Page | 1

Augus t 7, 2015

Docke t O perations, M- 3 0 U.S. Departme nt of T ransportation ( DOT) Docket M an agement S ystem 1200 Ne w J erse y A ve., SE R oom W 12-140, Wes t B uildi ng G r ound Floor Washington, D C 20590- 0001

Dear S ir or M adam:
Attached please find Aerial Photo Shop, Inc. ( Aerial Photo Shop) request , as a member of the Professional Aerial Photographers Association, International (PAPA) , for an exemption from the list ed Federal Aviat ion Regulations to allow co mmercial operation of its Small U nmanned Air craft Systems ("sUAS ") f o r aerial imaging to include video and still photography. This exemption requ est is in itially fo r the use of the Inspire 1 sUAS manufactured by DJI , an established sUAS company an d in accordance with the sUAS training and certification program as administered by PAPA

.
Also attached to this letter is the equipment “ Aerial Photo Shop Flight Manual ” (Manual) , which

o u tlines the operating requirements, limit ations, and technical specifications for the DJI System as used by Aerial Photo Shop. Aerial Photo Shop has reviewed this Manual and has found it to b e acceptable for sUAS o p erations . 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 th e pu blic and are protected from release under the F reedom of Information Act 5 USC 552 et. seq.

Tha nk you f

or y our t im e and consideration, and pleas e l e t m e know i f y ou ha ve a n y qu estions.

Sincerely,

David D. Price Aeria l P hoto Shop Corporate Officer

P rofessional A erial Ph otographers Association -Internation al S ectio n 333 Do c 15- 011Page | 2

Au g u st 7, 2015

Docke t O perations, M- 3 0 U.S. Departme nt of T ransportation ( DOT) Do cket M anagement S ystem 1200 Ne w J erse y A ve., SE R oom W 12-140, Wes t B uildi ng G r ound Floor Washington, D C 20590- 0001

Re : E xempti on Reques t S ection 333 of t he F A A Refor m A c t a nd Par t 11 of t he F edera l A viation Regulati ons f

r om 14 CF R 61.113 (a ) & ( b) ; 91.1 03(b) ; 91.119; 91.121; 9.151( a) ; 91.405 (a ) ( 1); 91.409 (a ) ( 2) ; 91.417 (a ) & ( b).

Dear S ir or M adam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Aerial Photo Shop I n c. ( Aerial Photo Shop) , an aerial photography and d igital imaging company , on behalf of itself and its related affiliates under common ownership and control, hereby applies for an exemption from the listed Federal Aviation Regulati ons ("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 and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

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 Aerial Photo Shop during aerial photography operations in accordance with the training and certification provided by the Professional Aerial Photogr aphers Asso ciation, International (PAPA)

. Aerial Photo Shop is a member of the Professional Aerial Photographers Association-International (PAPA) and has a demonstrated record of safe operations in the National Airspace System (NAS) . Prin cipal employ ees have logged well over 25 hours of sUAS flight operations. The Pilot /s In Command (PIC) proposed by Aerial Photo Shop is a FAA licensed pilot with years of safe and successful aerial photography operations. Approval of this exemption would thereby enhance safety and f u lfill the Secretary of Transp o r tation's (the FAA Ad ministrator's) responsibilities to "...establish requirements for the safe operation of such aircraft systems in the Na tional Ai rspace Sy stem." Section 333(c) of the Reform Act.

P rofessional A erial Ph otographers Association -Internation al S ectio n 333 Do c 15- 011Page | 3

Professional Aerial Photographers Association -International Section 333 Doc 15-011 The name and address of the applicant is:

A erial Photo Shop , Inc. 42160 Parado Del Sol Dr. Temecula, Ca 92592 PIC -David D. Price, FAA Licensed Pilot ( Commer cial Rotorcraft, Private Pilot ) PH: 760-807-1254 Email: david@aerialphotoshop.com

R egulations from which the exemption is requested:

14 C .F.R. Part 21 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.F.R. 417 (a) & (b)

I . STATUTORY AUTHORITY FOR EXEMPTIONS

T he Federal Aviation Act expressly grants the FAA authority to 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.

T he Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).

S ection 333(b) of the Reform Act assists the Secretary in determining whether sUAS may operate in the National Airspace System (NAS) without creating a hazard to the user, the pub lic, or a threat to national security. In making this determination, the Secretary must consider:

• T he sUAS's size, weight, speed, and operational capability;

• Whether the sUAS operates within the visual line of sight of the operatorPage | 4

• Whe ther the sUAS operates outside of highly populated areas and away from close proximity to airports
Reform Act §333(a). If the Secretary determines that a sUAS "may operate safely in the national ai rspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id. §333(c)

Aerial Photo Shop' sUAS are multirotor vehicles, weighing 20 or fewer lbs. including payload. They operate under normal conditions at a speed of no more than 70 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. The sUAS will operate only in the Pilot's visual line of sight at all times and will operate only within the controlled “A r ea of Operations” de scribed in the Confidential Aerial Photo Shop Flight Manual (Manual) , attached as Exhibit 1 (hereinafter "Manual"). S uch operations will ensure that the sUAS will "not c reate a hazard to users of the N ationa l Airspace S ystem or the public." Reform Act Section 333 (b).

Given the small size of the sUAS involved and the restricted and c ontrolled environment within which they will operate, our application falls squarely within the zone of safety (an equivalent l evel 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 of the sUAS, altitudes , and controlled areas in which the sUAS will operate, approval of the application presents no national security issue.
Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant of the

r equested exemptions is in the public interest. Accordingly , Aerial Photo Shop respectful ly requests that the FAA grant the requested exemption without delay.

II. PUBLIC I NTEREST
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 of the rulemaking required under Section 33 3 of the Reform Act. By granting

an exemption the FAA will fulfill Congress's intent of allowing UAS to operate with significant safety precautions in low risk environments.
The use of sUAS on aerial photography operations can significantly reduce the risk to phot ographers and participants. sUAS can inspect, photograph, and collect data on hard to get to areas that otherwise would require direct access or manned aircraft

. Additionally, sUAS could replace the use of helicopters and small aircraft to produce imagery f or various purposes. The sUAS we propose to fly in this application are less than 20 pounds,

a nd carry no combustible material on board, as opposed to the much larger conventionally

P rofessional A erial P h otographers Association -International S ection 333 Doc 15- 011Page | 5

Professional Aerial Photographers Association -International Section 333 Doc 15-011 powered small aircraft. S hifting to sUAS from manned aircraft presents a marked safety increase for our workers and the public.

