcttension; • Inspection ofthe propellers for condition, unusual marks, chips, cracks and tightness of fasteners; • Inspection ofelectrical wiringfor condition, unusual marks ordiscoloration; • Inspection of electrical terminal fittings and plugs for secure attachment and general condition; • Inspection of the attachment of all fittings such as flight controller, GPS antennas etc. for secure attachment; • Inspection of payload attachment points for condition and security of payload; • Inspection ofthe condition and function of all ancillary equipment such as transmitter etc. • Testing ofall system battery packs for charge status and general condition. Ifany issues or problems are identified then the aircraft is not allowed to fly until the issue has been remedied. If minor problems (such as damaged propellers, 10faulty battery packs etc.) are identified and remedied, and the PIC believes the aircraft is suitable to return to Operational Status then the work completed is noted in the Maintenance Logbook. If major issues are identified (such as an unserviceable motor, damaged airframe etc.), then the aircraft undergoes a full flight test regime (as described below), once the identified fault has been remedied. FULL FLIGHTTEST The system has all functions tested with a minimum offive minutes flight time by a qualified PIC recording any abnormalities in the Flight Record Logbook (Appendix D). Ifthe PIC deems the aircraftto be safe then he must sign the Flight Record Logbook as fit for Operational use. Systems with identified issues relating to firmware or software (see below) are grounded by The 111th until any problems are rectified. SOFTWARE AND FIRMWARE UPDATE POLICY All new software and firmware are thoroughly assessed before installation. Particular attention is focused on relevance to operations, reason for release and any known issues. Multi-rotor and sUAS forums are consulted regularly for any reported issues with the release and only when the validity of the upgrade has been confirmed is the upgrade considered. In all circumstances the upgrade is performed by qualified The 111th personnel or appointed service providers. All upgrade information such as version numbers and new functions are recorded in the Maintenance Logbook. The 111th PIC are made aware that the firmware or software has been upgraded before any flight operations are undertaken. Any upgraded system has all functions thoroughly tested with a minimum of five minutes flight time by a qualified The 111th PIC who records any abnormalities in the Flight Record Logbook. Ifthe PIC deems the aircraft to be safe then the PIC signs the Flight Record Logbook as fit for Operational use. If any doubts exist as to the new upgrade the aircraft is downgraded to the previous firmware and the flight test procedure is repeated. Systems with identified issues relating to firmware or software are grounded untilthe problem can be rectified.

11

## LOGS AND RECORDS PILOTAND AIRCRAFT HOURS The 111th PICs are required to keep a log of pilot and aircraft hours. To meetthis requirement, The 111th holds and updates a spreadsheet-based Personal Flying Log Book forAircraft Operating Crew. This log book is a separate documentwhich can be viewed on request (see sample page atAppendix D). BATTERY lOGBOOK The 111th Personal Flying Log Book (Appendix D) additionally records information about battery condition (charge) before and after each flight. The Battery Logbook is accompanied by - and supported with -the Maintenance Logbook (Appendix B),and The 111th Incident Logbook (Appendix 

### C). 

## FLIGHT PLANNING WEATHER Operator will require PIC to obtain all necessary weather information in order to plan and conduct safe flight operations according to and as referenced by any applicable UA Operator Manuals. If operating near an operational Automatic Terminal Information Service (ATIS) or AUTOMATED WEATER OBSERVATION SYSTEM (AWOS), the appropriate broadcast system will be consulted. If ATIS or AWOS broadcasts are not available, PIC will consult-alternative sources for a currentweatherforecasts. The operating envelope for the Phantom 3 has been referred to earlier. It is emphasized that the PIC is to ensure the operating envelope environment meets or exceeds all safe and legal visibility, precipitation, humidity, and wind limitations forsafe operation. SITE PERMISSIONS • Secure permissions from property owner if required. • Secure permissions from participants. 12• Coordinate with local law enforcement if required. • Prior to operations, Operator receives permission for take-off and landing from the relevant land-owner. In most cases permission attainment is unproblematic as the landowner and the client are the same individual (or entity). In the case of local authority owned land, the relevant authority is contacted in advance to secure permission for take-off and landing, and to find out about any operating restrictions or specific insurance requirements that might apply. PRE-FLIGHT INSPECTIONS AND CHECKS Prior to each flight, the PIC will conduct a pre-flight inspection and determine if the sUAS is in a condition for safe flight, and to account for all possible discrepancies or inoperable equipment. If the inspection reveals any condition that will affect the safe operation ofthe sUAS, the aircraft will be prohibited from operating until the necessary maintenance can be performed and the sUAS can be returned to safe flight. The preflight inspections will include the following components according to the recommended checklists in the DJI Phantom 3 operator manual, and in theThe 111th checklist: 

