# Shawn Maylen, DBA Silicon Valley UAV

Address: Att: Shawn Maylen 1052 Metro Circle Palo Alto, CA. 94303 Info@SiliconValleyUAV.com 408-355-0216

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, D.C. 20590 April 12, 2015 Re: Petition ofShawn Maylen I 

### DBA Silicon Valley UAV for an Exemption Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 Dear Gentlemen: Pursuantto Section 333 oftheFAA 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 AviationRegulations ("FARs") identified below, to allow commercial operations ofsmall unmanned aerial vehicles 

### (i.e. "small unmanned aircraft" or "UAS/UAV"). The exemption is requested based on information inthis petition, as well as the accompanying Silicon Valley UAV Flight Operations Manual ("FOM") and the Pre I 

### PostFlight Checklists for the UAS identified and incorporatedbyreference into Section 2 ofthe Flight Operations Manual. I the petitioner submitthese supportingmaterials as confidential documents under 14 C.P.R. 

### § 11 .35(b); as they contain confidential commercial andproprietary information that Petitionerhas not and will not share with others. Similarly, these documents contain operating conditions andprocedures that are not available to the public and are protected from release underthe Freedom of informationAct, 5 U.S.C. 

### § 552 

### etseq., and any other requirements established by the FAApursuantto Section 333 oftheFAA Reform Act. Foryour convenience, the petition is organized as follows: 

### I. Description ofPetitioner II. Types ofOperations A. Requestto Use UASs for R&D atTest Sites Owned or Controlledby ShawnMaylen 

### I SiliconValleyUAV.

### U.S. Department ofTransportation April12, 2015 Page2 B. 

### Request to Use UASs for Survey and Inspection ofDamage After Casualty Events C. Requestto Use UASs for Risk Assessment, RiskManagement, Loss Control, Surety & SecurityPerformance III. Relevant Statutory Authority IV. SiliconValley UAV/ShawnMaylen Proposed UAS Operations Meetthe Requirements of Section 333 ofthe ReformAct V. Regulations From WhichExemption is Requested A. 14 C.P.R. 

### Part 21, SubpartH- 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 IdentificationRequirements D. 14 C.P.R.§ 91.9(b)(2): Civil Aircraft FlightManual inthe 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 AircraftAirworthiness F. 14 C.P.R.§ 91.103: Preflight Action G. 14 C.P.R. 

### § 91.109(a): FlightInstruction 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 FlightinVFR 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/ShawnMaylenwas founded in 2014 in California. I am a competent sub 20 lbs. UASIUAV pilot with 28+ months ofresearch, development, and testing ofmultiple flight controllers, ESC's, powerdistribution systems, as well as programing experience ofmultiple best-ofbreed UAS flight controllers. SiliconValley UAV/ShawnMaylenhas over 510 hours of UASIUAV flying experience onmultiple UAS platforms under 20 pounds overthe past4 years. Silicon Valley UA V/Shawn Maylenhas the ability to competently applythe stated experience/skill-sets/flight-time for commercial application safely. SiliconValleyUAV/Shawn Maylen's background also includes 14 years

### U.S. Department ofTransportation April12, 2015 Page 3 ofwilderness I

### urban search & rescue training, effective use ofGPS 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 includingBanking, Real Estate, Travel, and Automotive. SiliconValley UAV/ShawnMaylennowprovides free UASIUAV R&D services. We have a 100% safety record overthe past4 years, and my capabilities are atthe forefront ofpurpose-built UAV technology designed specificallyfor each customer's unique mission protocols. I can service a wide variety ofcommercial, government, and educational requirements immediately as well as ensure the best-of-bread return-to-home & imagerytechnology available to the commercial market. SiliconValleyUAV/ShawnMaylen is committedto remaining atthe forefront of 100% safe commercial application ofUAS I 

### UAV technology. In this regard, SiliconValleyUAV/Shawn Maylen will continually examinethe latesttechnology 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 ofgreat value to SARteams. SiliconValleyUAV/ShawnMaylen expectto use ourUAS'sto support ourclients extensive systems ofrisk assessment, risk management, loss control, logistics capabilities/tools, and surety performance programs with free imagery. SiliconValley UAV/ShawnMaylen's primary focus is safety first, as well aspreventing accidents, terrorism, as well as interdiction ofsecurity events before theyhappen. SiliconValleyUA V/ShawnMay lenwill provide a unique aerial tool combined with best-of-breed ground based technologies to assess and enhance safety in places that are inaccessible orhave troubling access points for personal inspection or inspectionby expensive manned aircraft. SiliconValley UAV/ShawnMaylenhas all the current skill-sets and equipment necessary to offer a high degree I 

### level ofsafety and effective UASIUAV services to commercial entities & first responderteams. Well have the abilityto call on an array ofhighly experienced aviation system professionals/mentors to fly each specific mission/flightprofile correctly, and in a mannerthatwill deliver or exceed an EquivalentLevel ofSafetythe FAA currentlyprescribes for mannedrotary aircraft. SiliconValleyUAV/ShawnMaylenhas developed a keen knowledge-base ofmulti-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 ofthorough planning for both normal operations and for contingencies plans thatmight affectthe safety offlight, people, and physical property is a core philosophy ofSiliconValleyUA V/ShawnMay len. Petitionercontact information: Silicon Valley UAV/Shawn Maylen 1052 Metro Circle, Palo Alto, CA. 94303 I 

