Kurt von Strasser

Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14

Kurt von Strasser

Ascent Aerial Video Productions

10300 West Charleston Boulevard, Suite 13

- 175

Las Vegas, NV 89135 USA

email: kvonstrasser@gmail.com | Phone: 702.907.7515



### UAS Integration O ffice

– Speci al Rules Coordinator

Federal Aviation Administration U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

February 10, 2015

Re: Petition for Exemption for U se of UAS for Real Estate, Public Interest, Small Business Applications Under Section 333, Title 14

Pursuant to Section 333 off the FAA Modernization and Reform Act of 2012, and 14C.P.R. Part 11, I Kurt von Strasser and my Company, Ascent Aerial Video Productions, hereby applies for an exemption fr om the Federal Aviation Regulations identified below and to permit the commercial use of use of ultra

- light unmanned aerial system s for photography and videography

.

This exemption is made based on information outlined in this petition, as well as the

accom panying DJI Inspire 1 Operators Manual (Appendix D ), the Yuneec Typhoon Q500 Operators Manual (Appendix E ) and my own Ascent Aerial Video Productions Operational Manual (Appendix C ). The UA aircraft were selected specifically because of their proven capabi lity for stable, reliable controlled flight as well as a gyro stabilized flight mode, GPS aided navigation, an on

- board compass, blinking LED’s on the bottom, a failsafe mode for returning home, and ground station based telemetry of flight operations. Thes e devices are offered for general sale around the

world and have often been used as Model Aircraft in the USA. Each has extensive manufacturers support including operating manuals, video training, software updates and customer support.

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Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14



### I

. **Petitioner’s C ontact Information**  **:**

Kurt von Strasser

Ascent Aerial Video Productions 10300 West Charleston Blvd., Suite 13

- 175 Las Vegas, NV 89135

Phone: 702.907.7515

Email: kbs@parkavenueventures.net

**II**

. **The Specific Sections of Title 14 of the Code of Federal Regulations From** 

**Which Kurt von Strasser III**  **Requests Exemption are:**

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & ( b).

**III. The Extent of relief Kurt von Strasser III**  **seeks and the Reason He Seeks**

**Such Relief:**

I, Kurt von Strasser III, am a licensed Private Pilot, certificate number 561510978, having obtained my license in 1980.

I, Kurt von Strasser III , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating

to prevent me, Kurt von Strasser III , contemplated commercial cinematic, academic and other flight operations within the nati onal airspace system.

The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Kurt von Strasser III ’s

, ultra

- light weight UAS meets th e definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of

my ultra

- light weight UAS is expressly contemplated by the Reform Act. I would like

to operate my ultra

- light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photography.

T he Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; whether the UAS will be operated near airpo rts or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me. My UAS aircraft utilize four (4) counter

- rotating propellers for balance, control an d stability. My UA ’s are equipped with GPS and auto return safety technology. My UA Maximum Takeoff Weigh t is less than seven (7) pounds and four ( 4 ) pounds each, respectively, (far below the maximum 55 pound limit); including

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Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14



### camera with gimbal and any ot her payload

. Each would be classified as an ultra

light UAS aircraft.

I consider safety as foremost with each flight. My small unmanned aircraft are designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize

the Smart Mode* (see Manufacturer’s Operating Manual) for aerial videography / photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost the UA is designed slowly return and descend to point of takeoff . I d o not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather.

Horizontal Ground Speed for most drone vide ography requirements are typically

less than 7

- 10 miles per hour which further adds to safety. Maneuvers are limited in scope and gently performed (as opposed to more radical recreational use) due to the need to keep the camera steady for video purposes. Flight paths are planned out in advance, as opposed to recreational flight and therefore safer than many recreational flights since speed, maneuvers and flight paths are very conservative and preplanned.

During any planned operation of the my UAS, I first scout the area and flight path, determine what obstacles, if any, are present, where to post warning signs notifying persons that aerial drone photography is taking place and any other conditions from lighting, line of sight issues and power lines that I should be aware of to conduct safe operations. I clearly mark the area of the flight path with warning signs indicating that the UAS will in operating for 30 minutes prior to the flight and until all flight operations have ceased.