Last ly, sUAS reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection. The sUAS used by Aerial Photo Shop use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times heavier.

III . EQUIVALENT LEVEL OF SAFETY AND SECURITY

Aer ial Photo Shop proposes that the exemption requested herein apply to sUAS that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe protocols followed on imaging and photography operations conduct ed with conventional aircraft.

Aer ial Photo Shop will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption:

1. The s UAS w ill be le ss th an 20 pounds. 2. Flights w ill be o perated within v isual line o f s ight of a p ilot. 3. Max imu m total flight time f or e ach o perational flight will be 20 minutes. The o perator calculates b attery r eserv e , and will return t h e sUAS to the "D esignated Sa fet y Zone" with a t least 20% battery power reserve should that occur prior to the 20 min ute limit. 4. Flights w ill normally b e operated at an a ltitude o f not more than 400 f eet AGL , but never in controlled airspace without prior coordination and approval of ATC. 5. Flights will not be conducted within the surface area of controlled a irport airspace without prior coordination and approval of ATC. 6. Flights w ill not b e conducted within 5 miles of any uncontrolled airport without prior coordination and approval of the airport authority. 7. Crew for each operation will consist of the sUAS Op erator who will keep the sUAS within his vis u al line o f

s ight a t all times a nd a q ua lified O bserver. 8. Th e s UAS operator will be trained in flight, operations, and safety procedures as detailed in th e F light Manual. 9. The sUAS will only operate within a confined "A r ea of Operations" as d efined i n t he Manual , including but not limited to evaluation of the airspace by reference to a current 1:500,000 scale FAA S ectional A eronautical Chart . T he Manual al so r equires t he establishment o f a "D esig nated S afety Zone" f or t he flight o perations ar ea. 10. A br iefing w ill be conducted r egarding the planned sUAS operations prior to each day's p r o duction a ctivities. I t will be ma ndatory th at all personnel who w ill be p erforming d uties within the boundaries of the Designated Safety Zone be present for this briefing. 11. All onsite p e rsonnel will consent to the UAS flyover on site by waiver, and the Op erator w ill obtain additional verbal or written consent of all persons who will be allowed within 100 feet of the flight operation.Page | 6

Professional Aerial Photographers Association -International Section 333 Doc 15-011 12. Operator will have been trained in operation of UAS gen erally and will have received up

- to

date information on the particular s UAS to be operated as required by the Aerial Photo Shop Manual. 13. Necessary w ritten and/or oral permission from the relevant property holders will be obtained. 14. All required permissions a nd permits will be obtained from territorial, state, country, or city juri sdi ctions, including local law enforcement, fire, or other appropriate government agencies. 15. If the sUAS loses communications or loses its GPS signal, it will have the capability to e nter "loiter mode" and hover, reestablish satellite connection, and return to a predetermined location within the "Designated Safety Zone" and land. 16. Aerial Photo Shop 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 a weatherproof container on the persons back.

I V. DESCRIPTION OF SPECIFIC REGULATIONS

14 C FR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

S ections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passenge rs, the proposed operations can achieve the equivalent level of safety of current operations by requiring the O perator operating the aircraft to have completed a sUAS flight training course of 25 hours before flying a sUAS (See the Aerial Photo Shop Manual for details) or meeting any FAA pilot licensing requirement

. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The area of operation is controlled and restr icted per prior planning and necessary coordination with the local FSDO if applicable, and all flights are planned and coordinated in advance as set forth in the Aerial Photo Shop Manual.

T he sUAS to be operated hereunder is less than 2 0 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and opera tes exclusively within a controlled A rea of O peration as set out in the Aerial Photo Shop Manual. Like other civil aircraft, operations under this exemption will be tightly c ontrolled and monitored by the O perator, pursuant to the Aerial Photo Shop Manual requirements, and under the requirements and in compliance with local public safety requirements, to provide security for t he Area of O peration as is currently done on aerial photography operations . The FAA will have advance notice of all operations as required

.
T he risks associated with the operation of the sUAS are therefore diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, and allowing operations of the sUAS as requested , with an operator who has met the minimum requirements stated in the Aerial Photo Shop Manual , achieves the level of safety contemplated by 14 C.F.R. §61.113 (a) & (b).Page | 7

Professional Aerial Photographers Association -International Section 333 Doc 15-011 14 C.F.R. 91.103: Preflight Action

T his regulation requires that each O perator in Command take certain actions before flight to ensure the safety of flight. 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 Checklist in the Aerial Photo Shop Manual. These actions will provide an equivalent level of safety.

14 C .F. R. 91.119: Minimum/ Maximum Safe Altitudes

S ection 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which will typically operate at altitudes of less than 400 AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude s higher than the base of controlled airspace without prior approval and coordination with ATC and will be in

a Controlled A rea with a "Designated Safety Zone" , where buildings and people will not be exposed to operations without the specified pre

- obtained consent. ( See Aerial Photo Shop Manual for detailed procedures.)

T he equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. No flight will be taken without the required permission of the property owner or local officials. Because of the advance notice to the property owner and any onsite personnel , as outlined in the Aerial Photo Shop 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 2 0 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 of conventional aircraft that must comply with Section 91.119.

14 C .F.R. 91.121: Altimeter Settings

T his regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available befor e departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Aerial Photo Shop Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C FR 91.151 (a): Fuel requirements for flight in VFR conditions

S ection 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 Aerial Photo ShopPage | 8

Professional Aerial Photographers Association -International Section 333 Doc 15-011 Manual, and has a limited range and flight time which require an exemption from 14 CFR 91.151 (a)

T he battery powering the sUAS provides approximately 20 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would necessarily be impossible to conduct. Given the limitations on the sUAS's proposed flight area and the location of it s proposed operations within a predetermined area, a shorter time frame (less than 30 minutes) for flight in daylight or night VFR conditions is reasonable.

A erial Photo Shop believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS, in a controlled area where only people and property o wners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS.

A n equivalent level of safety can be achieved by limiting flights to 2 0 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 20% of battery 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 in its limited operating area.

S imilar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C FR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections

T hese regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in the subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...," and others shall inspect or maintain the aircraft in compliance with Part 43.