### 408-355-0216- info@SilicinValleyUAV.com

### U.S. Department ofTransportation April12, 2015 Page4 II. TYPES OF OPERATIONS A. Requestto Use UASs for R&D imagery at Test Sites Owned or Controlledby Silicon ValleyUAV/ShawnMaylen- SiliconValleyUAV/ShawnMaylen is requesting exemptions pursuantto Section 333 to conductresearch and development at SiliconValley UA V/ShawnMay lencontrolled and carefully selected properties owned ormanaged facilities. Testing facilities will notbe open to the public and access will be restricted to SiliconValley UA V/ShawnMay lenemployees orconsultants engaged in R&D flying or R&D-related work. UAS testing will occur outside navigable airspace at an altitudes of400 feet AGL orless. Thetest sites will enable SiliconValleyUA V/ShawnMay lento evaluate howthe UASs will operate and capture images overvarious types ofbuildings, cell sites, towers, stadium events, mass casualty events, and in various weather 

### Itechnical conditions. SiliconValleyUA V/ShawnMay lenwill use thesetests to, among otherthings, develop newpotential uses for UASs that support SiliconValley UAV/Shawn Maylen's currentrelationships orpotential clients core business, refine operational procedures 

### Iprotocols, and test differentpayloads and sensors. Thetest areas will also be used for maintenance evaluation and pilottrainingpurposes. SiliconValleyUAV/ShawnMaylen's efforts are focused on meetingthe needs ofits clients and enhancingthe SiliconValley UA V/Shawn Maylenbusiness processes. Specifically, SiliconValley UAV/ShawnMaylen will evaluate howto utilize the employed UAS'sto assess and evaluate risks associated with ordamage to clients interest. B. Requestto Use UASs for pre-emptive surveys and inspection ofequipment, infrastructure, bridges, roadways, fire abatement, cell sites, commercialradio towers, as well as damage of these structures 

### I equipment after Casualty Events. SiliconValley UAV/Shawn Maylen also seeks exemption pursuantto Section 333 to conduct inspections ofits own clients propertythat has suffered damage. Certaintypes ofproperty damage are difficult and dangerous for a human to physically inspect, particularlywhere the structural integrity has been compromised. The alternative ofusing conventional aircraft orhelicopters carries with it a large expense, operational difficulties, and added risks. SiliconValleyUAV/ShawnMaylenwill face unique demands during and immediately following catastrophic events ornatural disasters. SiliconValley UAV/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 ofrecovery and rebuilding. As partofthis effort, SiliconValley UAV/ShawnMaylen is committedto partnering with appropriate federal, state and local governments and first responder organizations to ensure full cooperation and coordination withtheirneeds. This will include information sharingthat canfurther assist first responders & 

### proper UAS development/deployment. C. Requestto Use UAS's for Filming, RiskAssessment, RiskManagement, Loss Control, and Surety Performance. SiliconValley UAV/ShawnMaylenis a already a leader in providing services to customers aimed at ensuring accidents or security eventnever occur. It is SiliconValley UAV/Shawn Maylen'sphilosophyto manage Safety and Risks veryproactively. SiliconValley UA V/ShawnMaylenwill apply experience and ourhyper evolved UAV/UAS safetyprotocols toI •



### U.S. Department ofTransportation April12, 2015 Page 5 evaluate a client's unique loss potential and may recommend costeffective, professional and measurable methods to manage security & 

### risks. SiliconValleyUA V/ShawnMay lenhas a vastinventory ofcontrol services that can be customized to address Security issues, management, crew 

### I employee safety, business continuity and crisis management in all area ofourbusiness. As part ofour Safetyprogram, SiliconValley UA V/ShawnMay lenunderstands that UASs will be an invaluable tool that will permitrisks to be assessed and mitigated in places where it is impossible orunsafe for a humanto conduct an assessment. In addition, UASs provide an opportunity for ongoing documentation and monitoring ofrisks and will permitnewmitigation strategies to be applied iforas necessary. As set forth in the attached Operations manual, these flights will be flown under a strict set ofguidelines. They will be flown only overthe clients property or overpropertywhere permission has been obtained from the owner, and strict safetymeasures will be in place to ensure thatthere is no exposure to members ofthe 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 ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 333 ofthe Reform Act, the FAA Administratoris to permitunmanned 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 ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe U AS withinthe visual line ofsight ofthe operator. 1 

### Additionally, the FAAAdministratorhas general authorityto grantexemptions from the agency's safetyregulations 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, 

### etseq.). A party requesting an exemption must explain the reasons whythe exemption: ( 1) would benefitthe public as a whole, and (2) would not adversely affect safety (orhow it would provide a level ofsafety at least equal to the existing rules). 

### See 14 C.F .R. § 11.81 (petitions for exemption).

1

### !d. at 333(b)(1).

### U.S. Department ofTransportation Apri112/2015 Page6 IV. SiliconValley UAV/ShawnMaylenPROPOSED OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORMACT The proposed operations inthis Petition for Exemption qualify for expedited approval under Section 333 ofthe Reform Act. Each ofthe statutory criteria and otherrelevantfactors are satisfied. 