### D Airframe 

### D Battery 

### D Transmitters 

### D Camera and Gimbal 

### D Propulsion system including propellers In addition, with the battery attached and turned on in the sUAS, the PIC will oversee and monitorthe series ofdiagnostic tests to determine and verify proper voltage levels, control function, communication, and GPS satellite connectivity acquisition. PIC will utilize the DJI Phantom 3 LED indicators as well as telemetry data to determine if the proper preflight diagnostics have been completed. The PIC will also perform and log a pre-flight compass calibration each time the sUAS is flown from a new location. DOCUMENTATION PIC will ensure that all documents used by The 111th to ensure safe flight operations and any document required under 14 CFR 91.9 and 91.203 must be 13available at the Ground Control Station on site at any time the UAV is operating, and ready to be made available to any law enforcement official upon request. If possible, these documents will be on the PIC's person at all times during flight operations, and accessible to law enforcement without interrupting the PIC while conducting flight operations (possibly in a pouch on the back ofthe vest). PRE-FLIGHT AREA AND PERSONNEL CHECKS • Survey flight operations area for safety concerns and to verify conditions. • Examine all components of the sUAS to verify proper function in accordance with the applicable manuals and manufacturer's instructions. • Verify notification to all personnel on site. • Establish Designated SafetyZone and verify safe clearances. • PIC should wearthe specified safetyvest. • The ultimate responsibility for aircraft airworthiness and operational safety rests with the UAV pilot-in-command. For this, the PIC- as an aiduses a Pre-Flight Checklist (see Appendix A). In summary, the Pre-Flight Checklist prompts examination ofthe following: 

### D The airframe (for condition and lack ofdamage); 

### D The battery (for level-of-charge and security ofattachment); 

### D The transmitter (for level-of-charge and to check that switches are in the 'home' position); 

### D The camera (secured, on and operating). 

### D Propulsion system
• In addition, when the flight battery is connected to the UAV, the flight controller undertakes a series of diagnostic tests (while simultaneously locatingthe position ofGPS satellites). CLOSED SET OPERATIONS Ifthis exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply: • The operator must have a Motion Picture and Television Operations Manual (MPTOM) as documented in this grant ofexemption. 14• At least 3 days before aerial filming, the operator ofthe sUAS affected by this exemption must submit a written Plan ofActivities to the local Flight Standards District Office {FSDO} with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concurrence ofthe FSDO. The plan of activities must include at least the following: o Dates and times for all flights; o Name and phone number ofthe operatorforthe sUAS aerial filming conducted underthis grant ofexemption; o Name and phone number ofthe person responsible forthe on-scene operation ofthe sUAS; o Make, model, and serial or N-Number ofsUAS to be used; o Name and certificate numberofsUAS PICs involved in the aerial filming; o A statementthatthe operator has obtained permission from property owners and/or local officials to conductthe filming production event; the list ofthose who gave permission must be made available to the inspector upon request; o Signature ofexemption holder or representative; and o A description ofthe flight activity, including maps ordiagrams ofany area, city, town, county, and/orstate overwhich filming will be conducted and the altitudes essential to accomplish the operation. • Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder's MPTOM. ON-SITE PROCEDURES 

### The on-siteprocedures undertaken by The lllth are conductedin accordance with and controlled through an extensive use of checklists. For this reason the following sections repeatedlyreferto various checklistsfound inAppendixA ofthis Manual.
15• Site Survey - In advance of operations, a survey is undertaken to review the site, its terrain, structures and surroundings - to check any assumptions made about the location prior to arrival and to adjust the operations plan accordingly. For this, an On-Site Survey Checklist is used (see Appendix A, page 25}. The primary purpose of the site survey is to make a visual check ofthe operating area with the objective of identifying any potential hazards.

