**~'** ' • j 5548 S. Fuchsia Place, Boise, ID 83716 (208) 391-3677

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 April30, 2015



### Josh Cremer Photo and Video, LLC Petition for Exemption to Operate Unmanned Aircraft 

### Systems for Aerial Photography and Filming

FAA Regulatory Docket



### NAME AND ADDRESS OF PETITIONER COUNSEL FOR PETITIONER Josh Cremer Photo & Video, LLC Attn: Josh Cremer 17062 N. Tanner Place Nampa, ID 83867 (208) 51406239 josh@joshcremer.com L. Shay McArthur MCARTHUR LAW, PLLC 5548 S. Fuchsia Place Boise, ID 83716 (208) 724-8208 shay@mcarthurlaw.org

### April 30, 2015 Page 2 I. 

### PETITION SUMMARY Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012, Pub. L. 

### No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's ("FAA") general exemption authority under 49 U.S.C. § 44701(±), Josh Cremer Photo & 

### Video, LLC ("Petitioner") hereby petitions for exemptions from 14 C.P.R. Part 21, 14 C.P.R.§§ 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 92.103(b)(l), 91.119(c), 91.121, 91, 151, 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a)-(b). The proposed exemptions, if granted, would allow Petitioner to operate, small camera-mounted unmanned aircraft systems ("UAS") weighing 55 pounds for less for the purpose of close-set filming of videos, web videos, corporate videos, real estate videos, and still photography. Based on the small size ofPetitioner's UAS, the qualifications and experience of Petitioner's UAS operators, and the restricted environment within which Petitioner will operate, the requested exemptions fall squarely within the zone of safety envisioned by Congress and set forth in Section 333. Additionally, the enhanced safety achieved by replacing significantly larger matmed aircraft can-ying crew and flammable fuel with the small UAS carrying no passengers or crew and operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS operations enabled by the instant Petition are in the public interests. Thus, the requested exemptions should be granted.

II. BACKGROUND For the past year, Petitioner's production and filming have provided video services for corporate and private individuals. Combining the latest in technology and an superb safety record, Petitioner's skill and knowledge has been used by local, national, and international organizations. In order to continue to provide the highest level of service, and promote safety by

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### April 30, 2015 Page 3 eliminating the need for large manned aircraft, Petitioner seeks regulatory exemptions that will allow Petitioner to employ camera mounted UAS technology in the filming and production process. 

### III. STATUTORY AUTHORITY A. Section 333 Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems," provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the National Airspace System ("NAS"). Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may operate safely in the NAS before completion ofthe plan and rulemaking required by section 332(b)(l) ofthis Act or the guidance required by section 334 ofthis Act." In Section 332(b)(l), Congress made it clear that Section 333 provides a mechanism for "expedited operational authorization." The FAAA has committed to complying with this mandate by granting several petitions almost identical to the one at hand. See, e.g., 

### Exemption No. 11062, Regulatory Docket No. FAA-2014-0352 (granting regulatory exemptions to Astraeus Aerial for operation of unn1anned aircraft systems for the purpose of filming for the motion picture and television industry). Section 333(b) identifies several factors that the FAA should consider in determining whether commercial UAS operations should be approved. The include UAS that, "as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to the users ofthe [NAS] or the public
or pose a threat to national security." See 

### Section 333(b). B. 

### Section 44701([) In addition to the specific authority conferred by Section 333, the FAA Administrator has general authority to grant exemptions for the FAA's safety regulations and minimum standards

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### April 30, 2015 Page4 when the Administrator decides a requested exemption is in the public interest. See 

### U.S.C § 

### 44701(f). 

### IV. REQUESTED EXEMPTIONS Petitioner requests relief from the following regulations: Part 21 prescribes, in pertinent part, the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals. Section 61.113 prescribes that "no person who holds a private pilot certificate may act as
a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft,: (see 

### Section 61.113(a)), and that "a private pilot may, for compensation or hire, act as pilot in command of an aircraft in cmmection with any business or employment if: ( 1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire," (see 

### Section 61.113(b)). Section 61.133(a) sets forth privileges for persons holding commercial pilot certificates, including a provision impliedly limiting to persons holding a commercial pilot certificate the ability to act as pilot in command of an aircraft "[f]or compensation or hire." Section 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft unless it is in an airworthy condition. Section 91.9(b)(2) prohibits operation ofU.S. registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Section 91.1 03(b)(l) prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight, to include, "For any flight, runway lengths at airports of intended use, and the following takeoff

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### 30, 2015 Page 5 and landing distance information:
... For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein." Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: "Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle,

or structure." Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "to the elevation ofthe departure airport

or an appropriate altimeter setting available before departure." Section 91.151 (a) prescribes that no person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, 

### (1) during the day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes. Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft unless it has within it 

### (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy ofthe Aircraft Registration Application as provided for in § 47.31 (c). Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have the aircraft inspected as prescribed in subpart E ofthe same part and shall, between required

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### April 

### 30, 2015 Page 6 inspections, except as provided in paragraph (c) ofthe same section, have discrepancies repaired
as prescribed in Part 43 ofthe chapter. Section 91.407(a)(l) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under§ 43.7 ofthe same chapter. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 ofthis chapter. Section 91.417(a) and (b) prescribes, in pertinent part, that- (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventative maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include- (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date of completion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor.