### A. Approval is Warranted Based onthe UASs Size, Weight and Operational Capability SiliconValleyUAV/ShawnMaylenwill employthe UASs identified in Section 2 ofthe accompanying Operations Manual. These UAS will be used for all ofthe operations as set forth in the Operations Manual. Each ofthese UASs have characteristics in commonthatwarrant approval. All ofthe UASs will be limited to a maximum horizontal orvertical flight speed during standard operations of5 feet per second. Vertical ascent speed will be limitedto 15 m.p.h., andnone ofthe devices have a weight in excess of20 pounds. Each ofthe UASs shall incorporate an integrated GPS system to calculate the UASs' position and height andto relaythat informationvia Real time connectionto the operator. All UAS's will utilize "failsafe" mode whichthus permitsthe vehicle to return topredetermine locationto prevent injury or damage. All ourUAS systems permits the vehicleto returnto a predetermined location and land autonomouslyto prevent injury or damage. B. Approval is Warranted Based onthe Operational Restrictions SetForthinthe SiliconValleyUAV/ShawnMaylenFlight Operations Manual andthe manufacturers' maintenance and flight manuals. These documents in ourpossession contain all ofthe procedures and limitations necessary to successfully perform R&D and inspections ofSiliconValley UAV/ShawnMaylen customers property before, during and after catastrophes orother loss events. To assistthe FAA in its safety assessment ofSiliconValley UAV/Shawn Maylen operations, below is a summary ofoperational limitations and conditions which will ensure a level ofsafety equal to or exceedingthe level ofsafetyfor operations conducted undercurrentregulatory guidelines: 1. The UASs employedby SiliconValleyUAV/ShawnMaylenwill weigh 20 pounds or less. 2. Flights will be operatedwithin line ofsight ofa pilot and observer. 3. Maximum total flight time for each operational flight willbe limitedto an amount of time the UASs can be flown and land and still maintain a reserve batterypower ofno less than 25%. 4. Flights will be operated at an altitude ofno more than 399 feet A G L and will not be conducted within navigable airspace. 5. Flights will be operated at a lateral distance ofatleast 100 feet from anypersons orproperty not associated withthe operation who have not givenpriorpermission.

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6. Flights will be limitedto a vertical and horizontal speed ofno more than 5 feet per second. 7. Minimum crew for each operation will consist ofthe UAS Pilot, one ormore Visual Observers ("Spotter") as necessaryto safely conductthe mission, and a Sensor Operator, ifthe sensorrequires human direction orcontrol. 8. Each additional new UAV 

### I UAS pilotwill have a minimum of200hours previous amateur/noncommercial UAS/UAV flights, and be enrolled in training to pass the FAA written knowledge test, and will have sufficient experience and recurrenttraining to safelyconduct all commercial UAS flights in accordance withthe standards set forth in the Operations Manual. 9. The observer designated for any operation will be in constantvoice contactwith the pilot. 10. The UASs will operate in accordance withthe safety and operational requirements of theirrespective Manuals. 11. Priorto 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 andpermits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire orother appropriate governmental agencies. , 13. lfthe UAS's loseprimary controller uplink/ GPS, the UAS will have the capability to autonomouslyreturnto a pre-determined safe location withinthe operational area and land. 14. Contingency plans will be inplaceto safelyterminate flight ifthere is a loss of communication betweenthe pilot andthe observer. 15. The UASs will have the capabilityto abort a flight in case ofunpredicted obstacles or emergencies. 

### V. REGULATIONS FROMWHICHEXEMPTION IS REQUESTED The Federal AviationAct 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 interrelatedprovisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes ofconductingthe 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 safeguardsthatPetitioner has established which will ensure a level ofsafety betterthan orequal tothe rules from which exemption is sought.3

### U.S. Department ofTransportation April12, 2015 Page 8 A. 

### 14 C.F.R. Part21, Subpart H- Airworthiness Certificates and 14 C.F.R. 

### § 91.203(

### a)(1) The FAAhas statedthatno exemption is needed from this section ifa finding is made underthe Reform Actthatthe UAS selectedprovides an equivalent level ofsafetywhen comparedto aircraft normally used for the same application. These criteria are met, and therefore no exemption is needed. See Grant ofExemptionto Astraeus Aerial, DocketNo. FAA2014-0352 at 13-14,22. If, however, the FAA determines thatthere are some characteristics of the chosen UAS that fail to meetthe requirements ofthe Reform Act, an exemption is requested. 

### EquivalentLevel ofSafety The UAS's identified in Section 2 ofthe Operations Manual are safe whentaking into account their size, weight, speed, and operational capability. As set forth in Section II, 

### Supra, all ofthe UASs weigh less than 20 pounds and will be flown at less than 5 miles perhour and completely outside controlled airspace. Additionally, the UAS's carry neitherpilots nor passengers, carryno explosive materials and orflammable liquid fuels, and operate exclusively within theparameters stated in the Operations Manual. zSee 49 U.S.C. 