• Selection of Operating Areas and Alternatives - In advance of the preflight On-Site Survey, Google maps will be consulted and - if possible - the local site will be visited beforehand. The site will be specifically checked in terms of: o Proximity to Airport Reference Points (ARP} as denoted in the Airport Facility Directory (AFD}. Must operate outside 5 miles of ARP, unless otherwise agreed upon by virtue of written letter of agreement with the airport's management, or otherwise permitted by the COA issued toThe 111th o Ability of PIC and VO to operate the sUAS clear of, and give wayto, all manned aviation operations and activities atall times. o 500ft. clearance ofall non-participating persons, vessels, vehicles, and structures unless; A. sufficiently protected in the event ofan accident, and the nonparticipating persons remain protected at all times during operations ofthe sUAS, and B. The owners and controllers ofany vessels, vehicles, orstructures has granted permission forthe operating closer tothose objects and the PIC has made a safety assessment of the risk ofoperating closer to those objects and determined that it does not present an undue hazard. o Ability ofThe 111thto conduct operations over private or controlled access propertywith permission from the owner/controller or representative ofsuch, and said permissions are granted. o Proximityto radio interferences 16o Prevailing weather conditions have been adequately assessed, including; high winds, convection, visibility, minimum cloud clearance (500ft below, and 2,000 ft horizontal clearanceL or when visibility is less than 3 miles from the PIC. The primary site for take-off and landing will be assessed (size, shape, surface, slope and surroundings) and an alternative site will be identified should the primary site become unavailable or unsuitable.

• Boundaries -The 111th requires that proper identifiers and signage will be in place in the operating area to alert people to the fact that aerial work is being conducted. The PIC will be responsible for cordoning to ensure safe distances from operations are observed. Cordoning procedures to be practiced include:



### • o Take-off and Landing safety Area: PIC will determine the safe distances ofall people from the take-offand landing operation ofthe sUAS. The PIC will also establish a cordoned area with clearly marked delineation the take-offand landing operations. o Signage and Identifying Clothing: The PIC will place signage at each entry pointwithin the operations area alerting people tothe following: A. Low altitude aerial work is being conducted B. Use ofany actual sensing equipment being used C. A request asking people to not enterthe area without first notifyingthe PIC orThe 111th designated on-site flight operations personnel D. PIC and VO will put on outerwearthatwill identifythem in their respective roles. Signage will be attached on their person thatwill instruct law-enforcement, observers, or any other people presentthatthey are not to be interrupted un-necessarilywhile conductingflight operations. Anemometer Weather Check- Beyond pre-site planning weatherforecast checks, The 111th requires that the PIC conduct specific onsite weather checks. The PIC will utilize a hand-held or portable Anemometer to 17determine wind speed, direction, temperature, and humidity. Aerial operations will only be conducted within the specific recommended wind and humidity limitations of the sUAS manufacturer's operating manuals, or if not identified therein, only in conditions where wind speed is less than 15mph, gusting up to 20mph.

• Crew Briefing - The 111th flight operations personnel will typically include the PIC, VO, and other possible ground crew. The operations personnel, in addition to any other parties that may be present, will be briefed priorto the start ofoperations. The briefingwill include: o Introduction to the equipment being used includingthe sUAS and the ground station functions, with particular emphasis on moving parts including weight ofthe sUAS, and the harm or damage that could possibly be inflicted by coming into contact with those components (particularlythe propellers, and hot surfaces) o Familiarization with the failsafe return-to-home systems and instruction on how to activate those systems if the PIC is unableto activate those systems o Expected flight plan, holding positions, flight duration, and overall flight boundaries. o Expected responsibilities and authority of each flight operations personnel o Identification and familiarization with the take-off and landing designated areas, and the requirements for remaining clear of those areas at all times. o The need for all present to alert the PIC of any encroachments of people or objects intothe airspace and ground boundaries o Importance of mitigating any possible distractions or unnecessary communication with the PIC duringoperations o Careful review of Lost Link and emergency procedures • Communications - The 111th uses channel-hopping technology on 2.4GHz to maintain communications with the UAV for the purposes of 18platform control. There is no communication ('downlink') from the UAV to the ground station. In the event of loss ofor interference with the control frequency, the UAV is programmed to return to its take-off position and land autonomously ('return-to-home'). This failsafe procedure is described further under Emergency Procedures.