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### April 30, 2015 Page 7 (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) 

### and safety directives including, for each, the method of compliance, the AD 

### or safety directive number and revisions date. Ifthe AD 

### or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) 

### The records specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated or superseded by other work or for 

### 1 year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold.

McArthur Law, PLLC www .shaymcarthurlaw.comApril 30, 2015 Page 8 (3) A list of defects furnished to a registered owner or operator under§ 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. 

### V. PETITIONER'S PROPOSED OPERATIONS SATISFY SECTION 333. A. Unmanned Aircraft Systems The UAS to be operated under this request are less than 55 lbs. fully loaded, will be operated at a speed ofno more than 50 knots, carry neither a pilot nor passenger, carry no explosive materials or flammable liquids, and operate exclusively within a secured area. Petitioner's UAS use a radio frequency spectrum for operation and control that complies with Federal Communications Commission ("FCC") requirements, and Petitioner has integrated safety features into the UAS, as described in Petitioner's UAV Pre-Flight procedure and UAV In-Flight & Post-Flight Procedure (collectively referred to as, "operations manuals"). 1 Petitioner's UAS are equipped with redundant safety mechanisms allowing them to operate safely after experiencing certain in-flight failures. If a lost-link event occurs, including the loss of ground communications and/or the loss of a GPS signal, Petitioner's UAS have the ability to perform a pre-coordinated, predictable, automated flight maneuver and return to a predetermined location within a designated security perimeter for landing. The UAS further have the ability to abort a flight in the event ofunpredicted obstacles or emergencies. All flights will be terminated after a maximum of 15 minutes or with 30% remaining battery power, whichever
occurs first. Thus, good cause exists for granting Petitioner's requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel requirements for flight in VFR conditions).

1 The Operating Manual is submitted along with this petition.

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### April 30, 2015 Page 9 Petitioner's UAS will be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings will be as large as practicable. Regarding Petitioner's requested relief from 14 C.F.R. § 91.121 (Altimeter Settings), Petitioner seeks such reliefbecause Petitioner will not have a typical barometric altimeter onboard the UAS. Instead, altitude information will be provided to the UAS PIC via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. The altitude information will be generated by equipment installed onboard the UAS, using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC. Thus, good cause exists for granting the requested relief from 14 C.F.R. § 91.121. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from 14 C.F.R. Part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is warranted (ifnecessary) and meets the requirements for an equivalent level of safety under 14 C.F.R. Part 11 and Section 333. The UAS operated without an airworthiness certificate in the restricted environment and under the conditions and limitations proposed by Petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and not subject to the proposed limitations and conditions. Petitioner will strictly comply with safety and maintenance procedures included in all applicable UAS manufacturer's instructions and operating manuals. To the extent such information is not included in the guidelines developed by the manufacturers, Petitioners will develop and document maintenance, overhaul, replacement, and inspection requirements,

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### April 30, 2015 Page 10 procedures to document and maintain maintenance records with regard to Petitioner's UAS, and UAS technician qualification criteria. Petitioner's operations manuals will include maintenance requirements for Petitioner's UAS, including "on-condition" maintenance and modifications. In light ofthese mitigating factors, exemptions from 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b) are warranted. B. UAS Pilot in Command Petitioner's UAS pilot in command (PIC) shall not be required to hold a current pilot's license because it will only operate in Class G Airspace. Since there are no standards for either private or commercial UAS pilot certificates, knowledge of airspace regulations acquired from FAA ground school and dexterity in the control and operation ofthe UAS acquired from actual operation ofthe aircraft will be the most important factors in establishing an equivalent level of safety. According to the FAA, "the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing." 

### See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 18. With those factors in mind, Petitioner's UAS PIC shall be required to meet several conditions and limitations as outlined in the Operations Manual, including the following:
• The UAS PIC will have accumulated and logged a minimum of200 flight cycles and 25 hours oftotal time as a UAS rotorcraft pilot and at least 10 hours logged as
a UAS pilot with a similar UAS type (single blade or multi-rotor).
• The UAS PIC will have accumulated and logged a minimum offive hours of flight time with the specific make and model ofthe UAS to be utilized for operations under the exemption and three takeoffs and landings in the preceding 90 days.