### § 44701(f) (authorizingthe grant ofexemptions from requirements ofregulations prescribed pursuantto Sections 44701(a) and (b) and Sections 44702- 44716). 3

### See 14 C.F.R. § 11.81(e), which requires a petition for exemptionto include: The reasons why grantingthe exemption would not adversely affect safety, orhowthe exemption would provide a level ofsafety at least equal to that providedbythe rule from which you seek exemption. Operations underthis exemption will be closely controlled and monitored bythe operator and will be conducted in compliance with local public safety requirements, to provide security for the area ofoperation. SiliconValleyUAV/ShawnMay lenwill also provide the FAAwith advance notice ofall operations viaNOTAMS and coordinationwiththe local FSDO. In all cases, the UASs operated underthe proposed conditions, will be at least as safe as, orsaferthan conventional rotorcraft operating with an airworthiness certificate withoutthe restrictions and conditions ofthe proposed UAS operations. The aircraftthemselves do notneed a means to communicate with otheraircraft orA TC, because those capabilities will be possessedbythe 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 onthe UAS because it will be operated atall times byvisual line-of-sight. !

### d.

### U.S. Department ofTransportation April12, 2015 Page 9 B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft 

### 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extentthe Petitioner's UASs would otherwise require certification underPart 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 AircraftFlightManual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part45 ofthis chapter. • 14 C.P.R.§ 45.23(b), Markings ofthe Aircraft, states: When marks include onlythe Roman capital letter "N" andthe registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operatormust also display on that aircraft neareach entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches normore than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable.- Silicon Vally UAV makings will beprominently displayed

• 14 C.P.R. § 45.27(a), Rotorcraft, states: Eachoperator ofa rotorcraft must display onthat rotorcraft horizontally onboth surfaces ofthe cabin, fuselage, boom, ortail the marks requiredby§ 45.23. In a previous Grant ofExemption, the FAA determinedthat exemptionfrom these requirements was warrantedprovidedthatthe aircraft "have identification (N-Number) markings in accordance with 14 CPRpart45, Subpart C ifthe markings are as large as practicable." FAA DocketNo. FAA-2014-0352. Equivalent Level ofSafety 

### SiliconValleyUA V/ShawnMaylen will mark all aircraft withtheirN-Numberin a prominent spot onthe fuselage withmarkings that are as large as practicable.

### U.S. Department ofTransportation April12, 2015 Page 10 D. 14 C.F.R. § 

### 91.9(b)(2): Civil Aircraft FlightManual in the Aircraft and 14 C.F.R. §

### 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

### Pursuantto 14 C.F.R. § 

### 91.9(b)(2): (b) No personmay operate a U.S.-registered civil aircraft- (2) Forwhich anAirplane orRotorcraft FlightManual is required by§ 21.5 of this chapter, unless there is available inthe aircraft a current approved Airplane or Rotorcraft FlightManual, approvedmanual material, markings, andplacards, or any combinationthereof. Pursuantto 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no personmay operate a civil aircraftunless it has within itthe following: (1) An appropriate and current airworthiness certificate

... (b) No personmay operate a civil aircraft unless the airworthiness certificate required byparagraph (a) ofthis section ora special flight authorizationissuedunder § 91.715 is displayed atthe cabin or cockpit entrance so that itis legible to passengers orcrew. SiliconValley UAV/ShawnMaylendoes notrequest an exemption from this section but instead notifies the FAA that, in accordance with FAA Office ofChiefCounsel's Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept atthe control station or withthe PIC during flight. The ChiefCounsel's Office has held that for all UAS operations, this alternate method constitutes full compliance withthe regulations. E. 14 C.F.R. § 

### 91.7(a): CivilAircraftAirworthiness 

### Petitioner seeks an exemption from 14 C.P.R.§ 

### 91.7(a), which requires that a civil aircraft be in airworthy conditionto be operated. The FAA has statedthat no exemption is required to the extentthatthe requirements ofPart 21 are waived orfound inapplicable. Accordingly, Petitionerrequests thatthe requirements for Section 91.7 be treated in accordance with Section V(A), supra. F. 14 C.F.R. § 

### 91.103: PreflightAction 

### 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 boardthe aircraft. While the PIC will be familiar with all information necessaryto safely conductthe flight, an exemption is requestedto the extentthat an FAA-approved Flight manual is required.

### U.S. Department ofTransportation April 12, 2015 Page 11 

### G. 14 C.F.R. 

### § 91.109(a): FlightInstruction Petitioner seeks an exemption from 14 C.P.R.§ 91.109(a), which providesthat "[n]o person may operate a civil aircraft (except a manned free balloon) that is beingused for flight instruction unless that aircrafthas fully functioning dual controls." UASs and remotelypiloted aircraft, by their design, do nothave functional dual controls. Instead, flight control is accomplishedthrough the use ofa device that communicates withthe aircraft viaradio communications. 

