Shawn May len, DBA 

Silicon Valley UAV 

Address: 

Att: Shawn Maylen 

1052 Metro Circle 

Palo Alto, CA. 94303 

Info@S ilicon V alleyU A V .com 

408-355-0216 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

April 12, 2015 

Re: Petition of Shawn Maylen I DBA Silicon Valley UAV for an Exemption Pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 

Dear Gentlemen: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 ("Reform 

Act") and 14 C.P.R. Part 11, Shawn Maylen I DBA Silicon Valley UAV, hereby applies for an 

exemption from the Federal Aviation Regulations ("FARs") identified below, to allow 

commercial operations of small unmanned aerial vehicles (i.e. "small unmanned aircraft" or 

"UAS/UA V"). 

The exemption is requested based on information in this petition, as well as the 

accompanying Silicon Valley UA V Flight Operations Manual ("FOM") and the Pre I Post Flight 

Checklists for the UAS identified and incorporated by reference into Section 2 of the Flight 

Operations Manual. I the petitioner submit these supporting materials as confidential 

documents under 14 C.P.R. § 11 .35(b ); as they contain confidential commercial and proprietary 

information that Petitioner has not and will not share with others. Similarly, these documents 

contain operating conditions and procedures that are not available to the public and are protected 

from release under the Freedom of information Act, 5 U.S.C. § 552 et seq., and any other 

requirements established by the FAA pursuant to Section 333 ofthe FAA Reform Act. 

For your convenience, the petition is organized as follows: 

I. Description ofPetitioner 

II. Types of Operations 

A. Request to Use UASs for R&D at Test Sites Owned or Controlled by Shawn Maylen I 

Silicon Valley UAV. 
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April12, 2015 

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B. Request to Use UASs for Survey and Inspection of Damage After Casualty 

Events 

C. Request to Use UASs for Risk Assessment, Risk Management, Loss Control, 

Surety & Security Performance 

III. Relevant Statutory Authority 

IV. Silicon Valley UAV/Shawn Maylen Proposed UAS Operations Meet the Requirements of 

Section 333 of the Reform Act 

V. Regulations From Which Exemption is Requested 

A. 14 C.P.R. Part 21, Subpart H- Airworthiness Certificates and 14 

C.P.R. § 91.203 

B. 14 C.P.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

C. 14 C.P.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

D. 14 C.P.R.§ 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.P.R.§ 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

E. 14 C.P.R. § 91. 7(a): Civil Aircraft Airworthiness 

F. 14 C.P.R.§ 91.103: Preflight Action 

G. 14 C.P.R. § 91.109(a): Flight Instruction 

H. 14 C.P.R. § 91.119: Minimum Safe Altitudes 

I. 14 C.P.R.§ 91.121: Altimeter Settings 

J. 14 C.P.R.§ 91.151(a): Fuel Requirements for Flight in VFR 

Conditions 

K. 14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

L. 14 C.P.R.§ 61.113 

VI. Drug and Alcohol Program 

VII. Public Interest 

VIII. Privacy 

IX. Federal Register Summary 

X. Conclusion 

I. DESCRIPTION OF PETITIONER 

Silicon Valley UAV/Shawn Maylen was founded in 2014 in California. I am a competent sub 20 

lbs. UASIUAV pilot with 28+ months of research, development, and testing of multiple flight 

controllers, ESC's, power distribution systems, as well as programing experience of multiple best-ofbreed UAS flight controllers. Silicon Valley UAV/Shawn Maylen has over 510 hours of 

UASIUAV flying experience on multiple UAS platforms under 20 pounds over the past 4 years. 

Silicon Valley UA V /Shawn Maylen has the ability to competently apply the stated 

experience/skill-sets/flight-time for commercial application safely. Silicon Valley UAV/Shawn 

Maylen's background also includes 14 years 
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of wilderness I urban search & rescue training, effective use of GPS navigation systems both 

wilderness & urban, canine scent detection training & security experience coupled with 22 years of 

Enterprise level business experience in multiple top performing sectors including Banking, Real 

Estate, Travel, and Automotive. 

Silicon Valley UAV/Shawn Maylen now provides free UASIUAV R&D services. We have a 

100% safety record over the past 4 years, and my capabilities are at the forefront of purpose-built 

UAV technology designed specifically for each customer's unique mission protocols. I can service 

a wide variety of commercial, government, and educational requirements immediately as well as 

ensure the best-of-bread return-to-home & imagery technology available to the commercial market. 

Silicon Valley UAV/Shawn Maylen is committed to remaining at the forefront of 100% safe 

commercial application ofUAS I UAV technology. In this regard, Silicon Valley UAV/Shawn 

Maylen will continually examine the latest technology to meet emerging commercial needs, as well 

as educate first responders as to how best incorporate UAS/ UA V technology and effectively utilize 

aerial technology. Please note 3D imaging is of great value to SAR teams. 

Silicon Valley UAV/Shawn Maylen expect to use our UAS's to support our clients extensive 

systems of risk assessment, risk management, loss control, logistics capabilities/tools, and surety 

performance programs with free imagery. Silicon Valley UAV/Shawn Maylen's primary focus is 

safety first, as well as preventing accidents, terrorism, as well as interdiction of security events 

before they happen. Silicon Valley UA V /Shawn May len will provide a unique aerial tool combined 

with best-of-breed ground based technologies to assess and enhance safety in places that are 

inaccessible or have troubling access points for personal inspection or inspection by expensive 

manned aircraft. 

Silicon Valley UAV/Shawn Maylen has all the current skill-sets and equipment necessary to offer a 

high degree I level of safety and effective UASIUA V services to commercial entities & first 

responder teams. Well have the ability to call on an array of highly experienced aviation system 

professionals/mentors to fly each specific mission/flight profile correctly, and in a manner that will 

deliver or exceed an Equivalent Level of Safety the FAA currently prescribes for manned rotary 

aircraft. 

Silicon Valley UAV/Shawn Maylen has developed a keen knowledge-base of multi-rotor, power 

distribution, and flight controller programing & build experience specifically focused on issues 

affecting multiple open source flight controllers, multirotor manufacturing, and safe use of 

UASIUAV's. The importance & implementation of thorough planning for both normal operations 

and for contingencies plans that might affect the safety of flight, people, and physical property is a 

core philosophy of Silicon Valley UA V /Shawn May len. 

Petitioner contact information: Silicon Valley UAV/Shawn Maylen 

1052 Metro Circle, Palo Alto, CA. 94303 I 408-355-0216- info@SilicinValleyUAV.com 
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April12, 2015 

Page4 

II. TYPES OF OPERATIONS 

A. Request to Use UASs for R&D imagery at Test Sites Owned or Controlled by Silicon 

Valley UAV/Shawn Maylen- Silicon Valley UAV/Shawn Maylen is requesting 

exemptions pursuant to Section 333 to conduct research and development at Silicon Valley 

UA V /Shawn May len controlled and carefully selected properties owned or managed 

facilities. 

Testing facilities will not be open to the public and access will be restricted to Silicon Valley 

UA V /Shawn May len employees or consultants engaged in R&D flying or R&D-related work. UAS 

testing will occur outside navigable airspace at an altitudes of 400 feet AGL or less. The test sites 

will enable Silicon Valley UA V /Shawn May len to evaluate how the UASs will operate and capture 

images over various types of buildings, cell sites, towers, stadium events, mass casualty events, and 

in various weather I technical conditions. Silicon Valley UA V /Shawn May len will use these tests 

to, among other things, develop new potential uses for UASs that support Silicon Valley 

UAV/Shawn Maylen's current relationships or potential clients core business, refine operational 

procedures I protocols, and test different payloads and sensors. The test areas will also be used for 

maintenance evaluation and pilot training purposes. Silicon Valley UAV/Shawn Maylen's efforts 

are focused on meeting the needs of its clients and enhancing the Silicon Valley UA V /Shawn 

Maylen business processes. Specifically, Silicon Valley UAV/Shawn Maylen will evaluate how to 

utilize the employed UAS's to assess and evaluate risks associated with or damage to clients interest. 