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### April 30, 2015 Page 

### 11 

### • The UAS PIC will have successfully completed the qualification process as specified in the operations manuals, to include a knowledge and skill test. Regarding Petitioner's requested relieffrom 14 C.F.R. § 91.7(a), it is Petitioner's understanding that Petitioner's UAS will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) is therefore unnecessary. To the extent such an exemption is deemed necessary, Petitioner asserts that it should be granted in light ofthe safety procedures proposed herein. In accordance with the pertinent part of 14 C.F .R. § 91.7(b), the operator in command of Petitioner's UAS shall be responsible for determining whether the aircraft is in a safe condition for flight. Petitioner's manuals for maintenance and operations shall include safety checklists to be used by the operator in command prior to each flight. Regarding Petitioner's requested relieffrom 14 C.F.R. § 91.9(b)(2) (Civil aircraft flight manual, marking, and placard requirements and§ 91.203(a) and (b), (Civil aircraft: certifications required), it is Petitioner's understanding that relief from these regulations is no longer necessary in light ofthe FAA Memorandum "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station," dated August 8, 2014. To the extent the FAA deems an exemption from this section necessary for Petitioner's proposed operations, such exemption should be granted in light ofthe mitigating fact that Petitioner will maintain the documents required under 14 C.F.R. §§ 91.9 and 91.203 at the UAS ground control station during flights. Regarding Petitioner's requested relieffrom 14 C.F.R. § 91.103(b)(l), Petitioner will comply with the other applicable procedures and requirements stated in§ 91.103(a) and (b). Specifically, the PIC will take all actions including reviewing weather, flight battery requirements, aircraft performance data, and landing and takeoff distances before initiation of a

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### April 30, 2015 Page 12 flight. The PIC will also account for all relevant site-specific conditions in their preflight procedures. Risks presented by sun glare will be mitigated by the PIC's and VO's ability to see other air traffic and initiate a return-to-home sequence ifneeded. The PIC's UAS operation will be limited to a unique and restricted enviromnent. Given the (1) separation of filming operations from other manned operations, (2) parallel nature of aeronautical knowledge requirements incumbent in the FAA ground school exam and the process ofobtaining a private pilot's license, and (3) the proposed UAS airmanship skills of Petitioner's PICs, the additional manned airmanship experience of a private pilot would not correlate to the airmanship skills necessary for Petitioner's proposed unmanned operations. Thus, Petitioner's request for relieffrom 14 C.F.R. § 61.113(a) and (b) and§ 61.133(a) should be granted. C. Operating Parameters ofPetitioner's UAS Petitioner's UAS operations will be conducted within a controlled area, and provide notice to all non-participating persons in the area of operations prior to beginning operations. In this controlled area, Petitioner's operations will remain within VLOS ofthe PIC and VO, below 400 feet AGL, and at speeds below 50 knots. Consistent with the relieftypically provided to manned operations under FAA Order 8900.1, Volume 3, Chapter 8, Section 1, Petitioner requests relieffrom 14 C.F.R. § 91.119(c) with respect to those participating persons, vehicles, and structures directly involved in the perfonnance ofthe actual filming. Regarding distance from pmiicipating persons, the operations manuals set forth safety factors for authorized and consenting production personnel. Because those procedures are specific to participating persons, no further FSDO or aviation safety inspector approval is necessary for reductions to the distances specified in Petitioner's manuals. Regarding the distance from nonparticipating persons, Petitioner will ensure that no persons are allowed within 500 feet ofthe operating area except those consenting to be involved

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### April 30, 2015 Page 13 and necessary for the filming production, with the possibility ofreducing this distance to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. This is consistent with FAA Order 8900.1, V3, C8, S 1. Petitioner will not conduct UAS operations within 5 nautical miles ofthe geographic center of a non-towered airport unless a letter of agreement with that airport's management is obtained and the operation is conducted in accordance with a Notice to Airmen ("NOTAM"). Additionally, Petitioner will not operate in Class B, C, or D airspace without written approval from the FAA. Nor will Petitioner operate the UAS 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. Petitioner's UAS will remain clear and yield the right of way to all manned operations and activities at all times (including, but not limited to, ultra light vehicles, parachute activities, parasailing activities, and hangliders). Although Petitioner seeks to comply with the waiver process as described in FAA Order 8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion Picture and Television Filming), the current section of Order 8900.1 has specific processes that preclude a jurisdictional FAA FSDO from issuing the required Certificate ofWaiver, because the section did not originally provide for UAS operations. Thus, Petitioner seeks exemption from the applicable regulations normally waived during that process. Petitioner proposes that the FAA include the required notifications and coordination withjurisdictional FSDOs through the conditions and limitations accompanying the requested exemption, and that the exemption sought herein will take the place of the Certificate ofWaiver normally issued by a jurisdictional FSDO under 8900.1. Under this rubric, Petitioner will notify every FSDO withjurisdiction over the area that Petitioner plans to operate, just as with manned filming operations, and those