### EquivalentLevel ofSafety Given the size and speedofthe UASs employed by SiliconValleyUA V/ShawnMay len, an equivalent level ofsafe training can still be performed without dual controls because no pilot or passengers are aboardthe UASs, and all persons will be a safe distance away inthe eventthatthe UASs experiences any difficulties during flight instruction. In addition, Petitionerwill conductflight training at its Research and Developmenttest sites, which are located on its own property. These training flights will be conducted in a sterile area and will otherwise complywith the provisions in the Operations Manual for flights atthe R&D facility. Accordingly, SiliconValleyUA V/Shawn Maylenproposed method ofoperation provides superior levels ofsafety. 

### H. 14 C.F.R. 

### § 91.119: Minimum SafeAltitudes 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 anyperson, vessel, vehicle, or structure in non-congested areas. 

### See 14 C.F.R. 

### § 91.119(c). Section 91.119(d) allows for a helicopterto operate atless than those minimum altitudes when it canbe operated "without hazard to persons orproperty onthe surface," providedthat "each person operatingthe helicopter complies with any routes or altitudes specificallyprescribed for helicopters by the FAA." 

### EquivalentLevel ofSafety Comparedto flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack offlammable fuel, anyrisk associated with these operationsis far less than those thatpresently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UASs, as well as the location where it is operated. In orderto avoid any riskto aircraft, flight operations will be restricted to 400' AGL orbelow. As set forth in the Manuals, the UASs will be operated in a restricted area, away from persons or structures notinvolved inthe 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 altimeterthat is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extentthat the UASs do nothave a barometric altimeter, but rather a GPS altitude read out.

### U.S. Department ofTransportation April 12, 2015 Page 12 Equivalent Level ofSafety 

### The FAA has stated that an equivalent level ofsafety can be achieved ifthe UASs will be operated at400' AGL orbelow and within visual line-of-sight in addition to GPS based altitude information relayed inreal time to the operator. 

### See Grant ofExemptionto Astraeus Aerial, DocketNo. F AA-2014-0352. As the attached Operations Manual indicates, the chosen UASs meets these requirements, and a zero altitude initiation pointwill be obtainedpriorto flight.

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

### Petitionerrequests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight in VFRconditions. Section 91.151 states: (a) No person maybegin a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assumingnormal cruising speed

- (1) Duringthe day, to fly after that for at least 30 minutes; or (2) Atnight, to fly afterthat for at least45 minutes. Here, the technological limitations on UAS batterypowermeans that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. SiliconValley UAV/ShawnMaylenproposes that all flights comply with this requirementby mandatingthatthe aircraftbe safely landedwithno less than 25% ofbattery life remaining. Equivalent Level ofSafety 

### The FAAhas statedthatan equivalent level ofsafety is provided ifthe UAS flight is terminated with at least 25%reserve battery power still available. 

### See Grant ofExemptionto Astraeus Aerial, DocketNo. FAA-2014-0352. The Operations Manual conforms to this limit, providing an equivalent level ofsafety. 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) (statingthat each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpartE ofthis part and shall betweenrequired inspections

... have discrepancies repaired as prescribed in part 43 ofthis chapter"). An exemption from these regulations is neededbecause Part 43 andthese sections only applyto aircraft with an airworthiness certificate, which the U AS will not have.

### U.S. Department ofTransportation April12, 2014 Page 13 Equivalent Level ofSafety 

### An equivalent level ofsafety 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 notbe conducted unless a flight operations checklist is performedthat includes all ofthe aircraft's components. The Operations Manual also sets requirements for maintenance log books and record keeping as well as routine andpost-flightmaintenance. The Manual sets requirements for both annual maintenance andpreventative maintenance based on hours offlight. L. 14 C.F.R. § 

### 61.113: Private PilotPrivileges And Limitations 

### Petitioner seeks exemption from 14 CFR 

### § 61.113, which restricts private pilot certificate holders from flying aircraftfor compensation orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure thatthe skill and competency ofany PIC matches the airspace in whichthe PIC will be operating, as well as requiring certifications ifthe private pilot is carryingpassengers or cargo for hire. In this case, while the UASs will be operated as part ofa commercial operation, it carries neitherpassengers nor cargo. In the Grant ofExemption in FAADocketNo. FAA-2014-0352, the FAA determinedthat the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrantthe addition cost and restrictions attendantwith requiring a the PIC to have a commercial pilot certificate and class II medical certificate. The restrictions SiliconValley UAV/ShawnMaylenhas placed on its UAS operations meet or exceed the restrictions similarly imposed onAstraeus Aerial in FAA DocketNo. FAA-2014-0352. Silicon ValleyUAV/ShawnMaylenwill operate in a sterile area away from persons andproperty not involved in the operation. It

### will be flown based on VLOS at400' AGL orbelow. A NOTAM will be issued between48 and 72 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO. Equivalent Level ofSafety 

### In addition to these flight restrictions, SiliconValley UAV/ShawnMaylenwill further ensure safe operation byrequiringthat any PIC be thoroughly versed not only in airspace and communication issues pertainingto all aircraft operators butalso in the unique aspects ofUAS flight. Pilots will also be required to conducttraining flights at SiliconValleyUAV/ShawnMaylenResearch and Development facilities to obtain flight experience with UAS specific models used for commercial operations in particular. Petitionerbelieves thatthis system will provide a higher level ofcompetency and proficiency for its pilots.1'



### U.S. Department ofTransportation April12, 2015 Page 14 

### VI. DRUG ANDALCOHOL PROGRAM SiliconValley UAV/ShawnMaylenhas policies in place to ensure that no person may act as a PIC, observer, or sensor operator ifthey are under the influence ofalcohol ordrugs. We have a no alcohol policy 24 hrs. priorto flight. Policy attached

... 