• Frequency Scans - The 111th will perform frequency scans to help identify possible conflict with radio communications. This will be performed via a hand-held or portable radio spectrum scanner by the PIC. These scans will include a full spectrum scan of the applicable frequency range ofthe sUAS. Possible sources of radio interference or conflict will be identified and evaluated to determine ifflight operations can be safely continued.

• Recharging and Battery Use (Fuel Management) - The DJI Phantom 3 utilizes a 4480 mAh 15.2V LiPo 45 "intelligent" battery. Batteries are charged at base prior to flight operations. The number of batteries that will be transported to the flight operations area will be based on the specific needs of the flight operations or mission. The battery capacity will be tested utilizing the internal proprietary tester on the battery, and will also be checked utilizing the proprietary DJI software, as well as any internally sensed telemetry software and hardware attached to the sUAS. A battery charge log will be kept via the proprietary DJI Phantom 3 software and will be completed priorto everyflight. Any batteryfound to be less than fully charged, damaged, displays insufficient voltage, or otherwise defective will not be used.

• Load-outs and Equipment -The Phantom 3 is a simple quad-copter sUAS with limited capability for loads and equipment. Removable equipment includes the battery, gimbal, camera, telemetry hardware, antenna, and imaging transmitter. The battery is held in place via proprietary fittings. The gimbal is attached via screws into the airframe. The camera is attached to the gimbal using screws and a proprietary harness. All other equipment is attached using nylon fittings, Velcro, or adhesives. Total takeoff weight with these components will not exceed the maximum recommended takeoff weight identified in the Phantom 3 19Users/operators Manual of 1280 grams, with a total payload weight not to exceed 300 grams. Payload security is tested prior to any operations both visually and by vigorous tactile testing. All attachment points will be inspected and tested weekly. 

## FLIGHT PROCEDURES The 111th will utilize checklists to direct the flight operations personnel in flight procedures. The following section will continually refer to the several checklists presented in the Appendix.

• Motor Start- All ofthe various preflight checks will have been performed priorto motorstart and will include:

o PIC and VO will put on identifying outerwear. o Pre-flight compass calibration, GPS verification, and voltage diagnostics completed. o Take-off position and location is checked to ensure it is clear of obstacles, debris, potential hazards, and people. o Transmitter switches are placed in the proper configuration, includingthe home switch and GPS mode switch. o Transmitter is on and properly charged with voltage confirmed. o Battery is secured, on, and properly seated. o Camera and gimbal is armed, responding to commands, and stabilized. o sUAS is placed in the propertakeoff position. o LED flight mode indicator, and telemetry read-out shows adequate GPS connectivity accordingtothe DJI Phantom 3 User/operators Manual. o LED flight mode indicators and telemetry read-outs showthe proper flight mode is selected DJI Phantom 3 User/operators Manual.

20o Camera is switched on. o All flight operations personnel are in their proper position and atthe ready. o Start motors, and establish functional pre-take-off power setting.

• Take-Off - Once motors have been started, the PIC will verify that the pretake-off checklist has been completed. Once this has been verified, the PIC will followthefollowingtake-off procedure: 1. Apply power for a controlled ascent to a safe low-level test altitude overthe take-offarea, and then hold. 2. After in hold, PIC performs check of all control stick response including rudder, aileron, elevator, and throttle to ensure proper response to commands. 3. PIC confirms with VO that the flight operations area is free of obstructions or other manned or unmanned airtraffic. 4. PIC confirms with all flight operations personnel that they are ready to proceed with flight operations as planned.