I maintain a second obse rver at all times who remains within 10 yards of the PIC position and who is responsible for assigning in spotting for obstacles , people,

vehicles and manned aircraft as well as keeping track of the UAS position

.

I am constantly on alert for any manned air craft (Police/Medical helicopters, private and commercial aircraft of any type, model aircraft, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft m ay approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot (PIC)

.

Utilizing battery power rather than combustible fuels, flights generally last betwe en three (3) to eight ( 8 ) minutes, with an altitude under one hundred fifty (150) feet. I utilize a fresh fully charged battery with each flight as a safety precaution; full flight

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### time limit for each battery is eighteen ( 18 ) minutes to twenty five (25) as specified by the manufacturer s and consistently twenty one (2 1 ) to twenty five (25) minutes

as tested.

My flight equipment provides for the monitoring of battery levels during flight. I do not operate my UAS at or below manufacture recommend minimum cha rge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each event t o
i nsure replacement for a sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the p ublic , public or private

property or manned aircraft and have no desire to lose my very substantial

i nvestm ent in my UAS equipment

.

As of this time I have completed over 200 practice flights with over 40 hours of UAS

airborne operation s as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of my specific UA S model s ’ operations

and performance under different temperature and weather conditions. I also practice regular weekly computerized simulated flights to maintain adequate skills and response reflex time , all this for the sake of safety. I have no less th an 5 hours of flight time logged in each model proposed herein within the past 90 day period.

I, Kurt von Strasser III , am extremely cautious when operating of my UAS/ultra light weight unmanned aircraft and will not “create a hazard to users of the natio nal airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into

the nat ional airspace system. Kurt von Strasser III ’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security. The UAS aircraft used are late model unit s manufactured by leading manufact urers (brand names) in the industry, DJI and Yuneec. Each has extensive experience in Unmanned Aerial Video Flight Systems and provides extensive software, flight manuals, operational information, specifications and customer support on their products

.

**I V. How**  **Kurt von Strasser III ’s**  **Request Will Benefit the Public as a**  **Whole:**

Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving non

- luxury homeowners and lower budget Realtor s from a valuable marketing tool. Manned aircraft pose a threat to the public through potential ca tastrophic crash , e ach having

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Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14



### the potential result of loss of life , damage to property and substantial cost involved in responding to, handling the emergency and the subseq uent investigation and clean up . Each such manned aircraft event also involves combustible fuel that in the past has exploded and burned on impact. Police helicopters have made emergency hard landings within city limits. My, Kurt von Strasser III ’s , UAS pose no such threat

since size and lack of combustible fuel alleviates a lmost all potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspa ce system, hence the passing of the Reform Act. Granting my, Kurt von Strasser III ’s , exemption request furthers the public interest through academic/visual awareness of the geographical benefits in

and around the Las Vegas area. My ultra

- light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra

light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft;

which are manned, heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra

- light weight UAS's. Permitting me, Kurt von Strasser III , to im mediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the Las Vegas and surrounding

communit ies and cities for companies looking to relocate or build in the area s as

w ell as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the communit ies

involved

.

**V. Reasons Why Kurt von Strasser III**  **’s Exemption Will Not Adversely Affect**  **Safety or H**  **ow the Exemption Will Provide a Level of Safety At Least Equal**  **to Existing Rule:** 

My, Kurt von Strasser III ’s , exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Kurt von Strasser III , to log more flight ti me in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors that can be embraced by the NAR, AAR,

and TAR for develo pment in cooperation with the FAA. In addition I, Kurt von

Strasser III , submit the following representations of enhancements to current aerial videography and photography for real estate:

My UAS aircraft weigh less than 5 pounds complete with a small ultr a

- light weight high quality factory installed gimbaled high definition camera; I only operate my

UAS below 3 00 feet 9 (well within the 400 foot permissible ceiling set by the FAA

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### Modernization and Reform Act of 2012); my UAS only operate s for 3

- 8 minutes

av erage per flight; I land my UAS significantly prio r to manufacturer recommended minimum level of battery power which my flight systems monitor throughout the flight ; I pilot my UAS through remote control only by line of sight; My UAS has GPS a flight safet y feature whereby it hovers and then returns to the point of takeoff,

then slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocol s; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive pre

- flight inspections and protocol according

to all manufacturers recomme ndations as well as that of the AMA (Academy of Model Aeronautics) , during which safety carries primary importance; I always obtains all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety brea ches or any potential danger.