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### April 30, 2015 Page 

### 14 FSDOs will have the ability to coordinate further conditions and limitations with the UAS Integration Office to address any local concerns. Petitioner will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver
or Authorization ("COA'') 

### prior to conducting any operations under this grant of exemption. In fulfilling its requirements under the COA, Petitioner will be required to request a NOTAM not
more than 72 hours in advance, but not less than 48 hours prior to the operation. D. The Requested Exemption Promotes the Public Interest The enhanced safety achieved by replacing significantly larger manned aircraft carrying
crew and flammable fuel with small UAS carrying no passengers or crew and operated under the specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that the UAS operations enabled by the instant Petition are in the public interest. Moreover, as the FAA has already recognized, "U AS provide an additional tool for the filmmaking industry, adding a greater degree of flexibility, which supplements the current capabilities offered by manned aircraft." See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 22. 

### VI. CONCLUSION For the foregoing reasons, the regulatory exemptions requested herein should be granted and Petitioner should be permitted to conduct small UAS operations for the purpose ofclosed-set filming.
Respectfully submitted, McArthur Law, PLLC By: L. 

### Shay McArthur Counsel for Petitioner Josh Cremer Photo & 

### Video, LLC

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# Josh Cremer Photo & Video, LLC


# Operations Manual UAV Operators Manual

Document Version 2 April 1, 2015J



### This Page is left intentionally blank

### TABLE OF CONTENTS UNMANNED OPERATORS CERTIFICATE FOR CASR PART 101 0 PREFACE ......................................................................................................4 0.1 COMPLIANCE REQUIREMENT ....................................................................4 0.2 COMPLIANCE MATRIX ................................................................................4 0.3 SIGNATURE SHEET ...................................................................................5 0.4 ABBREVIATIONS, ACCRONYMS AND DEFINITIONS
......................................6 1 PART A 1.1. GENERAL 1.1.1. Company Operations .........................................................................7 1.1.2. CASR Part 101 Directions, Permissions and Approvals
............................7 1.1.3. Organization Structure .......................................................................7 1.1.4. Responsibilities of Company Personnel. ..................................................7 1.1.5. Metric and Imperial Units Conversion Table
...........................................9 1.1.6. Alcohol and Drug usage .....................................................................9 1.1.7. Security- Systems and Physical. .........................................................9 1.1.8. Privacy Provisions .............................................................................9 1.2. REMOTE CREW ADMINISTRATION 1.2.1. Remote Crew Qualifications ............................................................... 10 1.2.2. Remote Pilot Records .......................................................................10 1.2.3. Remotely Piloted Aircraft Flight Authorizations and Flight Records
.............. 10 1.2.4. Recency Requirements .....................................................................10 1.2.5. Duty and Flight Time Limitations .......................................................... 10 1.3. REMOTELY PILOTED AIRCRAFT SYSTEM ADMINISTRATION 1.3.1. Method of Recording Hours in Service and Unserviceability
...................... 11 1.3.2. Persons Permitted to Operate Remotely Piloted System Controls
.............. 11 1.3.3. Authority for Maintenance ..................................................................11 1.3.4. Dangerous Goods ............................................................................11 1.3.5. Weather Protection ............................................................................11 1.4. FLIGHT CONDUCT 1.4.1. Non-Company visitors ....................................................................... 12 1.4.2. Hand Over/Take over Procedures ....................................................... 12 1.4.3. Remote Pilot Briefing including Emergency Procedures
........................... 12 1.4.4. Use of Check Sheets ........................................................................12 2 PART B 2.1 OPERATING THE REMOTELY PILOTED AIRCRAFT SYSTEM 2.1.1 Specific Aircraft Operating Procedures ............................................... 13 2.1.2 Remotely Piloted Aircraft Systems Technical Data/System Specifications.13 2.1.3 Normal Procedures .........................................................................13 2.1.4 Pre-Flight Procedures .....................................................................13 2.1.5 Fuel/Battery Documentation .............................................................. 14 2.1.6 Aircraft Test Flights .........................................................................14 3 PARTC 4.1 OPERATIONS 4.1.1 Feasibility Check and Job Safety Assessment
.................................... 16 4.1.2 Accident/Incident Reporting ............................................................. 17 4.1.3 Types of Operations ...................................................................... 18 4 APPENDICES C.nnv nf l JAV

**OnF>r::~tnrc: r.F>rtifir::~tP**  ?n6.4 Aircraft Flight Log and Maintenance Record

.....................................................23 6.5 Briefing

.................................................................................................... 25 6.6 Job Safety Assessment.