B. Request to Use UASs for pre-emptive surveys and inspection of equipment, infrastructure, 

bridges, roadways, fire abatement, cell sites, commercial radio towers, as well as damage of 

these structures I equipment after Casualty Events. Silicon Valley UAV/Shawn Maylen also 

seeks exemption pursuant to Section 333 to conduct inspections of its own clients property that has 

suffered damage. Certain types of property damage are difficult and dangerous for a human to 

physically inspect, particularly where the structural integrity has been compromised. The alternative 

of using conventional aircraft or helicopters carries with it a large expense, operational difficulties, 

and added risks. Silicon Valley UAV/Shawn Maylen will face unique demands during and 

immediately following catastrophic events or natural disasters. Silicon Valley U A V /Shawn May len 

will be able to provide more expeditious responses and post-disaster assistance allowing its clients 

access to the resources necessary to begin the process of recovery and rebuilding. As part of this 

effort, Silicon Valley UAV/Shawn Maylen is committed to partnering with appropriate federal, 

state and local governments and first responder organizations to ensure full cooperation and 

coordination with their needs. This will include information sharing that can further assist first 

responders & proper UAS development/deployment. 

C. Request to Use UAS's for Filming, Risk Assessment, Risk Management, Loss Control, 

and Surety Performance. Silicon Valley UAV/Shawn Maylen is a already a leader in providing 

services to customers aimed at ensuring accidents or security event never occur. It is Silicon Valley 

UAV/Shawn Maylen's philosophy to manage Safety and Risks very proactively. Silicon Valley 

UA V /Shawn Maylen will apply experience and our hyper evolved UA V/UAS safety protocols to 
I • 

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evaluate a client's unique loss potential and may recommend cost effective, professional and 

measurable methods to manage security & risks. 

Silicon Valley UA V /Shawn May len has a vast inventory of control services that can be 

customized to address Security issues, management, crew I employee safety, business continuity and 

crisis management in all area of our business. As part of our Safety program, Silicon Valley 

UA V /Shawn May len understands that UASs will be an invaluable tool that will permit risks to be 

assessed and mitigated in places where it is impossible or unsafe for a human to conduct an 

assessment. In addition, UASs provide an opportunity for ongoing documentation and 

monitoring of risks and will permit new mitigation strategies to be applied if or as necessary. 

As set forth in the attached Operations manual, these flights will be flown under a strict 

set of guidelines. They will be flown only over the clients property or over property where 

permission has been obtained from the owner, and strict safety measures will be in place to 

ensure that there is no exposure to members of the public who are not involved in the operations. 

III. RELEVANT STATUTORY AUTHORITY 

This petition for exemption is submitted in accordance with Section 333(a) through (c) of 

the FAA Modernization and Reform Act of2012. Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned 

aircraft systems to operate in the National Airspace ("NAS") where it is safe to do so based on 

the following considerations: 

• The UAS's size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the U AS within the visual line of sight of the operator. 1 

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority ofthe 

Administrator); 49 U.S.C. § 44701(±) (permitting exemptions from§§ 4470l(a), (b) and§§ 44702-

44 716, et seq.). A party requesting an exemption must explain the reasons why the exemption: ( 1) 

would benefit the public as a whole, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules). See 14 C.F .R. § 11.81 (petitions for 

exemption). 

1 !d. at 333(b )(1). 
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IV. Silicon Valley UAV/Shawn Maylen PROPOSED OPERATIONS MEET THE 

REQUIREMENTS OF SECTION 333 OF THE REFORM ACT 

The proposed operations in this Petition for Exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. 

A. Approval is Warranted Based on the UASs Size, Weight and Operational 

Capability Silicon Valley UAV/Shawn Maylen will employ the UASs identified in Section 2 of the 

accompanying Operations Manual. These UAS will be used for all of the operations as set forth in 

the Operations Manual. Each of these UASs have characteristics in common that warrant approval. 

All of the UASs will be limited to a maximum horizontal or vertical flight speed during standard 

operations of 5 feet per second. Vertical ascent speed will be limited to 15 m.p.h., and none of the 

devices have a weight in excess of20 pounds. Each of the UASs shall incorporate an integrated GPS 

system to calculate the UASs' position and height and to relay that information via 

Real time connection to the operator. All UAS's will utilize "failsafe" mode which thus permits the 

vehicle to return to predetermine location to prevent injury or damage. All our UAS systems permits 

the vehicle to return to a predetermined location and land autonomously to prevent injury or damage. 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Silicon Valley UAV/Shawn Maylen Flight Operations Manual and the manufacturers' maintenance 

and flight manuals. These documents in our possession contain all of the procedures and limitations 

necessary to successfully perform R&D and inspections of Silicon Valley UAV/Shawn Maylen 

customers property before, during and after catastrophes or other loss events. 

To assist the FAA in its safety assessment of Silicon Valley UAV/Shawn Maylen operations, below 

is a summary of operational limitations and conditions which will ensure a level of safety equal to or 

exceeding the level of safety for operations conducted under current regulatory guidelines: 

1. The UASs employed by Silicon Valley UAV/Shawn Maylen will weigh 20 pounds or less. 

2. Flights will be operated within line of sight of a pilot and observer. 

3. Maximum total flight time for each operational flight will be limited to an amount of 

time the UASs can be flown and land and still maintain a reserve battery power of no less than 

25%. 

4. Flights will be operated at an altitude of no more than 399 feet A G L and will not be 

conducted within navigable airspace. 

5. Flights will be operated at a lateral distance of at least 100 feet from any persons 

or property not associated with the operation who have not given prior permission. 
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6. Flights will be limited to a vertical and horizontal speed of no more than 5 feet per second. 

7. Minimum crew for each operation will consist of the UAS Pilot, one or more Visual 

Observers ("Spotter") as necessary to safely conduct the mission, and a Sensor Operator, if the 

sensor requires human direction or control. 

8. Each additional new UAV I UAS pilot will have a minimum of200 hours previous amateur/noncommercial UAS/UAV flights, and be enrolled in training to pass the FAA written knowledge test, 

and will have sufficient experience and recurrent training to safely conduct all commercial UAS 

flights in accordance with the standards set forth in the Operations Manual. 

9. The observer designated for any operation will be in constant voice contact with the 

pilot. 

10. The UASs will operate in accordance with the safety and operational requirements of 

their respective Manuals. 

11. Prior to the operation, a Mission Plan will be created setting forth the limitations for 

the flight as well as contact and hazard information. 

12. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies. , 

13. lfthe UAS's lose primary controller uplink/ GPS, the UAS will have the capability 

to autonomously return to a pre-determined safe location within the operational area and land. 

14. Contingency plans will be in place to safely terminate flight ifthere is a loss of 

communication between the pilot and the observer. 

15. The UASs will have the capability to abort a flight in case ofunpredicted obstacles or 

emergencies. 

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under§ 40101 ofthe Act, including UASs, from its safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the public interest. 2 

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 

45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed below 

are (1) the specific sections of 14 C.F .R. for which exemption is sought, and (2) the operating 

procedures and safeguards that Petitioner has established which will ensure a level of safety 

better than or equal to the rules from which exemption is sought.3 
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A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 

91.203( a )(1) 

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the UAS selected provides an equivalent level of safety when 

compared to aircraft normally used for the same application. These criteria are met, and 

therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA2014-0352 at 13-14,22. If, however, the FAA determines that there are some characteristics of 

the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety 

The UAS's identified in Section 2 ofthe Operations Manual are safe when taking into 

account their size, weight, speed, and operational capability. As set forth in Section II, Supra, 

all of the UASs weigh less than 20 pounds and will be flown at less than 5 miles per hour and 

completely outside controlled airspace. Additionally, the UAS's carry neither pilots nor 

passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively 

within the parameters stated in the Operations Manual. 

zSee 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). 

3 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek exemption. 

Operations under this exemption will be closely controlled and monitored by the operator 

and will be conducted in compliance with local public safety requirements, to provide security 

for the area of operation. Silicon Valley U A V /Shawn May len will also provide the FAA with 

advance notice of all operations via NOTAMS and coordination with the local FSDO. In all cases, 

the UASs operated under the proposed conditions, will be at least as safe as, or safer than 

conventional rotorcraft operating with an airworthiness certificate without the restrictions and 

conditions of the proposed UAS operations. The aircraft themselves do not need a means to 

communicate with other aircraft or A TC, because those capabilities will be possessed by the pilot 

and observer, who are not onboard. See Grant ofExemption, Docket FAA-2014-0352 at 13. In 

addition, no sense and avoid technology is necessary on the UAS because it will be operated at all 

times by visual line-of-sight. ! d. 
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B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

14 C.F .R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent the Petitioner's UASs would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards 

for the same reasons identified in the request for exemption from 14 C.F .R. Part 21, Subpart H, 

supra. 