G iven that these se ctions and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Aerial Photo Shop. Maintenance will be accomplished by the operator and pursuant to the flight manual and operating handbook as referenced in the Aerial Photo Shop Manual. An equivalent level of safety 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 of time. If mechanical issues arise , the sUAS can land immediately even if operating a t a maximum of 1200 feet AGL . As provided in the Aerial Photo Shop 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.

P ursuant to C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:Page | 9

Professional Aerial Photographers Association -International Section 333 Doc 15-011 A pplicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7
(a ); 9 1.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in aerial photography operations.

A pproval of ex emptions 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 2 0 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

T he operation of small sUAS, weighing less than 2 0 lbs., conducted in the strict co nditions outlined above, will provide an equivalent level of safety supporting the grant of the 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.

P rivacy

A ll Flights will occur over private or public 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 agreed to be in the area where aerial photography will take place.

S atis faction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate j ustification for the grant of the requested exemptions allowing commercial operation of applicant's sU AS in the aerial photography industry pursuant to the Manual appended hereto.

S incerely,

D avid D. Price Aerial Photo Shop , Inc. Corporate Officers

# s UAS Operations Manual

Aerial Photo Shop , Inc.

7 August 2015

This manual contains standard operating procedures and guidelines for UAS operations.2 

## Aerial Photo Shop , Inc.

s UAS Operations Manual

**Table of Contents**
P urpose , Scope, and Mission Statement

............................................................. 5
Definitions

.......................................................................................................... 6 Personnel Responsibilities

.................................................................................. 8
Visual Observer

.................................................................................................... 8
PIC

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

..................................................................................... 8 Qualification Requirements

................................................................................. 8 Operating Limitations and Conditions

................................................................ . 9
Maintenance Procedures

.................................................................................. 10
Routine Maintenance

........................................................................................ 10 Full Flight T est

.................................................................................................... 11 Software Firmware Update Policy

...................................................................... 11 Logs and Records

.............................................................................................. 12
Pilot and Aircraft Hours

...................................................................................... 12 Battery Logbook

................................................................................................ . 12 Flight Planning

.................................................................................................. 13
Weather

............................................................................................................. 13
Site Permissions

................................................................................................ . 13
Pre

- Flight Inspections and Checks

...................................................................... 13
Documentation

.................................................................................................. 14
Pre

- Flight Area and Personnel Checks

................................................................ 143 Clo sed Set Operations

........................................................................................ 15
On

- Site Procedures

............................................................................................ 16 Site Survey

.................................................................................................. 16 Selection of Operating Areas and Alternatives

............................................ 16
Boundaries

.................................................................................................. 17
Anemometer Weather Check

..................................................................... 18 Crew Briefing

.............................................................................................. 18
Communications

......................................................................................... 19 Frequency Scans

......................................................................................... 19 Recharging and Battery Use (Fuel Management)

........................................ 19
Load

- outs and Equipment

........................................................................... 19 Flight Procedures

.............................................................................................. 21
Motor Start

........................................................................................................ 21
Take-O ff

............................................................................................................. 21
In

- Flight

.............................................................................................................. 22
Let Do wn/Landing

.............................................................................................. 23
Shutdown

.......................................................................................................... 23 Emergency Procedures

...................................................................................... 24
Motor Thrust Loss

.............................................................................................. 24 Battery Failure

................................................................................................... 24 Battery Failure Failsafe

............................................................................... 25 Transmitter/Controller Battery Failur e

....................................................... 26 Controller Battery Failsafe

.......................................................................... 26 Loss of Control Frequency

.................................................................................. 26
Loss of Frequent Failsafe

.................................................................................... 26 Malicious or Accidental Interference with Control Frequency

........................... 274 Pi lot Incapacitation

..................................................................................... 27
Aircraft Incursion

........................................................................................ 27 Fly Away Procedure

.......................................................................................... 28 Crash & Incident Response

................................................................................ 28 Appendix A - Checklists

..................................................................................... 29
Pre

- Flight Start

- Up Checklist

.............................................................................. 30
Pre

- Flight Inspection Checklist

........................................................................... 32
In

- Flight

.............................................................................................................. 33 Landing Checklist

............................................................................................... 34 Appendix B

....................................................................................................... 35 Maintenance Logbook

....................................................................................... 36 Appendix C

....................................................................................................... 37 Incident/Accident Logbook

................................................................................ 38 Appendix D

....................................................................................................... 39 Flight Record Logbook

....................................................................................... 40 Appendix E

........................................................................................................ 41 Inspire1 User M anual

.................................................................................... 415 

## PURPOSE, SCOPE, AND MISSION STATEMENT
Aerial Photo Shop , Inc. (Aerial Photo Shop), 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 Pilots In Command (PIC) that will operate systems according to the approach outlined in this Manual of Procedures (Manua l) are trained in accordance with this Manual and FAA regulations and have decades of successful experience on Ae rial Photographic flight missions.

T he intent of the Manual is to provide the outline of a system to conduct safe and successful sUAS operations in accordance with the applicable FAA regulations and consistent with the section 333 waiver that this M anual 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 operatio nal procedures is intended to promote the highest levels of professionalism in safe aerial photographic flight missions.6 

## 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.

A r ea of Operations - Defined as the area where sUAS operations will be carried out for a specific flight or series of flights on a given mission.

C hecklists - Procedural checklists used by the PIC to verify proper and safe procedures during all phases of s UAS operations.

De signated Safety Zone - Defined and marked area of ground operations used for safe take offs and landings of the sUAS at a given Area of Operations.

F light Control Systems - The combination of telemetry, PIC operated controls, and onboard control mechanisms that are employed to control the flight of the sUAS.

Fr equency Analyzer - A device used to scan the Area of Operations for possible interference from radio waves.

G PS - Global Positioning System.

H andheld Radio - A radio transceiver capable of communication with other Pilots or FAA personnel in the Area of Operations.

L oiter Mode - A default recovery mode the sUAS goes into when communications are lost from the PIC.

M aintenance Recommendations - Periodic maintenance recommendations for each of the sUAS components that have a usable life.7 M anual - This flight manual that combines the Operator specific procedures with the sUAS manufacturers’ manual.

M anufacturers Recommendations - Written recommendations provided by the manufacturer s of the various components of the sUAS.