• In-Flight - The 111th requires that the PIC is free to concentrate on positioning, scanning, and monitoring systems and the flight operations area without un-necessary distraction, and to ensure the flight is compliant with remaining 500 ft clear of all non-participating persons, vessels, vehicles, or structures unless proper permissions have been obtained as described in the previous section addressing the selection of sites. Throughout the flight, PIC will take particular care to remain within the established operating permissions and envelope by executing the following practices: o Verify through verbal communication with the VO that they are alerted to any manned or unmanned aircraftwithin the flight area. o Verify through verbal communication with the VO that obstacles are being identified and avoided. o Interval monitoring of voltage and communication with UAV to ensure adequate voltage according to the DJI Phantom 3 User/operating Manual for safe return and landing. 21o Monitor time since motors were started to ensure a minimum of 3 minutes of batteryfuel is available for return and landing of UAV. o A safety margin of a minimum of 3 minutes of battery life is maintained at all times. o Maintain visual contactwith flight systems/mode and battery LED light indicators at all times. o Maintain situational awareness ofchanges in weather, visibility, or cloud avoidance at all times. o Maintain operation speeds less than 100mph. o Maintain visual contact with UAV atall times. o Ensure VO has visual contactwith the UAV in flight at all times. Establish a position hold until VO re-establishes visual contact with the UAV ifcontact is lost.



### • Let-Down/Landing- To execute a safe recovery and landing of the UAV, the PIC will ensure thatthe following practices are followed:

o Establish and guide the UAVthrough a safe route to directly above the cordoned take-off and landing area. o Maintain a safe descent rate and follows all procedures and techniques to avoid vortex state orsettlingwith power. o Verifythat a minimum of3 minutes of battery life is available, as mentioned above, to ensure a holding position ifthe landing area is not cleared. o Verifythatthe landing area is clear ofdebris, obstacles, people, or hazards thatwould preclude a safe landing.



### • Shutdown - Upon landing, the throttle is returned to the home position causing the rotors to stop spinning. Operations then proceed as follows: • The UAV battery is switched offordisconnected. • The camera is stopped and is then switched off. • The UAV is removed from the landing area and is checked for any abnormalities or damage. 22• The transmitter is switched off. • The UAV battery is removed, tested, and then the battery is safely secured and stored.


## EMERGENCY PROCEDURES The emergency procedures described below address the following, safety-critical question: 

### In the eventofa malfunctionfailure orotherin-flightemergency/howis the sUAS going to safely land withoutcreating a hazard to otherairspace users or personsorpropertyon theground? MOTORTHRUST LOSS As a quad copter, The Phantom 3 has no 'rotor redundancy'. Loss of power to a motor on a quad copter will result in a crash. For this reason, The 111th takes specific preventative steps to ensure that loss of powerto a motorwill not occur: • Wiring integrity is checked visually priorto any flight operations. • A pre-flight battery check is undertaken to testthe charge ofthe cells. • Upon take-off, the sUAS is lifted into a temporary, low-altitude holding position and the throttle/ rudder and aileron/elevator control sticks are moved to check that UAV is responding as expected. Ifthere is a loss ofthrust to a motor, any residual control left available to the PIC will be used to guide the UAV away from people and objects to avoid injury or damage to property and people. Every effort will be made to restrict the crash site tothe safest possible position. BATTERY FAILURE As has been addressed in above previous sections, The 111th has procedures and practices in place designed to prevent sUAS battery failure or malfunction, and they include: • The batteries are physically inspected and tested through all phases of preflight and postflight for damage or swelling • The Battery performance and condition is tested prior to each flight to ensure they are fully charged, and the proprietary DJI Phantom 3 software 23charge track/log is checked to ensure the battery meets the minimum safe requirements as specified by DJI in operating manual and firmware specs. • Throughout all phases offlight, the battery voltage, percentage of charge remaining, and time in operation is constantly monitored via the telemetry transmission to the ground station to ensure there is the proper minimum voltage and time to return and land is achieved and maintained. • The PIC will immediately land the UAV in the nearest possible landing area if telemetry indicates the minimum voltage, time in operation, or percentage ofcharge are not met. BATTERY FAILURE FAILSAFE (Low Battery RTH) The low battery level failsafe is triggered when the DJI Intelligent Flight Battery is depleted to a pointthat may affectthe safe return ofthe aircraft. Users are advised to return home or land the aircraft immediatelywhen prompted. The DJI pilot app will display a notice when a low batterywarning is triggered. The aircraft will automatically return tothe Home Point if no action is taken after a 10 second countdown. The user can cancel the RTH procedure by pressing the RTH button on the remote controller. The thresholds forthese warnings are automatically determined based on the aircraft's current altitude and distance from the Home Point. The aircraftwill land automatically ifthe current battery level can only support the aircraft long enough to descend from its current altitude. The user can still use the remote controllerto alterthe aircraft's orientation duringthe landing process. A more detailed description of indications, warnings, and thresholds is presented in Appendix E-Phantom 3 User Manual, page 13 and 14, ofthis document. TRANSMITTER/CONTROLLER BATTERY FAILURE As has been mentioned previously, through the extensive use of checklist procedures, The 111th requires that the PIC ensure the DJI Phantom 3 controller (ground station) will be fully charged prior to any aerial operation. Any monitors being used to displaytelemetrywill also be fully charged. CONTROLLER BATTERY FAILSAFE