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.P.R.§§ 91.9(c), 45.23(b) and 45.27(a). 

• 14 C.P.R.§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 of this chapter. 

• 14 C.P.R.§ 45.23(b), Markings ofthe Aircraft, states: 

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display 

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable.- Silicon Vally UAV 

makings will be prominently displayed 

• 14 C.P.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by§ 45.23. 

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) markings 

in accordance with 14 CPR part 45, Subpart C if the markings are as large as practicable." FAA 

Docket No. FAA-2014-0352. 

Equivalent Level of Safety 

Silicon Valley UA V /Shawn Maylen will mark all aircraft with their N-Number in a prominent 

spot on the fuselage with markings that are as large as practicable. 
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D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of 

this chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it 

has within it the following: 

(1) An appropriate and current airworthiness certificate ... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under 

§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 

Silicon Valley UAV/Shawn Maylen does not request an exemption from this section but instead 

notifies the FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 

2014, the UAS flight manual, registration certificate and other documentation will be kept at the 

control station or with the PIC during flight. The Chief Counsel's Office has held that for all UAS 

operations, this alternate method constitutes full compliance with the regulations. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Petitioner seeks an exemption from 14 C.P.R.§ 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, Petitioner requests that the requirements for Section 91.7 be treated in accordance 

with Section V(A), supra. 

F. 14 C.F.R. § 91.103: Preflight Action 

Petitioner seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight manual is required. 
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G. 14 C.F.R. § 91.109(a): Flight Instruction 

Petitioner seeks an exemption from 14 C.P.R.§ 91.109(a), which provides that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. 

Equivalent Level of Safety 

Given the size and speed of the UASs employed by Silicon Valley UA V /Shawn May len, an 

equivalent level of safe training can still be performed without dual controls because no pilot or 

passengers are aboard the UASs, and all persons will be a safe distance away in the event that the 

UASs experiences any difficulties during flight instruction. In addition, Petitioner will conduct flight 

training at its Research and Development test sites, which are located on its own property. These 

training flights will be conducted in a sterile area and will otherwise comply with the provisions 

in the Operations Manual for flights at the R&D facility. Accordingly, Silicon Valley UA V /Shawn 

Maylen proposed method of operation provides superior levels of safety. 

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F .R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may 

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F .R. § 91.119( c). Section 91.119( d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, and speed of the UASs, as well as the 

location where it is operated. In order to avoid any risk to aircraft, flight operations will be 

restricted to 400' AGL or below. As set forth in the Manuals, the UASs will be operated in a 

restricted area, away from persons or structures not involved in the operation. 

I. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F .R. § 91.12 I, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required 

to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read 

out. 
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Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety can be achieved ifthe UASs will be 

operated at 400' AGL or below and within visual line-of-sight in addition to GPS based altitude 

information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial, 

Docket No. F AA-2014-0352. As the attached Operations Manual indicates, the chosen UASs 

meets these requirements, and a zero altitude initiation point will be obtained prior to flight. 

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 

Conditions 

Petitioner requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight 

in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30 minute reserve. Silicon Valley 

UAV/Shawn Maylen proposes that all flights comply with this requirement by mandating that the 

aircraft be safely landed with no less than 25% of battery life remaining. 

Equivalent Level of Safety 

The FAA has stated thatan equivalent level of safety is provided ifthe UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of Exemption to 

Astraeus Aerial, Docket No. F AA-20 14-0352. The Operations Manual conforms to this limit, 

providing an equivalent level of safety. 

K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

Petitioner seeks an exemption from the maintenance inspection requirements contained in 

14 C.P.R.§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R.§ 

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is 

needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, 

which the U AS will not have. 
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April12, 2014 

Page 13 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the UAS Manufacturer's Manual, as referenced in the 

Operations Manual. As provided in the Operations Manual, flights will not be conducted unless 

a flight operations checklist is performed that includes all of the aircraft's components. The 

Operations Manual also sets requirements for maintenance log books and record keeping as well 

as routine and post-flight maintenance. The Manual sets requirements for both annual 

maintenance and preventative maintenance based on hours of flight. 

L. 14 C.F.R. § 61.113: Private Pilot Privileges And Limitations 

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate 

holders from flying aircraft for compensation or hire, and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot is carrying passengers or cargo for hire. In this case, while the UASs will be 

operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant 

ofExemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique 

characteristics ofUAS operation outside of controlled airspace did not warrant the addition cost 

and restrictions attendant with requiring a the PIC to have a commercial pilot certificate and 

class II medical certificate. 

The restrictions Silicon Valley UAV/Shawn Maylen has placed on its UAS operations meet or 

exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352. 

Silicon Valley UAV/Shawn Maylen will operate in a sterile area away from persons and property 

not involved in the operation. It will be flown based on VLOS at 400' AGL or below. A NOT AM 

will be issued between 48 and 72 hours before the flight is to occur, and the flight will be coordinated 

with the applicable FSDO. 

Equivalent Level of Safety 

In addition to these flight restrictions, Silicon Valley UAV/Shawn Maylen will further ensure safe 

operation by requiring that any PIC be thoroughly versed not only in airspace and communication 

issues pertaining to all aircraft operators but also in the unique aspects ofUAS flight. Pilots will also 

be required to conduct training flights at Silicon Valley UAV/Shawn Maylen Research and 

Development facilities to obtain flight experience with UAS specific models used for commercial 

operations in particular. Petitioner believes that this system will provide a higher level of competency 

and proficiency for its pilots. 
1' 

U.S. Department of Transportation 

April12, 2015 

Page 14 

VI. DRUG AND ALCOHOL PROGRAM 

Silicon Valley UAV/Shawn Maylen has policies in place to ensure that no person may act as a PIC, 

observer, or sensor operator if they are under the influence of alcohol or drugs. We have a no alcohol 

policy 24 hrs. prior to flight. Policy attached ... 

VII. PUBLIC INTEREST 

Granting Silicon Valley UAV/Shawn Maylen exemption request furthers the public interest. 

National policy set by Congress favors early integration ofUAS into the NAS in controlled, safe 

working environments such as those proposed in this petition. In addition, the public also has an 

interest in reducing the hazards and emissions associated with alternate use of large fossil fuel 

helicopters to conduct similar inspection operations. The UASs in question are very light and do not 

carry any flammable fuel, further reducing the risk from any potential accident. 

Additionally, Silicon Valley UAV/Shawn Maylen intended uses for the UASs have real-world 

benefits for Silicon Valley UA V/Shawn Maylen potential clients, current relationships, and future 

education partners. Silicon Valley UAV/Shawn Maylen will be able to inspect and 

survey its clients property/assets before and after a casualty event safely, thoroughly, and efficiently. 

The work of Silicon Valley UAV/Shawn Maylen will aid its clients in the process of safe UAS 

production filming, as well as recovery and rebuilding. The UAS work will also aid Silicon Valley 

UA V /Shawn May len to provide top-tier risk assessment, risk management, loss control, and surety 

performance programs by providing safe, efficient, and reliable UAS/UA V services. These programs 

prevent accidents and injuries, and there is a strong public interest in making these programs more 

effective through the use ofUASs. Finally, by coordinating and teaming with federal, state and local 

governments after a disaster, Silicon Valley UAV/Shawn Maylen can now provide valuable aerial 

imagery/information to first responders and government entities which will assist with aid & 

deployment of a proper coordinate disaster response. 

VIII. PRIVACY 

All flights will be conducted in accordance with any federal, state or local laws regarding 

privacy. 

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Silicon Valley UA V /Shawn May len seeks an exemption from the following rules: 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR § 61.113; 14 

CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 
U.S. Department of Transportation 

October 31, 2014 

Page 15 

91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 

14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b). 

The exemption will enhance safety by reducing risk to the general public and property 

owners from the substantial hazards associated with performing equivalent work with 

conventional aircraft and rotorcraft. 

X. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012-size, 

weight, speed, operating capabilities, proximity to airports and populated areas, operation within 

visual line of sight, and national security-provides more than adequate justification for the grant 

ofthe requested exemptions to permit Silicon Valley UAV/Shawn Maylen to operate the selected 

UASs and provide R&D and inspections during and after casualty events. 

Granting the requested exemption will benefit the public interest as a whole in many 

ways, including (1) significantly improving safety and reducing risk by alleviating human 

exposure to danger, and (2) improving the quality of services and decreasing operating costs 

compared with conventional flight operations. 

If you have any questions or require any additional information, please do not hesitate to 

Call or email. 

Silicon Valley UA V /Shawn May len 

408-355-0216 

info@SiliconValleyUAV.com 

shawnmaylen@Gmail.com 

Attachments: Silicon Valley UA V /Shawn May len Flight Operations Manual and Pre I Post Flight 

Check Lists (submitted as a Confidential Documents under 14 C.P.R.§ 11.35(b) and exempt from 

disclosure under the Freedom of information Act, 5 U.S.C. 

§ 552 et seq., and any other requirements established by the FAA pursuant to Section 333 ofthe 

Reform Act); Aircraft Flight and Maintenance Manuals as incorporated into the Silicon Valley 

UAV /Shawn Maylen Operations Manual (submitted as a Confidential Document under 14 C.P.R. § 

11.35(b) and exempt from disclosure under the Freedom oflnformation Act, 5 U.S.C. § 

Also attached: Drug & Alcohol Policy, UAVIUAS Flight log document sample (this is a work in 

progress) 
Silicon Valley UAV 

UAS Flight Operations and Safety Manual v1.3 May 2015 

This Flight Operations and Safety Manual (FOM) shall serve as the basis for all flight operations 

conducted by Silicon Valley UAV. 

At present Silicon Valley UAV owns and operates 2 UAS platforms which include the DJIInspire 

1 UAS and the DJI450 I Eagle Tree Flight Control Systems UAS with OSD sub 20 lbs aircraft. 

Commitment to Safety 

All UAS operations conducted by Silicon Valley UAV shall be carried out with the utmost 

consideration of safety towards all participants, spectators and property. At no time will UAS 

operations or flight profiles exceed the published operational limits of any UAS operated by 

Silicon Valley UAV. 

All flight operations will follow Silicon Valley UAV's published flight profile preflight and post 

flight checklist. No flight operations shall be carried out without the completion and adherence 

to all checklist items. 

Review of NOT AM's Prior to Flight Operations 

No flight operations shall commence until all NOTAM's relevant to the airspace of a proposed 

UAS Flight Profile have been thoroughly reviewed and the impact of such NOT AM's assessed. 

Review of Local Weather Forecast 

No flight operations shall commence until current local weather forecasts have been reviewed 

and approved by the PIC. 

Flight Logs 

Every UAS commercial or training flight undertaken by Silicon Valley UAV will be logged in both 

the PIC's log book as well as the log book associated with the specific UAS flown during the 

activity being logged. Log entries shall reference the "N Number" of all relevant UAS aircraft. 

Use of Real Time Telemetry 

Any UAS operated by Silicon Valley UAS shall be equipped with on-board real time telemetry 

which shall provide, at a minimum, the following information: 

UAS horizontal and vertical airspeed 

Current GPS location 

Real time compass heading of UAS flight path 
On board battery voltage(s) 

Utilization of this state-of-the-art technology will insure that Silicon Valley UAV can maintain 

the highest level of safety during the operation of any flight profile. 

Use of Published Silicon Valley UAV Pre I Post Flight Check Lists 

All UAS PIC's shall utilize approved pre and post flight check lists to insure utmost adherence to 

all safety standards and protocols. 

Conditions for Flight Profile Termination 

Any UAS flight profile will be immediately terminated should any of the following conditions 

develop: 

Loss of video down-link 

Loss of primary UAS telemetry down-link 

Battery voltage fluctuations outside of nominal values 

Decrease in RSSI (Receiver Signal Strength Indicator) strength below nominal value 

Erratic UAS behavior not initiated by PIC 

Unexpected aircraft I bird incursion into flight profile airspace 

Any incursion of ground spectators into primary or secondary safety zones 

Minimum Personnel Required for Flight Operations 

Under no circumstances may flight operation may be undertaken without the following 

personnel in attendance and available: 

Designated PIC 

Designated Safety Spotter 

Designated UAS Sensor Operator (if required) 

Established Safety Zones for PIC and Supplemental Ground Personnel 

No flight operations may commence unless and until appropriate safety zones have been 

established for both the PIC, Safety Spotter, and Sensor Operator (if required). 

Safety Zones must be a minimum of 100' in diameter and my house any or all ground based 

personnel actively involved in flight operations. 
Primary and Contingency Takeoff I Landing Zones 

Flight operations may not commence unless and until a specific primary takeoff and landing site 

has been identified and marked within the PIC Safety Zone. Additionally, a secondary 

contingency landing site shall be clearly identified and, if possible, marked to inhibit incursion 

by local spectators. The minimum diameter for the contingency landing site shall be 50'. 

Pilot Qualification 

All Silicon Valley UAV PIC's must demonstrate technical proficiency in all manner of UAS flight 

and control. In addition, the following specific requirements must be present to act as PIC for 

any UAS operated by Silicon Valley UAV must: 

Demonstrate a minimum 200 hours logged flight time as PIC operating UAS aircraft 

identical to those operated by Silicon Valley UAV. 

Have passed a pre-employment drug test within 90 days of working with Silicon Valley 

UAV. 

Have demonstrated legal US citizenship or residence status. 

Have passed a basic criminal background check. 

Adherence to Prepared UAS Flight Profiles 

No Silicon Valley UAV flight operation may be undertaken without a prior written flight profile. 

This flight profile must be approved by both the PIC and the commercial client. Every Silicon 

Valley UAV flight profile must also include the use of a designated flight spotter. 

Flight Profile Restrictions 

All Silicon Valley UAV flight operations must adhere to strict flight profile restrictions governing 

the maximum vertical and horizontal speeds. As currently published in the Silicon Valley UAV 

Flight Profile check list, these UAS vertical and horizontal speeds are not allowed to surpass 5 

feet per second except under exceptional conditions. 

Battery Safety 

All LiPo (Lithium Polymer) batteries flown by Silicon Valley will be transported in "LiPo safe" 

containers. All batteries will remain in their storage container until they are removed for flight. 

Unless previously determined to be necessary, no battery charging will occur during the 

undertaking of any commercial UAS flight profile. 

Maintenance and Inspection Protocols 

All Silicon Valley UAS aircraft must undergo thorough preflight and post flight inspections. 

These inspections must include examination of the UAS airframe, electric propulsion systems 

(including propellers) and on-board battery systems. 
Items subject to regular wear such as flight propellers will be replaced after every 10 hours of 

flight time. 

All maintenance inspections and activity must be logged in the associated UAS log book in a 

timely manner. 

Reporting Requests for Illegal Use of UAS Aircraft 

Silicon Valley UAV will immediately report and request for participation in illegal or suspicions 

activity to local law enforcement officials. 

Commitment to FAA Regulations 

Silicon Valley UAV operates under a Part 333 FAA waiver (pending) for the use of unmanned 

flying vehicles. Silicon Valley UAV recognizes that the regulatory environment surrounding the 

commercial operation of UAV's is very dynamic. As such, Silicon Valley UAV maintains a vigilant 

watch over all current and pending regulatory requirements. 
.. 

Silicon Valley UAV 

Drug & Alcohol 

Policy 

(For All Company Personnel/Team Member) 

INTRODUCTION 

It is the policy of (Silicon Valley UAV/Shawn Maylen) (herein referred to as the "Company") that the 

use, sale, purchase, transfer, possession, or presence in one's system of any controlled substance 

(except medically prescribed drugs) by any team member while on the Company's premises, 

engaged in Company business, operating Company equipment, or while under the authority of the 

Company is strictly prohibited. 

The Company further maintains a policy that the unauthorized use, sale, purchase, transfer, 

possession, or presence in one's system of alcohol or any other intoxicating agent by any employee 

while on the Company's premises, engaged in Company business, operating Company equipment, 

or while under the authority of the Company is strictly prohibited. 