### VII. PUBLIC INTEREST Granting SiliconValley UAV/ShawnMaylenexemptionrequest furthers the public interest. National policy setby 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 oflarge 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, SiliconValleyUAV/ShawnMaylen intended uses for the UASs have real-world benefits for SiliconValleyUA V/ShawnMaylenpotential clients, current relationships, and future education partners. SiliconValleyUAV/ShawnMaylenwill be able to inspect and survey its clients property/assets before and after a casualty event safely, thoroughly, and efficiently. The work ofSiliconValley UAV/ShawnMaylenwill aid its clients in the process ofsafe UAS production filming, as well as recovery and rebuilding. The UAS work will also aid SiliconValley UA V/ShawnMay lento provide top-tierrisk assessment, risk management, loss control, and surety performance programs by providing safe, efficient, and reliable UAS/UAV services. These programs prevent accidents and injuries, andthere is a strongpublic interest in makingthese programs more effective through the use ofUASs. Finally, by coordinating andteaming with federal, state and local governments after a disaster, SiliconValley UAV/ShawnMaylencan nowprovide valuable aerial imagery/information to first responders and governmententities which will assist with aid & 

### deployment ofa propercoordinate disasterresponse. 

### VIII. PRIVACY All flights will be conducted in accordance with any federal, state or local laws regarding privacy. 

### IX. FEDERAL REGISTER SUMMARY Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determinedthatpublication is needed: SiliconValleyUA V/ShawnMay len seeks an exemption from the following rules: 14 CFRPart21, SubpartH; 14 CFRPart 27; 14 CFR45.23(b); 14 CFR § 61.113; 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR91.119; 14 CFR

### U.S. Department ofTransportation October 31, 2014 Page 15 91.121; 14 CFR 91.151(a); 14 CFR91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR91.407(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b). The exemption will enhance safety byreducing risk to the general public andproperty owners from the substantial hazards associated withperforming equivalentworkwith conventional aircraft and rotorcraft. X. CONCLUSION Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximityto airports and populated areas, operation within visual line ofsight, andnational security-provides more than adequatejustification for the grant oftherequested exemptions to permit SiliconValleyUAV/ShawnMaylento operate the selected UASs andprovide R&D and inspections during and after casualty events. Granting the requested exemption will benefitthe public interest as a whole in many ways, including (1) significantly improving safety andreducing riskby alleviating human exposure to danger, and (2) improvingthe quality ofservices and decreasing operating costs comparedwith conventional flight operations. Ifyou have any questions orrequire any additional information, please do not hesitateto Call or email. SiliconValleyUA V/ShawnMay len 408-355-0216 info@SiliconValleyUAV.com shawnmaylen@Gmail.com Attachments: SiliconValley UA V/ShawnMay len Flight Operations Manual and Pre 

### IPostFlight CheckLists (submitted as a Confidential Documents under 14 C.P.R.§ 11.35(b) and exempt from disclosure underthe Freedom ofinformation Act, 5 U.S.C. § 552 

### etseq., and any otherrequirements establishedby the FAA pursuantto Section 333 ofthe Reform Act); AircraftFlight and Maintenance Manuals as incorporated into the SiliconValley UAV /ShawnMaylen Operations Manual (submitted as a Confidential Document under 14 C.P.R. § 11.35(b) and exempt from disclosure underthe Freedom oflnformationAct, 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 outwith the utmost consideration ofsafetytowards all participants, spectators and property. At no time will UAS operations orflight profiles exceed the published operational limits ofany 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 outwithoutthe completion and adherence to all checklist items. Review of NOT AM's Priorto 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 ofsuch NOTAM's assessed. Review of Local Weather Forecast No flight operations shall commence until current local weatherforecasts have been reviewed and approved bythe PIC. Flight Logs Every UAS commercial ortrainingflight 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 duringthe activity being logged. Log entries shall reference the "N Number" of all relevant UAS aircraft. Use of Real TimeTelemetry Any UAS operated by Silicon Valley UAS shall be equipped with on-board real timetelemetry which shall provide, at a minimum, the following information: UAS horizontal and vertical airspeed Current GPS location Real time compass heading of UAS flight pathOn board batteryvoltage(s) Utilization ofthis state-of-the-art technology will insure that Silicon Valley UAV can maintain the highest level of safety duringthe operation ofanyflight 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 immediatelyterminated should any ofthe following conditions develop: Loss ofvideo down-link Loss ofprimary UAS telemetry down-link Batteryvoltage 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 ofground spectators into primary or secondary safety zones Minimum Personnel Required for Flight Operations Under no circumstances may flight operation may be undertaken withoutthe 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 ContingencyTakeoff