...............................................................................26 6.7 Risk Assessment.

.......................................................................................28

## 0 PREFACE 0. 1 COMPLIANCE REQUIREMENTS The instructions, procedures and information contained in this manual have been devised to ensure safety and standardization in the conduct of operations. They are to be observed by all operating personnel. Personnel are also reminded of their obligation to comply with 14 CFR of the Federal Aviation Regulations and Orders and such directives, aeronautical information and notices. Nothing in this manual takes precedence over a FAA regulation or permits unsafe operation Where in the light of operating experience, errors are found in the manual or deficiencies in the manner in which operations are conducted, recommendations for amendment action shall be submitted to the Chief Controller. 

### 0.2 SIGNATURE SHEET All personnel employed or contracted by this organization must sign this sheet as evidence of having read, understood and agreed to apply the procedures and data contained in this Operations Manual. If this manual is reissued or revised they must resign, acknowledging review of the revision. 

### Printed Signature Date Printed Signature Date

Name Name

### AA Area Approval AC Advisory Circular AGL Above Ground Level AlP Aeronautical Information Package ASIC Aviation Security Identification Card ATSB Australian Transport Safety Bureau ATC Air Traffic Control ATM Air Traffic Management CAR Civil Aviation Regulations 1988 CASA Civil Aviation Safety Authority CASR Civil Aviation Safety Regulations 1998 DAMP Drug and Alcohol Management Plan lAW In accordance with NM Nautical Miles RP Remote Pilot RPA Remotely Piloted Aircraft RPAS Remotely Piloted Aircraft System TSI Transport Safety Investigation Act 2013 UA Unmanned Aircraft UAS Unmanned Aircraft System(s) UAV Unmanned Aerial Vehicle UOC UAV Operators Certificate VLOS Visual Line of Sight VMC Visual Meteorological Conditions

## 1 PART A 1.1 GENERAL 1.1.1 COMPANY OPERATIONS All aerial operations using remotely piloted aircraft (RPA) will be conducted in accordance with (lAW) the conditions and limitations placed on the UAV Operators Certificate (UOC). A copy of the approved UOC is at Appendix One. 

### 1.1.2 RESPONSIBILITIES OF COMPANY PERSONNEL CEO/Director The CEO/Director has the overall responsibility for the company's business performance and compliance. They will provide the necessary resources so that all operations and maintenance can be conducted to meet company obligations, goals and objectives. Chief Controller The Chief Controller is the person appointed by the operator, approved by CASA and is responsible for all remote pilot training and operational matters affecting the safety of the UOC holder's operation. The role and responsibilities of the Chief Controller are: a) ensuring that the operator's air operations are conducted in compliance with The Civil Aviation Act and the Regulations, b) maintaining a record of qualifications held by each remote pilot (RP), c) monitoring operational standards, supervising and training RP employed by the operator, d) maintaining a complete and up-to-date reference library of operational documents as required by CASA for the class of operations conducted; and e) being the point of contact between the operating company and CASA. Maintenance Controller The Maintenance Controller is the person appointed by the operator, approved by CASA and is responsible for ensuring the maintenance of company Remotely Piloted Aircraft Systems (RPAS) in accordance with the manufacturer specifications. The role and responsibilities of the Maintenance Controller are: a) control all company RPAS maintenance, either scheduled or unscheduled; b) ensure personnel performing maintenance on the RPAS are competent. The Maintenance Controller must keep a record of personnel permitted to perform maintenance. c) develop, enforce and monitor RPAS maintenancef) maintain a thorough technical knowledge of the company RPAS, g) ensure maintenance activities are conducted in accordance with the procedures specified in the Maintenance Manual; and h) Investigate all defects in the RPAS. Controller/Remote Pilot in Command The controller/Remote Pilot in command of the aircraft is responsible for: a) conduct of flight- start to end; and b) safe operation of the aircraft.


### 1.1.3 METRIC AND IMPERIAL UNITS This manual makes reference to both imperial and metric units. See conversion table at Appendix two. 

### 1.1.4 DRUG AND ALCOHOL MANAGEMENTPLAN As a 'safety sensitive aviation activity,' personnel could be randomly tested for alcohol and other drugs. 

### 1.1.5 SECURITY- SYSTEMS AND PHYSICAL Reasonable steps must be taken to prevent sabotage and vandalism to the RPAS. 

### 1.2. REMOTE CREW QUALIFICATIONS The Chief Controller is responsible to ensure any remote crew including the controllers is competent. 

### 1.2. 1 REMOTE PILOT RECORDS Individual Controllers/Remote Pilots are responsible for their own Remotely Piloted Aircraft (RPA) log book. Individual remote pilots are required to carry their own Controller/Remote Pilot certificate with them on operations. 