My, Kurt von Strasser III ’s , safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkably astounding, there ha ve been incident s involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra

- light weight UAS.

First, the potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific areas away from mass populations. Second,

there is no fuel on boa rd a UAS and thus the potential for fire or explosions is greatly

diminished.

Third, the small size and extreme maneuverability of my UAS allow s me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan , tilt and zoom.

Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety

levels.

**VI. A Summary the**  **FAA May Publish in the Federal Register:**

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Ma nuals and Similar

.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §

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Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14



### 91.203(a)(1). The size, weight and enclosed operational area of my UAS air craft permits exemption from Part 21 because my UAS aircraft meet (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under

both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My current and projected

UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form con templated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equival ent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10 167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircr aft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me and any proposed PIC’s of the UAS prop osed

.

14 C.F.R. § 45.23: Marking of the Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement.

Regardless, I propose that each UA will carry its appropriate “N” number if one i s issued by the FAA, in such size as can reasonably fit upon the sides of the aircraft in at least two locations on the booms or fuselage. If an N number is not obtained from the FAA, I will mark the related UAS in the largest possible lettering by placin g the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UA will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos.

87 38, 10167, 10167A and 10700.

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Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14



### 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

commercial operations. The FAA has previously ruled in its exemption that a Private Pilot’s Certificate is required for flight of the UAS for commercial purposes. I, Kurt

von Strasser III

, am a licensed private pilot and will assure that all PIC’s proposed to operate any of the UAS aircraft also have at minimum a Private Pilot’s certifi cate and

current Class Three medical.

My UAS ’s do not carry any pilots or passengers. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me and any other Private Pilot

Certified PIC to operate the proposed UAS ’s to meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 3 00 AGL; safely below the standard of 400 AGL. I will however operate my UAS in safe areas awa y from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

14 C. F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part

and shall b etween required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, theref ore, apply to my proposed UAS ’s . However, as a safety precaution I require the PIC to perform a comprehensive pre

- flight and post

- flight inspection of

the UAS , adhering to the manufacturers’ recommendations and checking all flight

systems, power system, ro tors and electronics including battery levels

. The UAS has significant self

- diagnostic software and systems checks built into its operations. Any system not reporting correctly and fully functional shall result in an aborted flight until the problem is i dentified and solved and the systems once again report

100% green and good to go.

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and similar . 14 C.F.R. 21, Subpart H,

entitled Ai rworthiness Certificates, sets forth requirements for procurement of

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### necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my proposed UAS ’s m eet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces o f legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS ’s both meet or exceeds each of th e elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires a n aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptio ns to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. T herefore, an equivalent level of safety will be

achieved.

**In summary, Kurt von Strasser III**  **seeks an exemption from the following Regulations:** 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C .F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my two
small ultra

- light weight unmanned aircraft vehicle s (UA’s) in community awareness

, for the public good and for real estate operations and small business operations, to develop economic platforms for real estate to enhance the experience of those

se eking to relocate to any such area served

.

Currently, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel , po sing potential risk to the public. Granting my request for ex emption will reduce current risk levels and thereby enhance safety.

My UAS aircraft do not contain potentially explosive fuel, they are far smaller, lighter and more maneuverable than conventional real estate video and photographic

aircraft with much less flight time and do not require transit to and from the

“ shoot” location to an Airport, resulting in far less required time airborne and therefore exposure & liability. Further, I operate at lower altitudes and in controlled airspace eliminating potentia l public risk flying to and from established air ports and

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Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14



### operations take place well below pattern altitude. All of my operations are conducted with a pre

- flight aircraft inspection, flight path inspection, and actual flights are normally conducted at ver y low altitudes and speed with conservative maneuvers necessary for video cinematography.