NA S - National Airspace System.

N on Participants - Persons who have not agreed to participate in sUAS operations.

O perator - The entity submitting as the applicant on this waiver request to the FAA who will be re sponsible for all sUAS operations and procedures.

PA PA - Professional Aerial Photographers Association, International.

P articipants - Persons who have agreed to participate in sUAS operations.

P ilot In Command - Person who will fly the UA during sUAS operations and who is responsible for all safety related or operational decisions under the direction of the Operator in accordance with this Manual and FAA requirements

.

SO P - Standard O perating P rocedures.

s UAS - Small Unmanned Aerial Systems as contemplated under the FAA guidelines, not to exceed 55 pounds in weight or 100 miles per hour in speed.

Tel emetry - Electronically transmitted data that provides control and information transmissions to and from the PIC and the sUAS.

UA – Unmanned Aircraft.

Vi sual Observer - An individual who is designated to observe flight operations and to maintain visual contact with the UA during flight operations while maintaining communications and coordination with the PIC.8 

## PERSONNEL RESPONSIBILITIES

VISUAL OBSERVER A ll operations will utilize a Visual Observer. The main responsibilities of the Visual Observer will be to ensure that the UA is operated within the visual line of sight of both the PIC and Visual Observer at all times. The Visual Observer will maintain

v erbal 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 Pi lot in Command is responsible for the safe operation of the sUA S at all times in accordance with this Manual and the applicable FAA regulations.

Pi lot in Command will be responsible for:

• All support personnel.

• Performing all pre

- flight, flight phase, and post flight inspections, air worthiness, diagnostics , and tes ting.

• Manufacturer recommended maintenance operations.

• Weather condition assessments and forecast reviews.

FLIGHT T EAM COMPOSITION The o nsite f light t eam is co mposed of a Pi lot i n Comman d (PIC) and a Visual Observer ( V O). The PI C i s r esponsible f or a ll f light o perations and de cisions t o proceed. The V O is responsible to ma intai n visual contact wit h the UA a nd to provide co nstant co mmunication with t he P IC r egarding a ircraft s tatus a nd surrounding co nditions w ithin the A rea o f Ope rations.

QUALIFICATION R EQUIREMENTS The PI C mus t be a n FAA -l icense d pi lot w ith at l east 2 5 h ours of sUAS fl ight t ime. The V O mus t demonstrate e xperience with FAA pr ocedures a nd the

s tandard procedures o f

t his M anual.9 

## OPERATING LIMITATIONS AND CONDITIONS

Operational Ceiling - Maximum 1,200 ft AGL, typical 400 ft AGL.

O perational Endurance - 15 minutes.

M aximum Speed - 100 MPH

M aximum Operating Temperature - 110 degr ees F

M inimum Operating Temperature - 0 degrees F

M aximum Operational Wind Speed - 15 MPH (gusts to 20 MPH)10 

## MAINTENANCE PROCEDURES

Onl y Aerial Photo Shop personnel or an appointed service technician may carry out maintenance on t he sUAS aircraft systems described in this operations manual. In all cases a Maintenance Logbook (see Appendix B ) is completed to reflect a ny work undertaken and a flight test, testing all functions (including the return

- to

- home failsafe facility), is subsequently carried out by the PIC

.

R OUTINE MAINTENANCE The Pre

- Flight and Post

- Flight checklists shown in Appendix A are completed by the PIC every time a n Aerial Photo Shop sUAS aircraft is operated. Every six months (or fifty hours of flight time – whic hever 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 a full flight

- test before the aircraft is returned to Operational Status:

• Inspection of the airframe for any damage, unusual marks and tightness of fixings;

• Inspection of the motor mountings for correct tension;

• Inspection of the propellers for condition, unusual marks, chips, cracks and tightness of fasteners;

• Inspection of electrical wiring for condition, unusual marks or discoloration;

• Inspection of electrical terminal fittings and plugs for secure attachment and general condition;

• Inspection of the attachment of all fittings such as flight co ntroller, GPS antennas etc. for secure attachment;

• Inspection of payload attachment points for condition and security of payload;

• Inspection of the condition and function of all ancillary equipment such as transmitter etc.

• Testing of all system battery pac ks for charge status and general condition.

If

any 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, faulty battery packs etc.) are identified and r emedied, 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 an11 unserviceable motor, damaged airframe etc.) , then the a ircraft u ndergoes a full flight test regime (as described below), once the identified fault has been remedied.

F ULL FLIGHT TEST The system has all functions tested with a minimum of five minutes flight time by a qualified PIC recording any abnormalities in the Flight Record Logbook (Appendix D). If the PIC deems the aircraft to 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 Aerial Photo Sho p until any problems are rectified.

S OFTWARE 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 s UAS 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 a ll circumstances the upgrade is performed by qualified Aerial Photo Shop per sonnel or appointed service providers. All upgrade information such as version numbers and new functions are recorded in the Maintenance Logbook. All Aerial Photo Shop PIC are made aware that the firmware or software has been upgraded before any flight o perations are undertaken.

A ny upgraded system has all functions thoroughly tested with a minimum of five minutes flight time by a qualified Aerial Photo Shop PIC who records any abnormalities in the Flight Record Logbook. If the 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 rela ting to firmware or software are grounded until the problem can be rectified.12 

## LOGS AND RECORDS

P ILOT AND AIRCRAFT HOURS Aerial Photo Shop PIC are required to keep a log of pilot and aircraft hours. To meet this requirement, Aerial Photo Shop holds and updates a spreadsheet

based Personal Flying Log Book for Aircraft Operating Crew. This log book is a separate document which can be viewed on request (see sample page at Appendix D).

B ATTERY LOGBOOK Aerial Photo Shop 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 – Aerial Photo Shop Incident Logbook (Appendix C ) and Maintenance Logbook (Appendix B ).13 

## FLIGHT PLANNING

W EATHER Opera tor 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 operating Automatic Terminal Information Service (ATIS), the ATIS broadcast system will be consult ed

. If ATIS is not available, PIC will consult

- alternative sources for a current weather forecast.

T he operating envelope for the Inspire 1 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 for safe operation.

S ITE PERMISSIONS

• Secure permissions from property owner if required.

• Secure permissions from participants.

• Coordinate with local law enforcement if required.