### 1.2.2 REMOTELYPILOTED AIRCRAFTFLIGHTAUTHORIZATIONS AND FLIGHT RECORDS If there is more than one controller each operation is to be authorized by the Chief Controller. Flight authorization is at Appendix three. 

### 1.2.3 RECENCY REQUIREMENTS The Controller/Remote Pilot must have a minimum of three take offs and three landings on type within a 90-day period.The Chief Controller is responsible for the operational standards and supervision of the remote pilots who are employed by the company. RPs are responsible to ensure they do not fly while fatigued. 

### 1.3 REMOTELY PILOTED AIRCRAFT SYSTEM ADMINISTRATION 1.3.1 METHOD OF RECORDING HOURS IN SERVICE AND UNSERVICEABILITY The UAV Operators Certificate (UOC) holder is responsible to ensure records are kept. The controller is responsible for ensuring hours and unserviceability are recorded, refer to Appendix four. 

### 1.3.2 AUTHORITYFOR MAINTENANCE Only people authorized by the Maintenance Controller can perform maintenance. The Maintenance Controller is responsible for keeping records of personnel that may perform maintenance. 

### 1.3.3 DANGEROUS GOODS The carriage of dangerous goods is not permitted. Parts of the RPAS may be classified as dangerous goods during transportation. 

### 1.3.4 WEATHER PROTECTION The UOC holder is responsible to ensure appropriate weather protection is provided to avoid unserviceability of the RPAS. 

### 1.4 FLIGHT CONDUCT
1.4.1 NON-COMPANY VISITORS Non-company visitors must not come within 100 feet of the RPA during operation. The Controller/Remote Pilot must provide a safety briefing. 

### 1.4.2 HAND OVER/TAKE OVER PROCEDURES A hand over take over procedure is required, when there are two controllers, to positively identify an action and ensure the participants understand it. 

### 1.4.3 REMOTE PILOT BRIEFING INCLUDING EMERGENCY PROCEDURES To ensure co-ordination in a multi crew environment a briefing must be conducted prior to the commencement of any operation. Refer to Appendix five. 

### 1.4.4 USE OF CHECK SHEETS

## 2 PART B 2.1 OPERATING THE REMOTELY PILOTED AIRCRAFT SYSTEM 2.1.1 SPECIFIC AIRCRAFT OPERATING PROCEDURES The aircraft will be operated in accordance with the manufacturers operating instructions, which are considered to be part of the Flight Manual. Company initiated variation to the Flight Manual will require supplementary documentation. 

### 2.1.2 NORMAL PROCEDURES It is considered a good safety practice for operators to utilize check lists/sheets specific to their RPA referring to the Flight Manual. Company supplied checklists must to be used. 

### 2.1.3 PRE-FLIGHT PROCEDURES Pre-flight and post flight checks are mandated. It is the Controller/Remote Pilot's responsibility to ensure the aircraft is airworthy prior to any flight. Refer to Flight Manual for pre and post flight procedure checklist. 

### 2.1.4 FUEUBATTERYDOCUMENTATION Manufacturer's instructions for correct fuel specification and/or follow manufacturers' battery documentation especially relating to charge/discharge rates must be followed. Battery conditions are to be monitored. 

### 2.1.5 AIRCRAFT TEST FLIGHTS When completion of maintenance requires a test flight, the person completing the maintenance is responsible to ensure a satisfactory test flight is completed. The Maintenance Controller is responsible to ensure this happens.3 PART
D 3. 1 OPERA T/ONS 3.1.1 FEASIBILITY CHECK AND JOB SAFETY ASSESSMENT Before

a task can be carried out a feasibility check must be performed

to ensure

it is within the scope of the UOC. The flow chart represents the process
to be followed
to determine