24The 111th will use The DJI Phantom 3 flight control system that incorporates an automated failsafe system which commands the UAV to Return to Home and land ifthere is a loss of remote control for a period of3 seconds due to batteryfailure or any other cause. When the controller battery level is critically lowThe Remote Status Indicator will blink red and sound an alert. LOSS OF CONTROL FREQUENCY (and/or Ground Station Failure) To help prevent a loss of control frequency, The 111th requires that the PIC ensure flight operations only occur within un-aided visual line of site VLOS at all times. Doing so will keep the UAV well within the required minimum range ofthe DJI Phantom 3 controller/transmitter. LOSS OF CONTROL FREQUENCY FAILSAFE Ifthe control frequency signal is lost for more than 3 seconds {sUAS out of range, ground station failure etc.) the DJI Phantom 3 Flight Controller has been programmed to switch the sUAS into failsafe mode and it will 'return to home' {RTH} and auto land: • If the failsafe occurs while in GPS mode according to the parameters of the DJI Phantom 3 User/Operator Manual, the UAV will return to the takeoffand landing area and auto-land. • Ifthe fail location occurs while in A Til mode according to the parameters ofthe DJI Phantom 3 User/Operator Manual, the UAV will auto-land. • The RTH failsafe mechanism works by the sUAS Flight Controller saving the home (take-off) point automatically when the throttle stick is moved for the first time (after 6 or more GPS satellites have been acquired - denoted by a single red pulse from the LED or a series ofcontinuous green pulses). The RTH failsafe function on the sUAS is tested on aweekly basis by The 111th by switchingthe transmitter offduring atestflight session. MALICIOUS OR ACCIDENTAL INTERFERENCE WITH CONTROL FREQUENCY As was mentioned in previous sections, through the extensive use of checklists, The 111th requires that the PIC utilize a Spectrum Scanner to ensure there is no accidental or malicious radio interference. In the unlikely event that this should

25occur, the PIC will initiate the failsafe procedure mentioned in the previous section

• Pilot Incapacitation - If the pilot-in-command becomes incapacitated to the extent that control ofthe UAV becomes unviable, the UAV will hover in a stationery position until the battery's second level low-voltage protection is triggered. At this point, the UAV will descend and land in a steady, controlled manner. If an observer is present, they will have been briefed on the sUAS's failsafe (return-to-home) mode and its activation (see Section on "Crew Briefing").

• Aircraft Incursion - If another aircraft should enter or appears to be entering the Visual Line of Sight Operating Envelope VLOS, PIC will operate the UAV to immediately maintain safe visual separation, and give way to any manned flight operation.