• Prior to operations, Operator receives permission for take

- off and landin g f rom the relevant land

- owner. In most cases permission attainment is

un problematic 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.

PR E

- FLIGHT INSPECTIONS AND CHECKS Prior to each flight, the PIC will conduct a pre

- flight inspection and determine if the s UAS is in a condition for safe flight, and to account for all possi ble discrepancies or inoperable equipment. If the inspection reveals any condition that will affect the safe operation of the s UAS, the aircraft will be prohibited from operating until the necessary maintenance can be performed and the s UAS can be returne d to safe flight. The preflight inspections will include the following components according to the recommended checklists in the DJI Inspire 1 operator manual, and in the Aerial Photo Shop checklist:14  Airframe  Battery  Transmitters  Camera and Gimbal  Propul sion system including propellers

In a ddition, with the battery attached and turned on in the s UAS, the PIC will oversee and monitor the series of diagnostic tests to determine and verify proper voltage levels, control function, communication, and GPS sate llite connectivity acquisition. PIC will utilize the DJI Inspire 1 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 s UAS is flown from a new location.

D OCUMENTATION PIC will ensure that all documents used by Aerial Photo Shop to ensure safe flight operations and any document required under 14 CFR 91.9 and 91.203 must be available at the Ground Control Station on s ite at any time the sUAS 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 of the vest ).

PR E

- FLIGHT AREA AND PERSONNEL CHECKS

• Survey flight operations area for safety concerns and to verify conditions.

• Examine all components of the s UAS to ve rify proper function i n
a ccordance with the applicable manuals and manufacturer’s instructions.

• Verify notification to all personnel on site.

• Establish Designated Safety Zone and verify safe clearances.

• PIC should wear the specified safety vest

.

• The ultim ate responsibility for aircraft airworthiness and operational safety rests with the SUAS pilot

- in

- command. For this, the PIC – as an aid – uses a Pre

- Flight Checklist (see Appendix A ). In summary, the Pre

- Flight Checklis t p rompts examination of the followi ng:  The airframe (for condition and lack of damage);  The battery (for level

- of

- charge and security of attachment);  The transmitter (for level

- of

- charge and to check that switches15 are in the ‘home’ position);  The camera (secured, on and operating).  Propulsi on system

• In a ddition, when the flight battery is connected to the s UA S , the fligh t
c ontroller undertakes a series of diagnostic tests (while simultaneously locating the position of GPS satellites).

C LOSED SET OPERATIONS If this exemption permits operati ons 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 M anual (MPTOM) as documented in this grant of exemption.

• At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Fligh t S tandards District Office (FSDO) with jurisdiction over the area of propose d f ilming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

o Dates and times for all flights;

o Name and phone number of the operator for the s UAS aerial filming conducted under this grant of e xemption;

o Name and phone number of the person responsible for the on

scene operation of the s UAS;

o Make, model, and serial or N

- Number of s UAS to be used;

o Name and certificate number of s UAS PI Cs involved in the aerial filming;

o A statement that the operator has obtained permission fro m pr operty owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

o Signature of exemption holder or representative; and

o A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

• Flight operations may be conducted closer than 500 feet from participating16 persons consenting to be involved and necessary for the filming production, as specified in the exemption holder's MPTOM.

ON

- SITE PROCEDURES The on

- site procedures undertaken by Aerial Photo Shop are conducted in accordance with and controlled through an extensive use of checklists. For this reason, the following sections repeatedly refer to various checklists found in Appendix A of this Manual.

• Si te Survey - In advance of operations, a survey is undertaken to review the site, its t errain, structures and surroundings – to check any assumptions made about the location prior to arrival and to adjust the operations pla n
a ccordingly. For this, an On

- Site Survey Checklist is used (see Appendix A , pa ge 25). The primary purpose of the site survey is to make a visual check of the operating area with the objective of identifying any potential hazards.

• S election of Operating Areas and Alternatives - In advance of the pre

- flight 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 upo n by virtue of written letter of agreement with the airport’s management, or otherwise permitted by the COA issued to Aerial Photo Shop

o Ability of PIC and VO to operate the s UAS clear of, and give way to , all manned aviation operations and activities at al l times.

o 500 ft. clearance of all non

- participating persons, vessels,

v ehicles, and structures unless; A. sufficiently protected in the event of an accident, and the nonparticipating persons remai n p rotected at all times during operations of the s UAS, and B. The owners and controllers of any vessels, vehicles, or structures has granted permission for the operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it17 does not present an undue hazard.

o Ability of Aerial Photo Shop to conduct operati ons over private or controlled access property with permission from the owner/controller or representative of such, and sai d p ermissions are granted.

o Proximity to radio interferences

o Prevailing weather conditions have been adequately assessed, including; high winds, convection, visibility, minimum clo ud cl earance (500 ft below, and 2,000 ft horizontal clearance), or when visibility is less than 3 miles from the PIC.

T he primary site f or 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.

• B oundaries - Aerial Photo Shop requires that proper identifiers an d 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 inclu de :
o Take- off and Landing safety Area: PIC will determine the safe distances of all people from the take

- off and landing operatio n
o f the UAS. The PIC will also establish a cordoned area wit h

c learly marked delineation the take

- off and landing operations.

o Signage and Identifying Clothing: The PIC will place signage at each entry point within the operations area a lerting people to the following: A. Low altitude aerial work is being conducted B. Use of any actual sensing equipment being use d C. A request asking people to not enter the area withou t f irst notifying the PIC or Aerial Photo Shop designate d

on

- s ite flight operations personnel D. PIC and VO will put on outerwear that will identify them in their respective roles. Signage will be attached on their person that will instruct law

- enforcement, observers, or any other people present that they are no t to be interrupted un

- necessarily while conducting flight18 operations.

• Anem ometer Weather Check - Beyond pre

- site planning weather forecast checks, Aerial Photo Shop req uires that the PIC conduct specific on

- si te
w eather checks. The PIC will utilize a hand

- held or portable Anemometer to determine wind speed, direction, temperature, and humidity. Aerial operations will only be conducted within the specific recommended wi nd

a nd humidity limitations of the s UAS manufacturer’s operating manuals, or if not identified therein, only in conditions where wind speed is less tha n 1 5mph, gusting up to 20mph.

