~' 

' • 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@j oshcremer.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 of the 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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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 U AS 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 of the plan 

and rulemaking required by section 332(b)(l) of this Act or the guidance required by section 334 

of this Act." In Section 332(b)(l), Congress made it clear that Section 333 provides a 

mechanism for "expedited operational authorization." The F AAA 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 of the [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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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 of U.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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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 of the 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 of the Aircraft Registration Application as provided for in § 4 7.31 (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 of the same part and shall, between required 

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inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired 

as prescribed in Part 43 of the 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 of the 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 of this 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) of this section: 

(1) Records ofthe maintenance, preventative maintenance, and alteration 

and records of the 1 00-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) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

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(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 of the 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. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the 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) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is sold. 

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(3) A list of defects furnished to a registered owner or operator under§ 

4 3.11 of this 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 of no 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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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 relief because 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 (if necessary) 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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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 of the 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 of total 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 of five hours of 

flight time with the specific make and model of the UAS to be utilized for 

operations under the exemption and three takeoffs and landings in the preceding 

90 days. 

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• 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 relief from 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 of the 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 U AS 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 relief from 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 of the 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 of the 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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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 if needed. 

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 

of obtaining 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 of the PIC and VO, below 

400 feet AGL, and at speeds below 50 knots. 

Consistent with the relief typically 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 of the 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 of the operating area except those consenting to be involved 

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and necessary for the filming production, with the possibility of reducing 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 8 900.1, V3, C8, S 1. 

Petitioner will not conduct UAS operations within 5 nautical miles of the 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 ("NOT AM"). 

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 of Waiver, 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 with jurisdictional FSDOs through the 

conditions and limitations accompanying the requested exemption, and that the exemption 

sought herein will take the place of the Certificate of Waiver normally issued by a jurisdictional 

FSDO under 8900.1. Under this rubric, Petitioner will notify every FSDO with jurisdiction over 

the area that Petitioner plans to operate, just as with manned filming operations, and those 

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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 ("CO A'') prior to conducting any operations under this grant of exemption. In 

fulfilling its requirements under the COA, Petitioner will be required to request a NOT AM 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 of closed-set 

filming. 

Respectfully submitted, 

McArthur Law, PLLC 

By: 

L. Shay McArthur 

Counsel for Petitioner 

Josh Cremer Photo & Video, LLC 

McArthur Law, PLLC 

www .shaymcarthurlaw .com 
Josh Cremer 

Photo & Video, 

LLC 

Operations Manual 

UAV Operators Manual 

Document Version 2 

April 1, 2015 
J 

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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 ....................................................................... 1 0 

1.2.3. Remotely Piloted Aircraft Flight Authorizations and Flight Records .............. 1 0 

1.2.4. Recency Requirements ..................................................................... 1 0 

1.2.5. Duty and Flight Time Limitations .......................................................... 1 0 

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 

?n 
6.4 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 

UA V 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 maintenance 
f) 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 MANAGEMENT PLAN 

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 REMOTELY PILOTED AIRCRAFT FLIGHT AUTHORIZATIONS 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 AUTHORITY FOR 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 FUEUBATTERY DOCUMENTATION 

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. 
ECK AND JOB SAFETY ASSESSMENT 

 out a feasibility check must be performed to ensure it is within the scope of the UOC. The flow chart represents the process to 

 task may proceed. 

ere are steps to consider. The corresponding steps are listed below. A red box indicates the task cannot proceed. 
s listed in the schedule for the UOC 

ove Ground Level (AGL) 

airspace/restricted airspace 

tical Miles (NM) from a registered aerodrome 

area 

rs from people not involved in operation 

(VLOS) 

ological Conditions (VMC) 

ny other State or Federal Regulation 

 Assessment 

must be performed prior to conducting any task. 

Note- A single task may consist of a number of flights 

nt would normally be performed during the feasibility planning phase to determine if the flight is viable and validated on the 

is when assumptions made during the initial Job Safety Assessment (such as forecast weather/wind, location of persons etc.) 

ety Assessment must consider the following: 

ssary maps and charts (either hard copy or electronic) for the area 

ather is suitable for the machine and the operation 

TAMs related to the operations area 

n moving into the area of operation or landing area during flight 

rights of way 

 landing areas (including alternate landing area) 

30m separation from the public 

ings Trees etc.) 

ference (power lines, antennas etc.) 

visual line of sight 

matches location/task 

nd owner 

by laws, 

val make it legal? 

however, outside 3NM of an aerodrome and not within the approach and departure path for a runway of an aerodrome. 
ent Matrix at Appendix seven. Note -this will form part of an Area 

l: 

essment if performed earlier. Commence job in accordance with the 

DENTREPORTING 

ents are required to be immediately reported to proper authorities. 

uired to be submitted within 72 hours of an accident, serious 

en notification should contain as much information about the accident, serious incident or incident as is within the knowledge o 

bmitting the notification. 

RATIONS 

d out within the limitations and conditions in the schedule of the 

se anything to be dropped or discharged from an unmanned aircraft in any way that may create a hazard to another aircraft, 

bject to other State and Federal laws and must be complied with. 

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ATION SHEET 

Task: Aircraft: 

Time Hours 

Launch Flight Notes: 

Recovery 

Launch 

Recovery 

Launch 

Recovery Job Site Assessment: 

Est. Total 

hours 

Actual 

Total 

hours 

Signed: 

 

Signed: 
LOG AND MAINTENANCE RECORD 

_ _ 

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Operator I 

aily Post flight Flight Serviceable Defect Comment Total 

ction inspection or Y/N number 

daily 

··.c:n::..-:: :,,. .. ,_ .... ·.·': ''-·····: . 
 of defect or maintenance required Name Rectification Name 

Signature Signature 

Date Date 

 of defect or maintenance required Name Rectification Name 

Signature Signature 

Date Date 

of defect or maintenance required Name Rectification Name 

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 added 
X 6 

SESSMENT 

Date I 

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 

T Signature I 
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 Assessment 
location 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. 
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)