FLY AWAY PROCEDURE A "fly away" is defined as the loss of control transmission link where the PIC no longer has control or the ability to command the UAV to remain within the bounds of the intended operation area. In the unlikely event that this should occur, the PIC will observe and record the direction offlight heading, speed, and altitude ofthe UAV, and then follow the Incident Response Procedure as outlined below: • Crash 

### & Incident Response While The 111th takes extreme caution in its flight procedures to prevent a loss of control or crash, any incident, accident, or operation that transgresses the lateral orvertical boundaries as defined by the applicable COA issued must be reported to the FAA sUAS Integration Office (AFS 80 within 24 hours. The following procedures will also be ensured by the PIC: o PIC will have on their person a copy of the local emergency response contact information, including fire, law enforcement, medical response, and the sUAS Integration Office contact information.

26

# AppendixA

--·--·-----·---------- ·-- 

### -----·-- 

# Checklists

27

### SITE SELECTION CHECKLIST:



### o Review applicable charts and note airspace including Special Use Airspace (SUA)/ Prohibited Areas/ and nearby designated airport traffic patterns. Assess property boundaries within the working area and consider coordination efforts and documentation needed forsafe operation. 

### o Check for NoticestoAirmen (NOTAMS) 

### o Determine aweather observation source forthe area. 

### o Note prevailing weather conditions. 

### o Assess Risk Factors. 

### o Visually checkthe operatingarea and identify potential hazards: • Persons/ vessels/ trees/ fencing/ structures/ high-tension lines/ livestock/ sensitive habitats areas/ noise abatement. 

### o Analyze and determinethe best take offand landing zone. 

## o Account for hard or soft surface conditions including sloping and terrain differences. 

### o Establish an alternate if the primary take off and landing zone should become unavailable or unsuitable. 

### PRE-FLIGHT START-UP CHECKLIST: (all models) 

### o Verifytransmitterand on-board aircraft batteries are fully charged. 

### o Ensure nofrequency conflicts with video and transmitter

## I receiver. 

### o Check rotors to ensure they are in good structural condition and properly secured. o Check motors. o Check the landing gear fordamage and function. o Ensure photo

## I video equipment mountingsystem is secure and operational. o UAV

## I Drone is in a level location safe fortakeoff. o FPV

## I Power up ground station. o FPV

## I Power upVideo receiver. o If using Video recorder/ turn on camera system. o Camera settings are correct (still images/ video/ frame rate). o SD camera memory clear and inserted intothe camera. o Action 

## I Startfilming. D 

### All transmittercontrols move freely in all directions. 28

### o All transmittertrims in neutral position. 

### o All transmitter switches in correct position (typically away). o Transmitter throttleto zero. o Radio transmitter on. o Connect

## I poweron batteryto airframe. o Ensure led indicators and audible tones are correct. o Timer on (ifapplicable). o FPV, confirm video is in monitor

## I goggles. o Scan for nearby cars 

## I people

## I animals. o Say "CLEAR!". o Arm flight controller. o Increase throttle slightly listeningforany abnormalities. o Short 20-30 second hover at 3-5 feet (listen forvibrations

## I loose items). o Confirm Voltage levels are correct. 

### PRE-FLIGHT INSPECTION CHECKLIST: o Perform initial walk-around. o Inspect UAVfor cracks in jointsand structural members. o Inspect UAV for loose ordamaged screws, ties, fasteners, straps. o Inspect UAVfor loose ordamaged wiring. o Inspect UAVfor loose ordamaged connections (solder, plugs, etc.). o Inspect prop mounts and screws and apply slight counter pressure on arms to check for loosened components. o Ensure antennas and masts are secure. o Inspect

## I clean FPV Camera and Lens and insure it is secured and connections are firmly attached. o Ensure camera settings are correct (still images, video, frame rate). o Ensure FPV Transmitters are secure and operational. o Ensure batteries are fully charged, properly seated and secured. o Ensure thefollowingfail-safe equipment is functioning: o RTH (return to home). o Recovery Command Response (toggle test). o Firmware Airport Proximity Detection. 29

### o Ensure props are smooth and free of damage 

## I defect (check blade, surface and hub). o Ensure prop adapters are tight

## I secure. o Ensure voltage alarm is connected. o Ensure arming

## I idle timeout is properlyconfigured. o Ensure correct model is selected in transmitter (ifapplicable). o Check RC transmitterforthe correct range and centeringfor all sticks. o Perform range test. 