• Cr ew Briefing - Aerial Photo Shop flight operations personnel will typical ly 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 prior to the start of operat ions

. The briefing will include:

o Introduction to the equipment being used including the s UAS and the ground station functions, with particular emphasis o n
mo ving parts including weight of the s UAS, and the harm or damage that could possibly be inflicted by coming into contact with those components (particularly the propellers, and hot surfaces)

o Familiarization with the failsafe return

- to

- home systems a nd i nstruction on how to activate those systems if the PIC is unable to activate those systems

o Expected flight plan, holding positions, flight duration, an d

o verall flight boundarie s.
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 into the airspace and ground boundaries

o Importance of mitigating any possible distractions or un

necessary communication with the PIC during operations

o Careful review of Lost Link and emergency pr ocedures

• Communications - Aerial Photo Shop uses channel

- hopping technology o n19 2.4GHz to maintain communications with the SUAS for the purposes of platform control. There is no communication (‘downlink’) from the SUAS to the ground station. In the event of loss of or interference with the control frequency, the SUAS 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 S cans - Aerial P h oto Shop when able will pe rform frequency

s cans t o he lp identify po ssible c onflict w ith radio communications. This w ill be performed via a ha nd -h eld or po rtable r adio s pectrum
scanner by t he P IC. These s cans w ill i nclude a f ull s pectru m scan of t he

a pplicable f req uency range of th e sU AS. Possible sources of r adio i nterference o r c onflict w ill be identified a nd ev aluated to d etermine if f light operations c an b e safely continued.

• Recharging an d B attery U se ( Fu e l Ma nagement) - The D JI Inspire 1 utilizes

a 4500 mAh 22.2 V “intelligent” b attery. Batteries a re charged at base p rior to f light operations. The number o f b atteries th at will b e transported to the f light o perations a rea w ill be ba sed on the s pecifi c needs o f t he f light operations o r mi ssion. The batter y c apacity w ill b e tested utilizing th e internal p roprietary t ester o n th e battery, and w ill a lso b e checked u tilizing the proprietary D JI s oftware, as well a s a ny i nternally s ensed tel emetry software a nd hardware a ttached to t he sU AS. A b attery c harge lo g w ill b e kept via th e p roprietary D JI Inspire 1 software a nd will be co mplete d prior to ev ery f light. Any battery f ound to b e less th an f ully -c harged, da maged, displays i nsufficient voltage, or o therwis e defective will n ot be used.

• Load -o uts an d E quipme nt - The Inspire 1 is a s imple qua d -c opter U AS wi th limited capability f or loads a nd equipment. Removable e quipment i ncludes the battery, gimbal, c amera, telemetry h ardware, antenna , and i maging transmitter. Th e battery i s h eld i n p lace v ia p roprietary f ittings. The g imbal is a ttached v ia s crews i nto th e airframe. The camera i s a ttached to th e gimbal us ing s crews a nd a pr oprietary ha rness. All o ther equipment i s attached u sing nylon f ittings, Velcro, or a dhesives. Total ta keoff w eight with these components w ill no t e xceed t he ma ximum r ecommended t ake

off weight i dentified in the Inspire 1 Users/operators Manual of 2935 grams, w ith a t otal payload weight no t to e xceed 300 g rams. Payload20 security is tested prior to any operations both visually and by vi gorous tactile testing. All attachment points will be inspected and tested weekly.21 

## FLIGHT PROCEDURES

A erial Photo Shop will utilize checklists to direct the flight operations personnel in flight procedures. The following se ction will continually refer to the several checklists presented in the Appendix.

• M otor Start - All of the various preflight checks will have been performed prior to motor start 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, includ ing the 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 s UAS is placed in the proper takeoff po sition

. o LED flight mode indicator, and telemetry read

- out shows adequate GPS connectivity according to the DJI Inspire 1 User/operator s Man ual.

o LED flight mode indicators and telemetry read

- outs show the proper flight mode is selected DJI Inspire 1 User/op erators Manual.

o Camera is switched on

. o All flight operations personnel are in their proper position and at the ready

. o Start motors, and establish functional pre

- take

- off power setting

.

• T ake -Off - Once motors have been started, the PIC will verify that the pre

take

- off checklist has been completed. Once this has been verified, the PIC will follow the following take

- off procedure: 1. Apply power for a controlled ascent to a safe low

- level test altitud e
o ver the take

- off area, and then hold

. 2. After in hold, PIC performs check of all control stick response including rudder, aileron, elevator, and throttle to ensure proper22 response to commands

. 3. PIC confirms with VO that the flight operations area is free of obstructions or other manned or unmanned air traffic

. 4. PIC confirms with all flight operations personnel that they are ready to proceed with flight operations as planned

.

• In -F l ight - Aerial Photo Shop requires that the PIC is free to concentrate on positioning, scanning, and monitoring systems and the flight oper ation s
a rea 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 sec tion 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 the y are alerted to any manned or unmanned aircraft within 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 s UA S t o
en sure adequate voltage according to the DJI Inspire 1 User/operating Manual for safe return and landing

. o Monitor time since motors were started to ensure a minimum of 3 minutes of battery fuel is available for return and landing of s UA S.

o A safety margin of a minimum of 3 minutes of battery life is maintained at all times

. o Maintain visual contact with flight systems/mode and battery LED light indicators at all times

. o Maintain situational awareness of changes in weather, visibility, o r cl oud avoidance at all times

. o Maintain operati on speeds less than 100mph

. o Maintain visual contact with s UA S at all times

. o Ensure VO has visual contact with the s UA S in flight at all times. Establish a position hold until VO re

- establishes visual contact wit h th e s UA S if contact is lost.23 • Let -D own/La nding - To execute a safe recovery and landing of the s UA S , t he PIC will ensure that the following practices are followed :
o Establis h and guide the s UA S through a safe route to directly abov e t he cordoned take

- off and landing area.

o Maintain a safe descent rate and follows all procedures a nd tec hniques to avoid vortex state or settling with power

. o Verify that a minimum of 3 minutes of battery life is available , as mentioned above , to ensure a holding position if the landing area is not cleared.

o Verify that the landing area is clear of debris, obstacles, people, or hazards that would preclude a safe landing.