There are many reasons why we have implemented a drug and alcohol testing program, they 

include but are not limited to: 

• Deter employees from abusing alcohol and drugs 

• Prevent hiring individuals who use illegal drugs 

• Be able to identify early and appropriately refer employees who have drug and/or alcohol 

problems 

• Provide a safe workplace for employees 

• Protect the general public and instill consumer confidence that employees are working safely 

• Benefit from Workers' Compensation Premium and Group Discount programs 

• Comply with State, Federal and Local laws and regulations 
Aspects of the Company's operations are subject to regulation by various federal, state and local 

agencies, therefore certain Company employees are subject to the terms and conditions of this 

Drug and Alcohol Policy, the terms and conditions of which are hereby incorporated within the 

(Silicon Valley UAV/Shawn Maylen drug and alcohol policy). The serious impact of drug use and 

alcohol abuse has been recognized by the federal government. Consequently, the Federal Motor 

Carrier Safety Administration (FMSCA) has issued regulations which require the Company to 

enhance its alcohol and controlled substance program. This is a "Supplemental" or addition to the 

(Silicon Valley UAV/Shawn Maylen policy), it is meant to educate the Company's employees about 

this enhanced program with the focus on drug and alcohol testing and safe UAV/UAS flight. 

It is the Company's intent that the policies and procedures in this Drug and Alcohol Policy be 

consistent with provisions contained in the (Silicon Valley UAV/Shawn Maylen drug & alcohol 

policy). In the unlikely event that the terms of this Drug and Alcohol Policy conflict with any provision 

contained in the Employee Handbook, the terms and conditions of this Drug and Alcohol Policy 

shall control. Violation of any provision contained in this Drug and Alcohol Policy shall be deemed a 

violation of the Company's overall drug and alcohol policy and will result in disciplinary action, up to 

and including termination. 

NEITHER THIS POLICY NOR ANY OF ITS TERMS ARE INTENDED TO CREATE A CONTRACT OF EMPLOYMENT 

OR CONTAIN THE TERMS OF ANY CONTRACT OF EMPLOYMENT. THE COMPANY RETAINS THE SOLE RIGHT 

TO CHANGE, AMEND, OR MODIFY ANY TERM OR PROVISION OF THIS POLICY WITH OR WITHOUT NOTICE. 

PLEASE BE ADVISED THAT THE FEDERAL MOTOR CARRIER SAFETY REGULATIONS ("FMCSR") SET THE 

MINIMUM REQUIREMENTS FOR TESTING OF SAFETY SENSITIVE EMPLOYEES. THE COMPANY'S POLICY IN 

CERTAIN INSTANCES MAY BE MORE OR LESS STRINGENT FOR OTHER EMPLOYEES. 

For More Information about DOT Requirements or Our Company Policy 

Contact the Company's Safety officer at (408-355-0216). As of the date of issuance of this D&A 

Policy, the Company's Safety officer is Shawn Maylen. This person also serves as the Company's 

role of Designated Employer Representative (DER). 

This policy is effective (Date of Hire). 

CONFIDENTIALITY/RECORDKEEPING 

All employee drug and alcohol test records are considered confidential. For the purpose of this 

policy/procedure, confidential recordkeeping is defined as records maintained in a secure manner, 

under lock and key, accessible only to designated employees. 

Employee alcohol and controlled substance test records will only be released in the following 

situations: 

• To the active employee, upon their request; 

• Upon written consent by the employee authorizing the release to a specified individual; 

• Upon request of a DOT agency with regulatory authority over the Company; 

• Upon request of state or local officials with regulatory authority over the Company; 

• Upon request of the United States Secretary of Transportation; 

• Upon request by the National Transportation Safety Board (NTSB) as part of an accident 

investigation; 

Ver. 3/14 2 
• In a lawsuit, grievance, or other proceeding when legally applicable; 

• Upon request by subsequent employers upon receipt of a written request by an employee; 

• To the DOT recognized National Drug & Alcohol Clearinghouse for truck and bus drivers 

(Pending) 

EMPLOYEE CATEGORIES SUBJECT TO TESTING 

This Supplemental Drug and Alcohol Policy applies to all employees, including, but not limited to, 

(all employees, agents, or team members.). 

The policies and procedure contained herein will be strictly applied to employees required to have a 

commercial driver's license (COL) who operate a commercial motor vehicle as defined in Part 382 

of Title 49 of the Code of Federal Regulations. 

If you are not required to have a COL or you do not operate commercial motor vehicles, please be 

aware that you might experience minor variations on how these policies and procedures are applied 

to you. 

Ver. 3/14 3 
DRUG & ALCOHOL PROHIBITIONS 

Employees are strictly prohibited from engaging in the following activities: 

Drug Prohibitions 

• Use of any controlled substance, except when administered by, or under the instructions of, a 

licensed medical practitioner, who has advised the employee that the substance will not affect 

the employee's ability to perform a safety-sensitive function. Be advised that the use of 

marijuana for medicinal purposes is not a legitimate explanation. Under federal law, the use of 

marijuana does not have a legitimate medical use in the United States. 

• These are the drugs that will be tested for. All Testing conducted according to SAMHSA's 

guidelines checks for a Five-Panel illicit drugs plus, alcohol (ethanol, ethyl alcohol, booze). 

These five illicit drugs are: 

• Amphetamines (meth, speed, crank, ecstasy) 

• THC (cannabinoids, marijuana, hash) 

• Cocaine (coke, crack) 

• Opiates (heroin, opium, codeine, morphine) 

• Phencyclidine (PCP, angel dust) 

However the company is not limited in the number of substances they can test for and may 

include drugs that individuals legitimately and/or therapeutically take based on a physician's 

prescription. Although most private employers can test for any combination of drugs, there are 

commonly selected "panels." 

The typical 8-Pane/ Test includes the above-mentioned substances plus: 

• Barbiturates (phenobarbital, butalbital, secobarbital, downers) 

• Benzodiazepines (tranquilizers like Valium, Librium, Xanax) 

• Methaqualone (Quaaludes) 

The typical 10-Pane/ Test includes the 8-Panel Test plus: 

• Methadone (often used to treat heroin addiction) 

• Propoxyphene (Darvon compounds) 

Testing can also be done for: 

• Hallucinogens (LSD, mushrooms, mescaline, peyote) 

• Inhalants (paint, glue, hairspray) 

• Anabolic steroids (synthesized, muscle-building hormones) 

• Hydrocodone (prescription medication known as Lortab, Vicodin, Oxycodone) 

• MDMA (commonly known as Ecstasy) 

• Sale, purchase, transfer, possession, or presence in one's system of any controlled substance 

(except medically prescribed drugs) by any employee while on the Company's premises, 

engaged in Company business, operating Company equipment, or while under the authority of 

the Company. 

• Testing positive for a controlled substance (except medically prescribed drugs). 

• Refusal to submit to a post-accident, random, reasonable suspicion, return-to-duty, or follow-up 

drug test. 

Ver. 3/14 4 
Alcohol Prohibitions 

• Reporting for duty or remaining on duty in a position requiring the performance of safetysensitive functions while having an alcohol concentration of .04 or greater. 

• Consumption of alcohol in any form while performing safety-sensitive functions. 

• Performance of any safety-sensitive function within 4 hours after consuming alcohol. 

• Refusal to take a required alcohol test. 

• Consumption of alcohol for 8 hours after an accident unless the employee has been given a 

post-accident test. This applies to employees with knowledge of an accident involving a 

commercial motor vehicle operating on a public road in commerce for which they performed a 

safety-sensitive function at or near the time of the accident. 

• Refusal to submit to a post-accident, random, reasonable suspicion, return-to-duty, or follow-up 

alcohol test. 

Definitions 

• Alcohol is defined as the intoxicating agent in beverage alcohol, ethyl alcohol, or other low 

molecular weight alcohols, including methyl or isopropyl alcohol. 

• Alcohol use is defined as the consumption of any beverage, mixture, or preparation, including 

any medication (prescribed or over-the-counter, intentional or unintentional), containing alcohol. 