I, Kurt von Strasser III , have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for

real estate and similar small business usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the

FAA Modernization and Reform Act of 2012.

There are no personnel on board my, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My operation of UAS ’s , weighing

less than seven (7) pounds and travelling at far lowe r speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs.

Accordingly I respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully Submitted,



# Kurt von Strasser III (ES)



### Kurt von Strasser III

REALTOR ® Urban Nest Real Estate Private Pilot, Single Engine Land VFR Quad Drone Pilot & Cinematographer

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Ascent Aerial Video Productions Request for Exemption for Use of UAS Under Section 333, Title 14



### APPENDI X A
Sample Flight Screen with Live Data (Inspire 1UAS) Specifications Overview

**UAS #1 DJI Inspire 1 Quad**

Manufacturer: DJI
Model: Inspire 1 T600

Weight: 2935 g / 6.47 Pounds

Passenger Capacity: 0 (unmanned)

Size (dimensions): 438x451x301 mm (17.24x17.76x11.85 inches)
Max Speed: 22 mps (72.18 fps / 49.21 mph)

Max Flight Time: 18

- 25 mins

Max Ceiling (software limited): 400 ft AGL

Operations: Line of Sight

Controller: Dedicated 2.4 GHz, Commercial Controller with 2 km maximum rated operat ing distance

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### APPENDIX B Sample Flight Screen with Live Data (Yuneec Typhoon Q500 1UAS) Specifications Overview

**UAS #2 Yuneec Typhoon Q500**

Manufacturer: Yuneec Electric Aircraft

Model: Typhoon Q500
Weight: 1700 g / 3.75 Pounds

Passenger Capacity: 0 (unmanned)

Size (dimensions): 420x420x240 mm (16.53x16.53x9.45 inches)

Max Speed: 22 mps (72.18 fps / 49.21 mph)

Max Flight Time: 25 minutes
Max Ceiling (software limited): 400 ft AGL

Operations: Line of Sight

Controller: Dedicated 10ch, 2.4GHz Commercial Controller with 2 km maximum rated operating distance

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### APPENDIX E

Operational Policies for all Unmanned Aircraft Systems Real Estate and Small Business Video Operations

Ascent Aerial Video Productions

Kurt von Strasser

1. The unmann ed aircraft system (UAS) will weigh less than 7 pounds, including energy source(s)
and equipment and shall not be loaded with any unauthorized payloads.

2. The UAS will not be flown at a ground speed exceeding 35 MPH.

3. Flights will be operated at an al titude of no more than 300 feet above ground level (AGL), as indicated by the procedures specified in the operator’s manual. All altitudes reported to ATC

must be in feet AGL.

4. The UAS will be operated within visual line of sight (VLOS) of the PIC at al l times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses.

5. All operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS
requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

6. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, will be included in the preflight inspection. All m aintenance and alterations will be properly documented in the aircraft

records.

Pre

- Flight Protocol:

1. Check batteries with voltage meter to insure fully charged and

ready for use. Inspect batteries for damage or leakage that may

affect proper operation.

2. I nspect propellers for cracks, chips or damage that may cause sudden loss of

propulsion or unmanageable/uncontrolled flight.

3. Check weather forecasts for wind advisory or other conditions that may
impact flight. Consult five (5) mile radius map for airport v icinity.

4. Contact respective airport to advise of estimated flight time, estimated flight duration,

estimated elevation of flight, and any other pertinent information as may be required by

distance.

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a. Inspect flight area for:

i. vicinity of public safety helipad s/heliports

ii. vicinity of medical helipads/heliports

iii. vicinity of light poles

iv. vicinity of utility wires

v. vicinity of trees or any other obstacles

vi. flocks of birds that may cause interference and potential flight impact

vii. vicinity of any elevated obstructions that may pose potential flight hazard

viii. vicinity of roadways with moderate to heavy traffic that

can be distracted

ix. public gatherings that may attract viewers

x. optional point of control for best visual site of

UAS while in flight Takeoff and landing

b. inspect area f or best and safest point of takeoff and landing

5. if in a subdivision or area that is within 150 feet of a residential street, post
warning sign(s)/stand(s) "Attention Aerial Photography In Progress

– Stay Back 150 Feet

"

Flight Protocol:

Takeoff and land f rom same location whenever possible.