• S hutdown - Upon landing, the throttle is returned to the home position causi ng the rotors to stop spinning. Operations then proceed as follows: 1. The s UA S battery is switched off or disconnected. 2. The camera is stopped and is then switched off. 3. The s UA S is removed from the landing area and is checked for any abnormalities or damage. 4. The transmitter is switched off. 5. The s UA S battery is removed , tested, and then the battery is safely secured and stored.24 

## EMERGENCY PROCEDURES

T he emergency procedures described below address the following, safety

- critical question: In the event of a malfunction, failure or other in

- flight emergency, how is the s UAS going to safely land without creating a hazard to other airspace users or persons or property on the ground?

M OTOR THRUST LOSS As a quad copter, The Inspire 1 has no ‘rotor redundancy’. Loss of power to a motor on a quad copter will result in a crash. For this reason, Aerial Photo Shop takes specific preventative steps to ensure that loss of power to a motor will not

occur:

• Wiring integrity is checked visually prior to any flight operations.

• A pre

- flight battery check is undertaken to test the charge of the cells.

• Upon take

- off, the s UAS is lifted into a temporary, low

- altitude holding position and the throttle/ rudder and aileron/elevator control sticks ar e
mo ved to check that s UA S is responding as expected.

I f there is a loss of thrust to a motor, any residual control left available to the PIC will be used to guide the s UA S away from people and objects to avoid injury or damage to property and people. Every effort will be made to restrict the crash site to the safest possible position.

s UA S B ATT ERY F AILURE As has been addressed in above previous sections, Aerial Photo Shop has procedures and practices in place designed to prevent s UA S batter failure o r malfunction, and they include:

• The batteries are physically inspected and tested through all phases of pre

flight and post flight 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 Inspire 1 software charge track/log is checked to ensure the battery meets t he minimum safe requirements as specified by DJI in operating manual and firmware specs.

• Throughout all phases of flight, the battery voltage, percentage of charg e
r emaining, and time in operation is constantly monitored via the telemetry transmission to t he ground station to ensure there is the proper minimum voltage and time to return and land is achieved and maintained.25 • The PIC will immediately land the SUAS in the nearest possible landing area if telemetry indicates the minimum voltage, time in operatio n, or percentage of charge are not met.

B ATTERY FAILURE FAILSAFE As a preventative measure to keep the s UA S from a forced landing or crash due to battery failure, the DJI Inspire 1 flight controller has several levels of low voltage protections incorporat ed as specified in the attached User/ Operator's Manual, triggering an automated Failsafe Return to Home and Landing command as follows:

• The low battery capacity warning alerts users when the battery is close to depletion during flight. When it appears, users should promptly fly back and land to avoid accidental damage. The Inspire 1 has two levels of lo w ba ttery capacity warning. The first appears when the battery has less than 30% power and the second appears when it has less than 15% power

. The followi ng list details the battery power warnings:

o When battery power drops below 30% the LED indicator will blink red slowly.

o At lower than 15% , the LED indicator will blink red rapidly . T he Inspire 1 will also begin to descend and land automatically

. A fter it has landed, keep the throttle stick at its lowest point or execute the combination stick command ( CSC ) to shut off

m otors

. o There is a hidden third low battery threshold in addition to the 1st and 2nd level warnings. This uses 10.65V as its threshold. Both t his voltage threshold and the 2nd Level Low Battery Warning will trigger auto

- landing.

• Altitude can be maintained if necessary by pushing up on the T h rottle stick.

1 st Level Low Battery Capacity Warning
2 nd Level Low Battery Capacity Warning Not Stationary or Sensor Bias is too big
Errors & Aircraft cannot fly.* Compass data abnormal because of ferro

- magnetic interference or th e compass needs calibration.26 TRANSMITTER/CONTROLLER BATTERY FAILURE As has been mentioned previously, through the extensive use of checklist procedures, Aerial Photo Shop requires that the PIC ensure the DJI Inspire 1 controller (ground station) will be fully charged prior to any aerial operation. Any monitors being used to display telemetry will also be fully charged.

CO NTROLLER BATTERY FAILSAFE Aerial Photo Shop will use The DJI Inspire 1 flight control system that incorporates an automated failsafe system which commands the s UA S to return to home and land if there is a loss of frequency due to battery failure. The PIC will reference the below LED lighting system to monitor the controller charge;

Rem ote Controller Power LED Indicator Status Power L ED I di t Sound Remote Controller Status
None Normal

B-B- B...... Low voltage (at 4V

- 4.3V). Replace the batteries immediately

B

-- B

-- B...... Alert will sound after 15 minutes of inactivity. It will stop once you start using the remote controller.

L OSS OF CONTROL FREQUENCY (and/or Ground Station Failure) To help prevent a loss of control frequency, Aerial Photo Shop 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 s UA S well within the required minimum range of the DJI Inspire 1 controller/transmitter.

L OSS OF CONTROL FREQUENCY FAILSAFE If the control frequency signal is lost for more than 3 seconds ( s UAS out of range, ground station failure etc.) the DJI Inspire 1 Flight Controller has been programmed to switch the UAS into failsafe mode and it will ‘return to home’ (RTH) and also land:

• If the failsafe occurs while in GPS mode according to the parameters of the DJI Inspire 1 User/Operator Manual, the s UA S will return to the take

T he r e m o te con tr o ll e r wi l l p owe r o ff a u to m a t ic a ll y when b a tt e r y vo l t a g e d r o p s b e l ow 4V

. L a n d a n d
ch a n g e b a tt e r ie s a s s oo n a s p o s si b l e when th e l ow vo l ta g e a l e r t o cc u r s t o a vo id l o ss o f con tr o l d u r in g
fl ig h t.27 off and landing area and auto

- land.

• If the fail location occurs while in ATTI mode according to the parameters of the DJI Inspire 1 User/Operator Manual, the s UA S will auto

- land.

• The RTH failsafe mechanism works by the s UAS 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 of continuous green pulses).

The R TH f ailsafe f unction on the sU AS i s tes ted b y Aeria l Pho to Shop by s witching th e transmitter o ff

d uring a tes t flight session.

MALICIOUS O R ACCIDENTAL I NTERFERENCE W ITH CONTROL F REQUENCY As w as me ntioned in previous s ections, t hrough the extensive us e o f che cklists, Aerial P hoto Shop requires t hat when able t he P IC utilize a S pectrum Scanner t o
e nsure t here is no a ccidental o r malicious radio i nterference. In th e u nlikely

ev ent that th is should occur, t he P IC w ill i nitiate t he f ailsafe pr ocedure

me ntioned in t he pr evious section

• Pilo t Incapacitation - If the pilo t- in

- command becomes incapacitated to the extent that control of the s UA S becomes unviable, the s UA S will hover in a stationery position until the battery’s second level low

- voltage protection is triggered. At this point, the s UA S will descend and land in a steady, controlled manner. If an observer is present, they will have been briefed on the s UAS’s failsafe (return

- to

- home) mode and its activation (see Section on “Crew Briefing”).