• Covered Employee shall include all active employees of (Silicon Valley UAV/Shawn Maylen 

drug & alcohol policy) who are subject to the terms and conditions of this Supplemental Drug 

and Alcohol Policy. Acknowledgement of Receipt of this Drug and Alcohol Policy shall be 

indication that the employee is subject to the policy. 

• General Applicability: A employee is considered to be performing a safety-sensitive function 

during any period in which he or she is actually performing, ready to perform, or immediately 

available to perform any and all functions described or related to these described here. 

Ver. 3/14 5 
TYPES OF DRUG & ALCOHOL TESTING 

Employees may be subject to each of the following types of drug and alcohol tests: 

Pre-Employment (drug only) 

Employees shall be subject to a drug test prior to employment. No employee shall be permitted to 

perform any safety-sensitive function, including the driving of any company vehicle, until they have 

received a negative drug test result. 

Post-Accident 

In the event of an accident involving a commercial motor vehicle operating on a public road in 

commerce, the involved employee shall be subject to a drug and alcohol test in the following 

circumstances: 

• If the accident involved the loss of human life; 

• If the employee receives a citation for a moving traffic violation arising from the accident, and 

the accident involves either: 

• Bodily injury to any person who immediately receives medical treatment away from the 

scene of the accident; or 

• One or more motor vehicles incurring disabling damage requiring the motor vehicle to be 

transported away from the scene by tow. 

Random 

Employees shall be subject to random drug and alcohol testing. Random testing will be conducted 

without notice to randomly selected employees. Employees may be grouped into drug and alcohol 

testing pools based on job function, safety sensitive UAV pilots may be in a separate pool. All 

employees within each pool have an equal chance of testing. 

Reasonable Suspicion 

Employees shall be subject to reasonable suspicion drug and alcohol testing if a trained supervisor 

or trained company official believes or suspects that the employee is under the influence of drugs or 

alcohol (or both). 

Return-to-Duty & Follow-Up 

Employees retained by the Company after a positive test result or a test refusal shall be subject to 

return-to-duty drug and alcohol testing. No employee shall be permitted to perform any safetysensitive function until they have received a verified negative drug and alcohol test result. 

Thereafter, such employees will be subject to certain follow-up drug and alcohol testing as 

established by Substance Abuse Professional (SAP). 

Ver. 3/14 6 
DOT DRUG & ALCOHOL CONSEQUENCES 

Consequences of Using Drugs or Alcohol While Performing Safety-Sensitive Functions 

A covered employee who has engaged in prohibited drug or alcohol use during the performance of 

a safety-sensitive function will be immediately removed from performing safety-sensitive functions. 

Further, the employee will be subject to disciplinary action, up to and including termination. 

Consequences of a Verified Positive Drug Test 

A covered employee who receives one (1) verified positive drug test result on a DOT required test 

will be immediately removed from safety-sensitive duties. An employee who has a positive DOT 

drug test cannot return to the performance of safety-sensitive functions until and unless the 

employee successfully completes the return-to-duty process described later. Notwithstanding the 

foregoing, an employee that receives one (1) verified positive drug test result will be subject to 

disciplinary action, up to and including termination. 

Consequences of a Alcohol Test with a Concentration Greater than .04 

A covered employee who receives one (1) alcohol test with a result indicating an alcohol 

concentration of .04 or greater will be immediately removed from safety-sensitive duties. An 

employee who has a positive alcohol test cannot return to the performance of safety-sensitive 

functions until and unless the employee successfully completes the return-to-duty process 

described later. Notwithstanding the foregoing, an employee whose test results indicate an alcohol 

concentration greater than .04 will be subject to disciplinary action, up to and including termination. 

Consequences of an Alcohol Test with a Concentration Greater than .02 but Less than .04 

A covered employee who is found to have an alcohol concentration of .02 or greater but less than 

.04 will be immediately removed from performing safety-sensitive functions until the employee is 

retested with a result below .02 or until the start of the employee's next regularly scheduled duty 

period, if it occurs at least 8 hours following administration of the test. Notwithstanding the 

foregoing, an employee whose test results indicate an alcohol concentration greater than .02 will be 

subject to disciplinary action, up to and including termination. 

Consequences of Refusing to Submit to a Required Drug and/or Alcohol Test 

A covered employee who refuses to submit to a required drug and/or alcohol test or who receives a 

verified adulterated or substituted drug test result will be immediately removed from performing 

safety-sensitive functions. An employee cannot return to the performance of safety-sensitive duties 

until and unless the employee successfully completes the return-to-duty process described later. 

Notwithstanding the foregoing, an employee that refuses to submit to a required drug and/or alcohol 

test will be subject to disciplinary action, up to and including termination. 

Ver. 3114 7 
REFUSAL TO SUBMIT TO A DRUG AND/OR ALCOHOL TEST 

You are considered to have refused to take a drug and/or alcohol test if you: 

Drug Test 

• Fail to appear at a collection site for any test (except a pre-employment test) within a 

reasonable time, as determined by the Company, consistent with applicable DOT agency 

regulations, after being directed to do so by the Company. This includes the failure of the 

employee to appear for a test when called by the Company's third party administrator; 

• Fail to remain at the collection site until the testing process is complete; Provided that a 

person who leaves the testing site before the testing process commences for a preemployment test is not deemed to have refused to test; 

• Fail to provide a specimen; 

• Fail to permit a monitored or observed collection if the Company ordered or if the collector 

required the collection to be monitored or observed; 

• Fail to provide a sufficient amount of urine specimen, provided the Medical Review Officer 

(MRO) finds there was no medical reason for the employee to provide insufficient amount of 

urine; 

• Fail or decline to take an additional drug test that the Company or collector has directed; 

• Fail to undergo a medical examination or evaluation the MRO or the Company has directed; 

• Fail to cooperate with any part of the specimen collection process; 

• Fail, for an observed collection, to follow the instructions to raise and lower clothing and turn 

around; 

• Possess or wear a prosthetic or other device that could be used to interfere with the 

collection process if the employee is found to have or wear a prosthetic or other device 

designed to carry clean urine or a urine substitute; 

• Admit to the collector to having adulterated or substituted the specimen; 

• Adulterate or substitute a urine specimen; or 

• Admit to the MRO to having adulterated or substituted the specimen. 

Alcohol Test 

• Fail to appear at an alcohol test site for any test within a reasonable time, as determined by the 

Company, consistent with applicable DOT agency regulations, after being directed to do so by 

the Company. This includes the failure of the employee to appear for a test when called by the 

Company's third party administrator; 

• Fail to remain at the alcohol test site until the testing process is complete; 

• Fail to provide an adequate amount of saliva or breath; 

• Fail to provide a sufficient breath specimen, provided the physician finds that there was no 

medical reason for the employee to provide an insufficient amount of breath; 

• Fail to undergo a medical examination or evaluation as the Company has directed as part of the 

insufficient breath procedures; 

• Fail to sign the certification statement at Step 2 of the Alcohol Testing Form (ATF); or 

• Fail to cooperate with any part of the testing process. 

Ver. 3/14 8 
DRUG & ALCOHOL TESTING PROCEDURES 

Drug and/or alcohol testing shall be conducted at a facility designated by the Company. Specimen 

collection, analysis and reporting shall be conducted in accordance with the procedures outlined 

below which are consistent with the federal regulations enumerated in 49 CFR Part 40 and all 

applicable guidance and state laws. These collection procedures are designed to protect the 

employee and the integrity of the testing processes, safeguard the validity of the test results, and 

ensure that those results are attributed to the correct employee. 

Drug Testing Procedures 

• A DOT drug testing Chain of Custody Form (CCF) will be used to document the chain of 

custody from the time the specimen is collected at the testing facility until it is tested at the 

laboratory. 

• A collection kit meeting the requirements of Part 40, Appendix A of the DOT regulations must be· 

used for the drug test. 

• The collection of the specimen must be conducted in a suitable location and must contain all 

necessary personnel, materials, equipment, facilities, and supervision to provide for collection, 

security and temporary storage and transportation of the specimen to a certified laboratory. 

• The employee should have and present positive identification to the collector. The employee 

may also request positive identification of the collection site employee. 

• The employee must provide a specimen meeting the specified volume and temperature 

requirements. 

• All identifying information must be entered on the CCF by the collection site person. The CCF 

will be signed by the collector, certifying collection was accomplished in accordance with the 

instructions provided. The employee must also sign the CCF indicating the specimen was 

his/hers. 