1. remain alert to birds, sound or aircraft, curious public, and approaching

vehicles

2. do not allow anyone to engage in conversation or distract the remote

control pilot (PIC) restrict flight to minimal elevation sufficien t to acquire

desired results

3. remained prepared for emergency landing at all t imes pay attention to flight

time

4. if possible set a timer as a safety alert

5. land UAS and shut down propulsion immediately following landing

Post flight:

1. disconnect battery to pre vent accidental activation of propulsion system

2. secure UAS in a safe location

3. remove all warning signs from public access areas

Emergency or Suspected Hazard:

Immediate land UAS at safest and closet ground location in the event

• manned aircraft is heard o r seen in vicinity of flight

• there is a public gathering within established safety boundary wanting to observe flight

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• pilot is being distracted from focusing on flight and safety

• sudden change in weather (wind bursts)

• sudden increase in vehicular traffic i n vicinity of flight

• birds enter into proximity of flight

7. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test fligh t in accordance with the operator’s manual. The PIC who conducts the functional test flight will make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry will be added t o the operator’s manual.

8. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul,
replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component /overhaul, replacement, and inspe ction/maintenance requirements will be established and
identified in the operator’s manual. At a minimum, requirements for the following will be included in the operator’s manual:

a. Actuators / Servos; b. Transmission (single rotor); c. Power plant (moto rs);
d. Propellers; e. Electronic speed controller;
f. Batteries; g. Mechanical dynamic components (single rotor);
h. Remote command and control; i. Ground control station (if used); and
j. Any other components as determined by the operator;

9. The Pilot In Command (PIC) will possess at least a private pilot certificate and current third

class medical certificate and at least a valid driver’s license.

10. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14

CFR § 6 1.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in complian ce with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted to accomplish the required flight cycles and flight time.

11. Prior to operations the PIC will have accumulated and l ogged, in a manner consistent with 14 CFR § 61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experience

- building, and take

- off and landing currency flights can be conducted to accomplish the required flight cycles and flight time.

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12. The UAS may not be operated directly over any person, except authorized and consenting personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.

13 The operator will request all non

- authorized and consenting persons to remain clear of the operational area by not less than 100 feet.

14. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual.

15. Each UAS operation will be completed within 15 minutes maximum flight time or with 25% battery power remaining, whichever occurs first.

16. If the operational area is within 5 miles of any airport, the PIC will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any
operations. This COA will also require the operator to request a Notice to Airman (NOTAM) not
more than 72 hours in advance, but not less than 48 hours prior to the operation.

17. All aircraft operated in accordance will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. If this registration is not available from the FAA, then each such aircraft shall be marked “Experimental.”

18. Each UAS operated will comply with a ll manufacturer Safety Bulletins.

19. The radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency
requirements.

20. If operating withi n five (5) miles of the center of any airport, at least three days before scheduled flight, the PIC or operator will submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed flight area. The 3

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

a. Dates and times for all flights;

b. Name and phone number of the operator

c. Make, model, and serial or N

- number of UAS to be used;

d. Name and ce rtificate number of UAS PIC involved

e. A statement that the operator has obtained permission from property owners and/or
local officials to conduct the flight operations; the list of those who gave permission must be made available to the inspector upon request;

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f. Signature of exemption

- holder or representative; and

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

22. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. 23. The UA will remain clear and yield the right of way to all o ther manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

24. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. A ll operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

25. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

26. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 nautical miles of the geographic center of a non

- towered
airpo rt as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with t he airport management must be made available to the Administrator upon request.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours.

END

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### APPENDIX D

D JI Inspire 1 Operators Manual

( See Separate Attachment )

File: DJI Inspire Operations Manual

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### APPENDIX E

Y uneec Typhoon Q500 Operators Manual

( See Separate Attachment )

File: Yuneec Yyphoon Q500 Operations Manual

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