### IN-FLIGHT CHECKLIST: o Basics: Ifflying manually, always keep yourfingers on the controller/transmitter. o Never letthe UAV outofyoursight even for a second. o Climb to a safe altitude away from potential hazards and to reduce noise pollution. o Keep aircraft at a safe operating distance from people, electric utility lines and buildings. o If the UAV must be flown over buildings or people, use a lightweight UAV and maintain a safe altitude for recovery and make every effort to minimize exposure. o Spotter: Use a spotterwhenever possible and appropriate, especially when flying by First Person View (FPV). o Do not fly UAVs within distance defined by local laws of any private/commercial airport/helipad. o Do notfly around a pre-existing UAVflying site without afrequency management agreement. o Do not interfere with operations and traffic patterns atany airport. 

### LANDING CHECKLIST: o Regardless ofwhether ofa manual orautomated UAV landing, scan landing area for potential obstruction hazards. o Announce out loud {(Preparing to Land".

30

### o Use a safe descent rate and follow correct procedures to avoid avortex state or settling. 

### o Carefully land the aircraft awayfrom obstructions and people. 

### o Turn the power offtothe aircraft and/ordisconnectthe batteries. D 

### Turn offthe transmitter. 

### o Turn the power offtothe photo equipment. 

### o Visually check aircraftforsigns ofdamage and/orexcessive wear. o Remove the unused fuel ifapplicable. Secure the aircraft. o Check pictures: Verifythatthe UAV camera actuallytookthe pictures. 

### o LOG FLIGHT. *FOR NORMAL OPERATIONS USE MODEL SPECIFIC CHECKLISTS.

31

# Appendix B MaintenanceLogbook

32

### MAINTENANCE LOGBOOK Date Component Maintenance Maintenance Comments Activity Time

33

# AppendixC Incident/ AccidentLogbook

34

### INCIDENT/ ACCIDENT LOGBOOK Date of Time of NameofInjured Incident/ Accident ActionTaken Notes Incident/ Incident/ Details Accident Accident

35

# Appendix

# D

-- ---·-----·-----·--·-- 

# FlightRecordLogbook

36

### FLIGHT RECORD LOGBOOK (Sample Page) Date Location Activity FlyingTime Battery Battery Comments Before After

37

# AppendixE Phantom 3UserManual

38

## Using this manual LegE1nds 

## 0 Warning 

### it, Important**t>~** Hints and Tips 

## liGJ Reference**,~E1ad** 

### Before the rirst rlignt Read the following documents before using the Phantom 3 Professional: 1. In the Box 2. Phantom 3 Professional UserManual 3. Phantom 3 Professional QuickStartGuide 4. Phantom 3 ProfessionalIAdvancedSafetyGuidelinesandDisclaimer 5. Phantom 3 ProfessionalIAdvancedIntelligentFlightBatterySafetyGuidelines We recommend that you watch all tutorial videos on the official DJI website and read the Disclaimer before you fly. Prepare for your firstflight by reviewing the Phantom 3 Professional Quick Start Guide and refer to the User Manual for more detailed information.

### Vid~o 

### Tutofials Please watch the tutorial videos atthe link below, which demonstrates howto use Phantom 3 Professional safely: http://www.dji.com/product/phantom-3/video 

### CQ,ownload

### tne DJI 

### Pilot·app Download and install the OJ! Pilot app before using the aircraft. Scan the OR codeto the right to download the latestversion.**~:-:ili~** TheAndroid version ofthe DJJ Pilot app is compatible with Android 4.1 .2or later.

### ~ The iOS version of the DJI Pilot app is compatible with iOS 8.0 or later. 

### fi'l• 1.:.1i:-1.

-•

2