• A urinalysis will be performed by a laboratory certified by the Department of Health and Human 

Services (DHHS) that has been retained by the Company. The laboratory will be required to 

maintain strict compliance with federally-approved chain-of-custody procedures, quality control, 

maintenance, and scientific analytical methodologies. 

• The laboratory must report all test results directly to the Company's designated medical review 

officer (MRO). The MRO is responsible for reviewing and interpreting all confirmed positive, 

adulterated, substituted, or invalid drug test results. The MRO must determine whether 

alternative medical explanations could account for the test results. The MRO must also give the 

employee who has a positive, adulterated, substituted, or invalid drug test an opportunity to 

discuss the results prior to making a final determination. After the decision is made, the MRO 

must notify the Company's designated employer representative (DER). 

• A employee who receives a positive, adulterated, or substituted drug test result has 72 hours to 

request the test of the split specimen (which is provided at the time of original collection). If the 

employee requests the testing of the split, the MRO must direct (in writing) the lab to provide the 

split specimen to another certified laboratory for analysis. The employee will pay for the testing 

of the split specimen. 

Alcohol Testing Procedures 

Alcohol testing may be conducted by a qualified Screening Test Technician (STT) or Breath Alcohol 

Technician (BAT). STTs are only permitted to conduct the first test given to an employee by using 

either a breath or saliva test (Screening Test). A BAT is authorized to conduct a Screening Test, 

but, unlike a STT, is also authorized to conduct the second test given to an employee whose test 

Ver. 3/14 9 
result is .02 or above (Confirmation Test). For a Screening Test, the STT or BAT may use an 

approved Alcohol Screening Device (ASD) or an Evidential Breath Testing device (EBT). For a 

Confirmation Test, the BAT is required to use an EBT. 

Screening Tests 

• The DOT Alcohol Testing Form (ATF) will be used to document the results of an alcohol 

screening test. 

• The testing will be performed in a private setting. Only authorized personnel will have access 

and are the only individuals who can see or hear the test results. 

• The employee should have and present positive identification to the STT or BAT at the test site. 

The employee may also request positive identification of the STT or BAT. 

• When an ASD is used, the STT or BAT must check the device's expiration date and show it to 

the employee. A device may not be used after its expiration date. 

• The STT or BAT will open an individually wrapped or sealed package containing the device in 

front of the employee and he/she will be asked to place the device in his/her mouth and use it in 

the manner described by the device's manufacturer. 

• The employee must work with the STT or BAT to perform the test, which includes the insertion 

of the device mouth piece in the employee's mouth and the exhalation (breathing out) must be 

performed in the manner described by the device's manufacturer. 

• The STT or BAT should wear single-use examination gloves and must change the gloves 

following each test. 

• When the device is removed from the employee's mouth, the STT or BAT must follow the 

manufacturer's instructions to ensure the device is activated. 

• If the procedures listed above cannot be successfully completed, the device must be discarded 

and a new test must be conducted using a new device. The employee will be offered the choice 

of using the new device or having the STT or BAT use the new device for the test. 

• If the new test cannot be successfully completed, the employee will be directed to immediately 

take a screening test using an EBT. 

• When an EBT is used, the mouthpiece of the breath testing device must be sealed before use 

and opened in the employee's presence. The mouthpiece is then inserted into the breath testing 

device. 

• The employee must blow forcefully into the mouthpiece of the testing device for at least 6 

seconds or until an adequate amount of breath has been obtained. 

• Once the test is completed, the BAT must show the employee the results. 

• The result displayed on the device must be read within 15 minutes of the test. The STT or BAT 

must show the employee the device and its reading and enter the result on the ATF. 

• If the reading on the ASD or EBT is less than .02, both the employee and the STT or BAT must 

sign and date the result form. The form will then be confidentially forwarded to the Company's 

DER. No further testing is authorized. 

• If the reading on the ASD or EBT is .02 or more, a confirmation test must be performed. 

Ver. 3114 10 
Confirmation Tests 

• If the result of the screening test is an alcohol concentration of 0.02 or greater, a confirmation test 

will be performed. If a different BAT will conduct the confirmation test, the BAT who conducts the 

screening test will complete and sign Step 3 of the ATF. The BAT will provide the employee with 

Copy 2 of the form. 

• In the presence of the employee, the BAT will conduct an "air blank" to ensure that the device is 

working correctly. The BAT must show the reading to the employee. The air blank result must be 

.00. If the reading is greater than .00, the BAT will conduct one more air blank. If the reading is 

greater than .00, testing will not proceed using the instrument. However, testing may proceed on 

another instrument. 

• The BAT will instruct the employee not to eat, drink, put any object or substance in his or her mouth, 

and, to the extent possible, not belch during a waiting period before the confirmation test. This time 

period begins with the completion of the screening test and will not be less than 15 minutes. The 

BAT will explain to the employee the reason for this requirement (i.e., to prevent any accumulation of 

mouth alcohol leading to an artificially high reading) and the fact that it is for the employee's benefit. 

The BAT will also explain that the test will be conducted at the end of the waiting period. If the 

employee has disregarded the instruction, the BAT will so note in the "Remarks" section of the ATF. 

• If a BAT other than the one who conducted the screening test is conducting the confirmation 

test, the new BAT will initiate a new breath alcohol testing form. The BAT will complete Step 1 

on the form. The employee will then complete Step 2 on the form, signing the certification. 

Refusal by the employee to sign this certification will be regarded as a refusal to take the test. 

The BAT will note in the "Remarks" section of the form that a different BAT conducted the 

screening process. 

• If the employee does not sign the certification in Step 4 of the form, it will not be considered a 

refusal to be tested. In this event, the BAT will note the failure to sign in the "Remarks" section 

of the form. 

• A breath alcohol test is invalid under the following circumstances: 

• The EBT does not pass its next external calibration check (invalidates all test results of 

0.02 or greater on tests conducted since the last valid external calibration test); this does 

not invalidate negative tests. 

• The BAT does not observe the minimum 15-minute waiting period prior to the confirmation 

test. 

• The BAT does not perform an air blank on the EBT before a confirmation test or such an 

air blank does not result in a reading of .00. 

• The BAT does not sign the form. 

• An EBT fails to print a confirmation test result. 

• The sequential test number or alcohol concentration displayed on the EBT is not the same 

as the sequential test number or alcohol concentration on the printed result. 

RETURN TO DUTY PROCESS AND FOLLOW-UP PROCEDURES 

The Company is not required to provide a Substance Abuse Professional (SAP) evaluation or any 

subsequent recommended education or treatment through an employee assistance program for an 

employee who has violated a DOT drug and alcohol regulation. If the Company, at its sole 

discretion, offers the employee an opportunity to return to a DOT safety-sensitive duty following a 

violation, the Company must, before the employee again performs that duty, ensure that the 

employee receives an evaluation by a SAP meeting the requirements of the regulations and that the 

employee successfully complies with the SAP's evaluation recommendations. 

Ver. 3/14 11 
SAP Responsibility 

• Making a face-to-face clinical assessment and evaluation to determine what assistance is 

needed by the employee to resolve problems associated with alcohol and/or drug use; 

• Referring the employee to an appropriate education and/or treatment program (EAP); 

• Conducting a face-to-face follow-up evaluation to determine if the employee has actively 

participated in the education and/or treatment program and has demonstrated successful 

compliance with the initial assessment and evaluation recommendations; 

• Providing the DER with a follow-up drug and/or alcohol testing plan for the employee; 

• Providing the Company and the employee with recommendations for continuing education 

and/or treatment. 

Return-to-Duty Testing 

If the Company decides to permit the employee to return to the performance of safety-sensitive 

functions, the Company must ensure that the employee takes a return-to-duty test. The return-toduty test cannot occur until: 

• The employee has been evaluated by a SAP to determine what education and/or treatment the 

employee needs to resolve problems related to alcohol or drug use; 

• The employee has successfully complied with the prescribed education and/or treatment; 

• The employee has been re-evaluated by the SAP to ensure that the employee has properly 

followed the education and/or treatment program. 