if a task may proceed. A numbered box indicates there are steps to consider. The corresponding steps are listed below.
A red box indicates the task cannot proceed.1.Isitlegal:WithinallconditionslistedintheschedulefortheUOCUnder500feetAboveGroundLevel(AGL)OutsideControlledairspace/restrictedairspaceGreaterthan3NauticalMiles(NM)fromaregisteredaerodrome•OutsidepopulousareaMorethan30metersfrompeoplenotinvolvedinoperationVisuallineofsight(VLOS)DayVisualMeteorologicalConditions(VMC)NotprohibitedbyanyotherStateorFederalRegulation2.PerformaJobSafetyAssessmentAJobSafetyAssessmentmustbeperformedpriortoconductinganytask.Note-AsingletaskmayconsistofanumberofflightsTheJobSafetyAssessmentwouldnormallybeperformedduringthefeasibilityplanningphasetodetermineiftheflightisviableandvalidatedonthepriortothefirstflight.ThisiswhenassumptionsmadeduringtheinitialJobSafetyAssessment(suchasforecastweather/wind,locationofpersonsetc.)arevalidated.AsaminimumtheJobSafetyAssessmentmustconsiderthefollowing:•Gatheringthenecessarymapsandcharts(eitherhardcopyorelectronic)forthearea•DeterminingtheweatherissuitableforthemachineandtheoperationReviewingtheNOTAMsrelatedtotheoperationsareaPossibilityofpersonmovingintotheareaofoperationorlandingareaduringflight•Footpath,orotherrightsofway•Suitabletakeoffandlandingareas(includingalternatelandingarea)Abilitytomaintain30mseparationfromthepublicObstructions(BuildingsTreesetc.)Possibleradiointerference(powerlines,antennasetc.)•AbilitytomaintainvisuallineofsightControllersabilitymatcheslocation/taskPermissionfromlandownerPrivacy•Localrestrictions,bylaws,•Needforsignage·..3.WouldanAreaApprovalmakeitlegal?Insidecontrolledairspacehowever,outside3NMofanaerodromeandnotwithintheapproachanddeparturepathforarunwayofanaerodrome.4.Isitsafe?CompletetheRiskAssessmentMatrixatAppendixseven.Note-thiswillformpartofanAreaApprovalapplication5.ApplyforAreaApproval:Proceed:ValidatetheJobSafetyAssessmentifperformedearlier.CommencejobinaccordancewiththeUOCapproval.3.1.2ACCIDENTIINCIDENTREPORTINGAccidentsandseriousincidentsarerequiredtobeimmediatelyreportedtoproperauthorities.Writtennotificationsarerequiredtobesubmittedwithin72hoursofanaccident,seriousincidentorincidentThewrittennotificationshouldcontainasmuchinformationabouttheaccident,seriousincidentorincidentasiswithintheknowledgeothepersonatthetimeofsubmittingthenotification.3.1.3TYPESOFOPERATIONSAlloperationsmustbecarriedoutwithinthelimitationsandconditionsinthescheduleoftheuocTheControllermustnotcauseanythingtobedroppedordischargedfromanunmannedaircraftinanywaythatmaycreateahazardtoanotheraircraft,personorproperty.Tickasappropriate.TheseoperationsmaybesubjecttootherStateandFederallawsandmustbecompliedwith.AERIALPHOTOGRAPHYAERIALSPOTTING,-AERIALSURVEYING()**~** 

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2 Single Unit Conversion Useful conversion
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2.54 centimeter

- -= 45 J Foot
30.5 centimeter

400 Feet 121.92
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- 100 =

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- -

- 35 -

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w=-

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**~{}:**

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hour

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3.6 Kilometers per

m:

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hour

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## 8 w ""'" en 'D §: V> N w N4.3 APPENDIX

3 FLIGHT AUTHORIZATION SHEET Date: Location: Task: Aircraft: Remote crew:

Time Hours PIC Launch

Flight Notes: 2RP Recovery RPA observer Launch Recovery Launch Recovery

Job Site Assessment: Est. Total hours Actual Total hours Specific instructions: . I Flight Chief Signed: ' Authorization Controller Remote Signed: Pilot4.4 APPENDIX

4 AIRCRAFT FLIGHT LOG AND MAINTENANCE RECORD Aircraft Type _______

_ Aircraft Serial Number ____

_ Date of Manufacturer I Aircraft ide-ntification

I Operator

I Date Pilot Daily Post flight Flight Serviceable Defect Comment Total inspection inspection

or Y/N number daily ·_,'

. ,\. ··.c:n::..-:: :,,.

.. ,_ ....

·.·': ''-·····:

. ' >Defect Description

of defect or maintenance required Name Rectification

Name Number

Signature

Signature Date

Date Defect Description

of defect or maintenance required Name Rectification

Name Number

Signature

Signature Date

Date Defect Description

of defect or maintenance required Name Rectification

Name Number

Signature

Signature Date

Date --

## 4.5 APPENDIX 5 Briefing The following briefing is to be given by the controller to all crewmembers and observers. The controller is also responsible to ensure the emergency contact telephone numbers are to hand.
Action ./ Overview of the mission as planned Any specific tasking for crewmember. EG. person tasked with observing for people straying into the area of operation Possible issues and identification of hazards associated with the mission including planned action How the controller will communicate any problem and/or subsequent action Identification of alternate landing area Identification of a safe zone Action following an incident Notes/comments specific to mission

Emergency contact numbers

.. Any add1t1onal requirements for th1s operation must be added4.6 APPENDIX

6 JOB SAFETY ASSESSMENT Company

I

Date

I Task

I Location

Check the following and address as needed ./Sketch of area (if necessary)