## I Landing Zones Flight operations may not commence unless and until a specific primary takeoffand landing site has been identified and marked within the PIC SafetyZone. Additionally, a secondary contingency landing site shall be clearly identified and, if possible, marked to inhibit incursion by local spectators. The minimum diameterforthe 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 flighttime as PIC operating UAS aircraft identical tothose operated by Silicon Valley UAV. Have passed a pre-employment drugtestwithin 90 days ofworkingwith 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 priorwritten 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 ofa designated flight spotter. Flight Profile Restrictions All Silicon Valley UAV flight operations must adhere to strictflight 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 forflight. Unless previously determined to be necessary, no battery charging will occur duringthe undertaking ofany 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 ofthe 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 flighttime. 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) forthe use of unmanned flying vehicles. Silicon Valley UAV recognizes thatthe regulatory environment surroundingthe commercial operation of UAV's is very dynamic. As such, Silicon Valley UAV maintains avigilant 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 memberwhile on the Company's premises, engaged in Company business, operating Company equipment, orwhile underthe authority ofthe 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, orwhile underthe authority ofthe 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 regulationsAspects ofthe 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 ofthis Drug and Alcohol Policy, the terms and conditions ofwhich 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 ofthis Drug and Alcohol Policy conflict with any provision contained in the Employee Handbook, the terms and conditions ofthis Drug and Alcohol Policy shall control. Violation ofany provision contained in this Drug and Alcohol Policy shall be deemed a violation ofthe 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 ACONTRACT OF EMPLOYMENT OR CONTAIN THE TERMS OF ANY CONTRACT OF EMPLOYMENT. THE COMPANY RETAINS THE SOLE RIGHT TO CHANGE, AMEND, OR MODIFYANY TERM OR PROVISION OF THIS POLICYWITH ORWITHOUT 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 ofthe date of issuance ofthis 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 ofthis 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 ofthe United States Secretary ofTransportation; • 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, orteam 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 motorvehicle as defined in Part 382 ofTitle 49 ofthe Code of Federal Regulations. Ifyou are not required to have a COL or you do not operate commercial motor vehicles, please be aware that you might experience minorvariations on howthese 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 underthe 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. Underfederal 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) Howeverthe company is not limited in the number ofsubstances they can test for and may include drugs that individuals legitimately and/ortherapeutically 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, orwhile underthe 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 orgreater. • 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 forwhich they performed a safety-sensitive function at or nearthe time ofthe accident. • Refusal to submit to a post-accident, random, reasonable suspicion, return-to-duty, or follow-up alcohol test.


### Definitions • Alcoholis defined as the intoxicating agent in beverage alcohol, ethyl alcohol, or other low molecularweight alcohols, including methyl or isopropyl alcohol. • Alcohol use is defined as the consumption ofany 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 ofthis Supplemental Drug and Alcohol Policy. Acknowledgement of Receipt ofthis Drug and Alcohol Policy shall be indication that the employee is subject to the policy. • GeneralApplicability: 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 ofthe following types ofdrug 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 motorvehicle operating on a public road in commerce, the involved employee shall be subject to a drug and alcohol test in the following circumstances:

• Ifthe accident involved the loss of human life; • Ifthe 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 ofthe accident; or • One or more motorvehicles 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 oftesting.
Reasonable Suspicion Employees shall be subject to reasonable suspicion drug and alcohol testing if a trained supervisor ortrained company official believes or suspects that the employee is under the influence ofdrugs 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 ofa 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 ofsafety-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 ofa Alcohol Testwith a Concentration Greaterthan .04 A covered employee who receives one (1) alcohol test with a result indicating an alcohol concentration of .04 or greaterwill be immediately removed from safety-sensitive duties. An employee who has a positive alcohol test cannot return to the performance ofsafety-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 greaterthan .04 will be subject to disciplinary action, up to and including termination. Consequences ofan Alcohol Testwith a Concentration Greaterthan .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 ofthe test. Notwithstanding the foregoing, an employee whose test results indicate an alcohol concentration greaterthan .02 will be subject to disciplinary action, up to and including termination. Consequences of Refusing to Submit to a Required Drug and/orAlcohol Test A covered employee who refuses to submit to a required drug and/or alcohol test orwho 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 ifyou: 

### 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 ofthe employee to appearfor 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 ifthe Company ordered or ifthe 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 forthe 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 orthe Company has directed; • Fail to cooperate with any part ofthe specimen collection process; • Fail, for an observed collection, to follow the instructions to raise and lower clothing and turn around; • Possess orwear a prosthetic or other device that could be used to interfere with the collection process ifthe employee is found to have orwear a prosthetic or other device designed to carry clean urine or a urine substitute; • Admit to the collectorto 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 testwithin 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 ofthe employee to appearfor 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 ofsaliva 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 ofthe insufficient breath procedures; • Fail to sign the certification statement at Step 2 ofthe Alcohol Testing Form (ATF); or • Fail to cooperate with any part ofthe 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 ofthe testing processes, safeguard the validity ofthe 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 ofthe DOT regulations must be· used forthe drug test. • The collection ofthe 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 ofthe specimen to a certified laboratory. • The employee should have and present positive identification to the collector. The employee may also request positive identification ofthe 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 accountfor 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). Ifthe employee requests the testing ofthe split, the MRO must direct (in writing) the lab to provide the split specimen to another certified laboratory for analysis. The employee will pay forthe testing ofthe 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 9result 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 hearthe 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 ofthe 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 ofthe 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 ofthe 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. • Ifthe 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. • Ifthe newtest 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 ofthe 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 ofthe 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 ofthe test. The STT or BAT must show the employee the device and its reading and enterthe result on the ATF. • Ifthe 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. • Ifthe reading on the ASD or EBT is 