Follow-Up Testing 

• A SAP must establish a written follow-up testing plan for each employee who has committed a 

DOT drug or alcohol regulation violation and who seeks to resume the performance of safetysensitive functions. The SAP does not establish this plan until after it is determined that the 

employee has successfully complied with the education and/or treatment recommendations. 

• The SAP must present a copy of the follow-up testing plan directly to the Company's DER. 

• The SAP is the sole determiner of the number and frequency of follow-up tests and whether 

these tests will be for drugs, alcohol, or both, unless otherwise directed by the appropriate DOT 

agency regulation. For example, if an employee had a positive drug test, but the SAP evaluation 

or the treatment program professionals determined that the employee has an alcohol problem 

as well, the SAP should require that the employee have follow-up tests for both drugs and 

alcohol. 

• The SAP must, at a minimum, direct that the employee be subject to six (6) unannounced 

follow-up tests in the first 12 months of safety-sensitive duty following the employee's return to 

safety-sensitive functions. The SAP may, however, require a greater number of follow-up tests 

during the first 12-month period of safety-sensitive duty. 

• The SAP may also require follow-up tests during the 48 months of safety-sensitive duty 

following this first 12-month period. The SAP is not to establish the actual dates for the follow-up 

tests he/she prescribes. The decision on specific dates to test is the responsibility of the 

Company. 

• The Company will not impose additional testing requirements on the employee that go beyond 

the SAP's follow-up and random testing plan. 

Ver. 3114 12 
INFORMATION ON DRUG ABUSE AND ALCOHOLISM 

As indicated in the introduction, drug use and alcohol abuse can have a serious impact on everyone. 

Either can negatively impact your health, work, personal life and the lives of others. The following 

information should assist you in identifying individuals at risk and establishing a track to recovery 

either for yourself or for someone you know. 

Effects of drug and alcohol on a person's health, work and personal life 

The following represent some of the potential effects that drug and alcohol use may have on the user: 

Workplace 

• May cause the employee to feel capable of handling tasks that are too much or too dangerous . 

• May cause lateness and absenteeism, increasing the workload of others 

• May cause crime on the job, including theft of Company and personal property 

• May cause major errors in the work performed, risking harm to the employee, coworkers and 

customers 

Health 

• Neurological problems, including dementia, anxiety and suicide 

• Cardiovascular problems, include hypertension 

• Increased cancer risk 

• Liver diseases, including alcoholic hepatitis and cirrhosis 

• Sexual dysfunction 

Personal life 

• Alcohol can also destroy relationships, lead to serious problems with the law (e.g., drunk 

driving}, and even cause harm to the people you love 

• If drinking affects your work life, it could lead to job loss and all of the financial problems that 

would follow 

Signs and Symptoms of a drug and/or alcohol problem 

Any one or more of the following signs may indicate a drug and/or alcohol problem: 

• Appears fearful, anxious or paranoid for no reason 

• Blackouts or the inability to remember what has happened 

• Cold, sweaty palms; shaking hands 

• Lack of motivation; appears lethargic or "spaced out" 

• Pattern of absenteeism with vague excuses 

• Red, watery eyes; pupils larger or smaller than usual; blank stare 

• Regular (or daily) use or consumption 

• Secretive or suspicious behavior 

• Sudden mood swings, irritability or angry outbursts 

• Unexplained need for money; stealing money or items 

Ver. 3114 13 
UAS FLYING HOURS LOG BOOK 

PERSONAL DETAILS 

NAME 

ADDRESS 

PHONE 

MOBILE 

EMAIL 

DOB 

ARN 

Version 1 Page 11 19 March 2014 
UAS FLYING HOURS LOG BOOK 

FLIGHT RECORD 

YEAR AIRCRAFT 

MONTH DAY TYPE REG 

--- --- ---

Signature ..................................................... . 

page ... of ... page 

Version 1 

ROUTE/REMARKS HOURS 

Totals brought forward 

Page 12 19 March 2014 
UAS FLYING HOURS LOG BOOK 

SIMULATOR RECORD 

INSTRUCTOR/TEST 

DATE SIMULATOR OFFICER TASK, DUTY OR PRACTICE SIM TIME - -- - - -·· --------------- -------

Signature ......................................... . 

page ... of ... pages 

Version 1 Page 13 19 March 2014 
AIRCRAFT SPECIFICATION AND TECHNICAL DATA 

Example Multi Rotor 

Manufacturer DJI innovations 

Model DJ I Flame Wheel 650 

Control System DJI Wookong 

TX Futaba (Model 

Number) 

Max Weight 2.5KG 

Motors DJI 2212-920kv 6 

Propellers 12*6 Carbon 6 

ESC 30 Amp 400 Hz Opto 6 

Battery 3S 5000 35C Endurance 1Om 2C Charge rate Max 

Battery 3S 3500 35C Endurance 6m 2C Charge rate Max 

Data Link DJI2.4 Ghz 

Max Wind Speed This should reflect 

manufactures 

specification if given. 

Example Fixed Wing 

Manufacturer BEVRC 

Model Skywalker 

Control System Ardu Mega Pilot 2.5 

TX Futaba 9CAP 

Servos 9Gram 1.5KG 4 

Data Link 3DR Radio System 

Wingspan 1680mm 

LenQth 1180mm 

Wing Area Optional 

WinQ Loading Optional 

Max Weight 1800g 

Motor 35mm 850-1300kv 

Brushless Outrunner 

Speed Controller 40Amp 

Servo 9Q 1.5kQ torque 4 

Battery 5000 4s 35C 2C Charge rate Max 

Max Wind Speed 25kph 

Endurance 40M max 

Version 1 Page 14 19 March 2014 
Example Helicopter 

Manufacturer 

model 

Control ~ystem DJI ACE one 

TX JR 3810 

Servos JR 8717 Except tail 

Servos JR 8900G Tail 

Data Link Nil 

Rotor Sj)an 1563mm 

Length 1360 

Max Weight 5000g 

Motor OS Speed 91 HZ-R 

30 

Fuel 67% Methanol 

15% nitro 

18% Synthetic 

Battery Zippy Flightmax 

2500mAh LiFe 

Receiver pack 

Max Wind 25Kph 

Endurance 12M in 

Version 1 PagelS 19 March 2014 
I • i 

Pre-Flight- Multi Rotor 

Visual check of airframe (including landing gear) 

Motors Free 

battery secure 

no loose leads, 

All antennas secure. 

Propellers - no damage, secure 

Role equipment secure 

Control TX - Check Antenna, 

If needed ground station powered and on line 

Control TX on, Voltage sufficient, correct model selected. 

TX switch Positions set Throttle closed. 

RPA battery voltage sufficient. See unloaded voltage table 

Power RPA (Use caution- Remain clear of blades) 

Role equipment operational 

Monitor RPA for indications of flight readiness. Satellite lock etc. 

Record time 

Lift off, Check Controls, Fly away. 

For Ground Station operations relevant checks will need to be added. 

P t OS-Fl" IQ ht - M u If I R t o or 

Observe normal motor rundown 

Record time 

Motor and Speed-controller temperature normal 

Battery temperature normal 

If applicable- Disconnect ground station 

If applicable- Disconnect role equipment 

De power RPA 

Control TX off 

Visual check of airframe (including landing gear) 

Motors Free 

battery secure 

no loose leads, 

All antennas secure. 

Propellers - No Damage, Secure 

Role equipment secure 

Version 1 Page IG 19 March 2014 
Pre-Flight- Fixed Wing 

Observe normal motor rundown 

Record time 

Motor and Speed-controller temperature normal 

Battery temperature normal 

If applicable - Disconnect ground station 

If applicable- Disconnect role equipment 

De power RPA 

Control TX off 

Visual check of airframe (including landing gear) 

Motors Free 

battery secure 

no loose leads, 

All antennas secure. 

Propellers - No Damage, Secure 

Role equipment secure 

Controls correct sense/no binding/steering 

Range check 

After Start for gas/glow 

Engine tuning 

Engine response 

Record time 

Post Flight- Fixed Wing 

Observe normal motor rundown 

Record time 

Motor and Speed-controller temperature normal 

Battery temperature normal 

If applicable - Disconnect ground station 

If applicable- Disconnect role equipment 

De power RPA 

Control TX off 

General visual check of RPS overall for obvious defects or damage sustained in 

flight 

Version 1 Page 17 19 March 2014