Maps and charts available and checked Weather, within limits for machine and operation NOTAMs Possibility
of public moving into area Footpath/right

of way Landing area including alternate Ability to maintain 30M of public Obstructions (buildings Trees) Possible interference (Power lines/antennas) Ability to maintain visual line of sight Controllers ability matches location/task Permission

of any landowners Privacy Local restrictions,

by laws Need for signage Pilot

T Signature

I Crew Comments-

## 4. 7 APPENDIX SEVEN RISK ASSESSMENT Overview The evaluation of risk is the process known as "Risk Assessment". The UAS Controller should perform this assessment. The Risk Assessment should be performed during the feasibility-planning phase to determine if the flight is viable, refer Part D Section 1. It should then be validated on the day prior to the flight. Any assumptions made during the initial Risk Assessment (such as forecast weather/wind, location of persons etc.) should be confirmed. The Risk Assessment involves calculating a risk factor based on both the severity of any undesired outcome and the likelihood of that outcome. Where the risk factor is unacceptably high a mitigating factor or control measure is needed to reduce the likelihood or consequence to manage the risk back to an acceptable level/factor. Even if the risk is acceptable you should consider any factor that could be applied to reduce the risk further. 

### Determining the Risk A detailed diagram of the site (Google maps may also be used) and the Risk Assessment Tool Prompt Sheet are used to identify possible risks. These risks are recorded on the Risk Calculation Sheet. Next the score for both the likelihood and consequence is determined using the Risk Score Table below and the scores are entered on the Risk Calculation Sheet. The Risk factor is then calculated by multiplying these two scores. Note- other elements such as local by Laws etc. which may prevent the flight should also be considered. 

### Risk Management The calculated Risk Factor for each identified risk is then reviewed Where the risk factor is unacceptably high a mitigating factor or control measure is needed to reduce the likelihood or consequence to manage the risk to an acceptable level/factor. Multiple control measures may be needed to reduce the risk to an acceptable level. Even if the risk is acceptable you should consider any factor that could be applied to reduce the risk further. The control measure is recorded on the Risk Calculation Sheet and a new Risk Factor calculated. Note- The risk assessment should also include any risk to the Controller, Observer and anyone else involved in the operation of the UAS. Where the residual risk is unacceptable the flight should not proceed. 

### Validation of Risk Assessmentlocation of persons etc.) should be confirmed. Where there are differences a new Risk factor must be calculated and control measures adjusted to manage the risk to an acceptable level prior to the flight. 

### Other Factors As this is a generic Risk Assessment process it cannot consider all possible areas of risk for every situation. There may be other areas that need consideration in addition to the Risk Assessment Sheet prompts. Therefore this risk assessment process should be considered a guide as to the minimum areas for inclusion in your Risk Assessment.>7: Extreme risk - detailed tre 6,7: High risk
RISK ASSESSMENT MATRIX- LEVEL OF RISK Scrutiny required by internal committees or internal audit to prevent escalation. Small delay, internal

I May tlu·eaten an inconvenience only. element of the service delivery function. Business objective delayed. Easily remedied, some impact on extemal stakeholders. Scrutiny required by external committees

or Auditor General's Office, etc. Considerable remedial action required with disruption

to a Group for period up to I month. Some business objectives not achieved.

Life threatening injury or multiple serious injuries causing hospitalization. Intense public, political and media scrutiny. Eg: inquest, front page headlines, TV, etc. Significant loss of critical information. Disruption

to one or more Groups for up to 3 months. Some major objectives not achieved. Multiple life threatening injuries. Less than

I 0 fatalities. Government inquiry or Commission
of inquiry or adverse national media in excess of I week. Permanent loss of critical information, substantial disruption
to CASA or external intervention for over
3 months. Threatens existence of a Group within CAS A. Major objectives not achieved Multiple fatalities,

I or more Govenunent inquiry and ongoing adverst inten1ational expostl Threatens ongoing existence of CAS A.

### RISK CALCULATION SHEET Undesired Outcome Severity Likelihood Risk Factor

Control Measure or comment on risk

#
Control Measure or comment on risk Final Final Final

#
Control Measure or comment on risk Final Final Final

## Risk Assessment Tool Prompt Sheet Consideration Possible Impact on Risk Time of Day Possible Low Sun, fading light, orientation, ability to maintain visual LOS Weather Check Forecast, Temperature, wind direction, wind strength, impact on battery life (cold battery, flying into wind), aircraft wind limit, Fire ban, Public Person moving into landing area during flight, footpath, right of way, Suitable takeoff and landing areas, ability to maintain 30m separation, Property Permission from land owner, privacy, buildings, antennas, trees, obstructions, ability to maintain visual line of sight, controllers ability matches location, local restrictions, by laws, Other aircraft Likelihood of other aircraft in area Equipment failure Likely failure modes, alternate landing site, emergency procedures, Battery fire following crash (dry grass), Environment Noise, ability to communicate with participants, distractions, possible distraction of public (drivers)