### .02 or more, a confirmation test must be performed.



### Ver. 3114 10

### Confirmation Tests • Ifthe result ofthe 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 ofthe ATF. The BAT will provide the employee with Copy 2 ofthe form. • In the presence ofthe 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. Ifthe reading is greaterthan .00, the BAT will conduct one more air blank. Ifthe reading is greaterthan .00, testing will not proceed using the instrument. However, testing may proceed on another instrument. • The BATwill instruct the employee not to eat, drink, put any object orsubstance 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 ofthe 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 BATwill also explain that the test will be conducted at the end ofthe waiting period. Ifthe employee has disregarded the instruction, the BAT will so note in the "Remarks" section ofthe ATF. • If a BAT otherthan 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. • Ifthe employee does not sign the certification in Step 4 ofthe 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 ofthe form. • A breath alcohol test is invalid underthe following circumstances: • The EBT does not pass its next external calibration check (invalidates all test results of 0.02 orgreater 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 ortreatment through an employee assistance program for an employee who has violated a DOT drug and alcohol regulation. Ifthe 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 ofthe 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/ortreatment program (EAP); • Conducting a face-to-face follow-up evaluation to determine ifthe employee has actively participated in the education and/ortreatment 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 forthe employee; • Providing the Company and the employee with recommendations for continuing education and/or treatment. 

### Return-to-Duty Testing Ifthe Company decides to permit the employee to return to the performance ofsafety-sensitive functions, the Company must ensure thatthe 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/ortreatment; • The employee has been re-evaluated by the SAP to ensure that the employee has properly followed the education and/ortreatment 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 ofsafetysensitive 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 ofthe follow-up testing plan directly to the Company's DER. • The SAP is the sole determiner ofthe number and frequency offollow-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 subjectto 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 offollow-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 ofthe 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 eitherfor yourself orfor someone you know. 

### Effects of drug and alcohol on a person's health, work and personal life The following represent some ofthe 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 ortoo dangerous

. • May cause lateness and absenteeism, increasing the workload ofothers • 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 • Ifdrinking affects your work life, it could lead to job loss and all ofthe financial problems that would follow 

### Signs and Symptoms ofa drug and/or alcohol problem Any one or more ofthe following signs may indicate a drug and/or alcohol problem: • Appears fearful, anxious or paranoid for no reason • Blackouts orthe inability to rememberwhat 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

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## 11 19 March 2014

### UAS FLYING HOURS LOG BOOK FLIGHT RECORD YEAR AIRCRAFT

MONTH DAY TYPE REG



### --- --- ---

Signature

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Version 1 ROUTE/REMARKS HOURS

Totals broughtforward

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### UAS FLYING HOURS LOG BOOK SIMULATOR RECORD INSTRUCTOR/TEST DATE SIMULATOR OFFICER TASK, DUTY OR PRACTICE SIM TIME

- -- - - -·· --------------- -------

Signature

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### 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) MaxWeight 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 MaxWind Speed This should reflect manufactures specification ifgiven.
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 MaxWeight 1800g Motor 35mm 850-1300kv Brushless Outrunner Speed Controller 40Amp Servo 9Q 1.5kQ torque 4 Battery 5000 4s 35C 2C Charge rate Max MaxWind Speed 25kph Endurance 40M max

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### 14 19 March 2014Example 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 MaxWeight 5000g Motor OS Speed 91 HZ-R 30 Fuel 67% Methanol 15% nitro 18% Synthetic Battery Zippy Flightmax 2500mAh LiFe Receiver pack MaxWind 25Kph Endurance 12Min

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## I • i


### Pre-Flight- Multi Rotor Visual check ofairframe (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 setThrottle closed. RPA battery voltage sufficient. See unloaded voltage table Power RPA (Use caution- Remain clear of blades) Role equipment operational Monitor RPA for indications offlight 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 Fl" ht M If R t

OS- IQ 

## - u I 

### o or Observe normal motor rundown Record time Motor and Speed-controller temperature normal Battery temperature normal Ifapplicable- Disconnect ground station Ifapplicable- Disconnect role equipment De power RPA Control TX off Visual check ofairframe (including landing gear) Motors Free battery secure no loose leads, All antennas secure. Propellers

- No Damage, Secure Role equipment secure

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### IG 19 March 2014

### Pre-Flight- Fixed Wing
Observe normal motor rundown Record time Motor and Speed-controllertemperature normal Battery temperature normal If applicable

- Disconnect ground station If applicable- Disconnect role equipment De power RPA Control TX off Visual check ofairframe (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 Startfor 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 Ifapplicable

- Disconnect ground station Ifapplicable- Disconnect role equipment De power RPA Control TX off General visual check of RPS overall for obvious defects or damage sustained in flight

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### 17 19 March 2014