• Air craft Incursion - If another aircraft should enter or appears to be

e ntering the Visual Line of Sight Operating Envelope VLOS, PIC will operate the s UA S to immediately maintain safe visual separation, and give way to any manned flight operation.28 FLY AWAY PROCEDURE A “fly away” is defined as the loss of control transmi ssion link where the PIC no longer has control or the ability to command the s UA S 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 of flight heading, speed, and altitude of the s UA S , and then follow the Incident Response Procedure as outlined below:

• Crash & Incident Response While Aerial Photo Shop takes extreme caution in its flight procedures to prevent a loss of control or crash, any incident, accident , or operation that transgresses the lateral or vertical boundaries as defined by the applicable COA issued must be reported to the FAA UAS 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 UAS Integratio n Of fice contact information29 

# Appendix A

Checklists30 

### P RE

- FLIGHT START

- UP CHECKLIST:
 Verify all transmitter, on

- board aircraft and camera batteries are full y cha rged (confirm voltages)

.  Ensure no frequency conflicts with video and transmitter / receiver

.  Check all control surfaces for signs of damage, loose hinges, and overall condition. Inspect the wings / rotors to ensure they are in good structural condition and properly secured.
 Check motor / engine and mounting attach ments to the airframe.
 Inspect propellers / mounting hardware (tight) / rotor b lades for c hips a nd d eformation.
 Check the landing gear for damage and function

.  Test electrical connections ( plugged in and secure ).
 Ensure photo / video equipment mounting system is secure and operational.
 Check location of GPS equipment controlling the autopilot.
 Check the IMU movements in the ground control software.
 SUAS in stabilization mode, ensure control response move toward th e
co rrect positions

.  SUAS / Drone is in a level location safe for takeoff

.  FPV / Power up ground station

.  FPV / Power up Video receive r.  If using Video recorder , turn on camera system

.  Camera settings are correct (still images, video, frame rate ).
 SD camera memory clear and inserted into the camera

.  Action / Start filming

.  All transmitter controls move freely in all directions

.  All trans mitter trims in neutral position

.  All transmitte r switches in correct position ( typically away)

.  Transmitter throttle to zero

.  Radio transmitter on

.  Connect / power on battery to airframe

.  Ensure led indicators and audible tones are correct

.  Timer on (if a pplicable)

.  FPV, confirm video is in monitor / goggles

.31  Scan for nearby cars / people / animals

.  Say “CLEAR!”.
 Arm flight controller

.  Increase throttle slightly listening for any abnormalities

.  Short 20

- 30 second hover at 3

- 5 feet (listen for vibrations / loose items)

.  Confirm Voltage levels are correct

.32 

### PRE

- FLIGHT INSPECTION CHECKLIST:  Perform initial walk

- around

.  Inspect SUAS for cracks in joints and structural members.  Inspect SUAS for loose or damaged screws, ties, fast eners, straps.  Inspect SUAS for loose or damaged wiring.  Inspect SUAS for loose or damaged connections (solder, plugs, etc.).  Inspect prop mounts and screws and apply slight counter pressure on arms to check for loosened components.  Ensure antennas and mas ts are secure.  Inspect / clean FPV Camera and Lens and insure it is secured an d

co nnections are firmly attached.  Ensure camera settings are correct (still images, video, frame rate).  Ensure FPV Transmitters are secure and operational.  Ensure batteries are fully charged, properly seated and secured.  Ensure the following fail

- safe equipment is functioning:  RTH (return to home).  Recovery Command Response (toggle test).  Firmware Airport Proximity Detection.  Ensure props are smooth and free of damage / defect (check blade, surface and hub).  Ensure prop adapters are tight / secure.  Ensure voltage alarm is connected.  Ensure arming / idle timeout is properly configured.  Ensure correct model is selected in transmitter (if applicable).  Check RC transmitter for the cor rect range and centering for all sticks.  Perform range test.33 

### IN

- FLIGHT CHECKLIST:  Basics: If flying manually, always keep your fingers on the controller/transmitter.  Never let the SUAS out of your sight even for a second.  Climb to a safe altitud e away from potential hazards and to reduce noise pollution.  Keep aircraft at a safe operating distance from people, electric utility lines and buildings.  If the SUAS must be flown over buildings or people, use a lightweight SUAS and maintain a safe altitu de for recovery and make every effort to minimi ze
e xposure.  Spotter: Use a spotter whenever possible and appropriate, especially when flying by First Person View (FPV).  Do not fly SUAS s within distance defined by local laws of any private/commercial airpor t/helipad.  Do not fly around a pre

- existing SUAS flying site without a frequency

management agreement.  Do not interfere with operations and traffic patterns at any airport.34 

### LANDING CHECKLIST :  Regardless of whether of a manual or automate d SUAS landing, sca n l anding area for potential obstruction hazards.  Announce out loud “Preparing to Land”.  Use a safe descent rate and follow correct procedures to avoid a vortex state or settling.  Carefully land the aircraft away from obstructions and pe ople.  Turn the power off to the aircraft and/or disconnect the batteries.  Turn off the transmitter.  Turn the power off to the photo equipment.  Visually check aircraft for signs of damage and/or excessive wear.  Remove the unused fuel if applicable. Secure the aircraft.  Check pictures: Verify that the SUAS camera actually took the pictures.  LOG FLIGHT

.35 

# Appendix B

Maintenance Logbook36 

### MAINTENANCE LOGBOOK

Date Component Maintenance Activity Maintenance Tim e Comments37 

# Appendix C

Incident/Accident Logbook38 

### INCIDENT/ACCIDENT LOGBOOK

Date of Incident/ Accident Time o f Incident/ Accident Name of Injured Incident/Accident Details Action Taken Notes39 

# Appendix D

Flight Record Logbook40 

### FLIGHT RECORD LOGBOOK (Sample Page)

Date Location Activity Flying Time Battery Before Battery After Comments