### LAW OFFICES OF WAYNE 

## A. JOHNSON

WAYNEA. JOHNSON, ATIORNEY 2901 W. PARKER ROAD #864434 PLANO, TEXAS 75086 214.454.3292 WAJ.USALAW@GMAIL.COM

June 4, 2015 DocketManagement Facility U. S. Department ofTransportation 1200 NewJersey Ave. SE West Building Ground FloorRoom W12-140 Washington, DC 20590 Re: Exemption request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 and 14 CFRPart 11, Drone Pilot, LLC hereby applies for anexemptionfrom the Federal Aviation Regulations (FARs) listedbelow and discussed in Appendix A. Exemptionis being sought in orderto allow Drone Pilotto operate its small unmanned aircraft systems (sUAS) for sUAS flight training and training-related demonstrations. sUAS are ideally suited for various commercial operations such as the above because the aircraft has the capability to deliver high quality data more efficiently and cost-effectively than traditional methods. Using sUAS can also be safer for workers because in many cases it will avoid putting workers in situations withpotential hazards, eliminatingthe risk ofinjuries. They also allowthe safe inspection ofhard-to-access or environmentally sensitive areas withoutthe use oftrucks and otherutility vehicles. Overall, sUAS canprovide significantbenefitsto workers and customers overthese traditional methods. Drone Pilot proposes to use rotor and fixed wing aircraft, which crafts have a maximum takeoff weight oflessthan 55 pounds, will be operated at a speed ofno more than 50 knots, and which crafts contain built-in safety features. Proposed operations will be conducted under controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) access controlled. Operations under the exemption will be subjectto strict operatingparametersto ensure atleast an equivalent level ofsafety to currently authorized operations using manned aircraft.

liPageThe name and mailing address ofthe petitioner, Drone Pilot, is: Drone Pilot, LLC Attn: Ed Tovar Ph.: 512.431.0545 Email: etovar@dronepilot.io Address: 6905 MesaDrive, Austin, Texas 78731 The regulations from whichthe exemptionis requested are listed below. These are more fully discussed inAppendix A. 14 CFR 

### § 61.113 (a) and (b) 14 CFR 

### § 61.133 (a) 14 CFR 

### § 91.7 (a) 14 CFR 

### § 91.119 (c) 14 CFR 

### § 91.121 14 CFR 

### § 91.151 (a) 14 CFR 

### § 91.405 (a) 14 CFR 

### § 91.407 (a) 

### (1) 14 CFR §91.409 (a) (1) and (2) 14 CFR 

### § 91.417 (a) and (b)

The Unmanned Aircraft Systems. Drone Pilot will conduct flight training operations with lightweight rotor and fixed wing aircraftproducedbyindustry recognized companies that are placed onthe market from time-to-time. All craft will (i) weighunder 55 pounds with energy sources and equipment, (ii) have stable platforms and common characteristics ofreliability, stability and safety, and (iii) be supportedby extensive manufacturers' operation manuals/user guides. Use ofthese sUAS is subjectto the operating parameters, conditions and limitations included in this Petition, including comprehensive flight training instruction on such matters as: • sUAS rules, regulations, requirements and guidelines published bythe FAA • manufacturers' operation manuals/user guides for each aircraft • operatingparameters, conditions and limitations contained inthe Petition • flight and safetyprocesses and procedures publishedbyreputable UAS organizations such as the Academy ofModel Aeronautics and the Associationfor Unmanned Vehicle Systems International. All courses will include both classroom and hands-ontraining. sUAS ofthis weight category generally have commoncharacteristics. Each canbe operated by toggle orentirelyby a touch-screen, map-based interface. This means the operator only needs to command the systemwhere to go, and the system does all the flying for the operator. They can be operated inboth semi and fully autonomous flight modes, withthe operator simply clicking on a mapto create a pre-planned flight pathfor a flight. In addition, the operator can create no fly zones ormaximum flight ranges and altitudes so the system cannot enter areas deemedunsafe or unnecessary to fly over. 21PageIn addition, the sUAS have built-in intelligent fault handling capabilities which allowthemto detect a system fault while inthe air and automatically fly backto its take-offlocation and land. Faults that canbe detected include: loss ofcommunication; exceedingpre-setwindthresholds; and lowbattery levels. All flight operations are global positioning system (GPS) controlled, making the systems easy to navigate. At any pointifthe operator is not explicitly commandingthe rotorcraft systemto move, the system automatically holds its GPS position. The flight control system employs not only GPS positioningbut a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. Industry recognizedproducers ofsUAS ofthis category generally maintain onlineproduct informationportals with comprehensive downloadable operating and maintenance manuals, user guides, flight checklists, safety information and missionplanning instructions. Often available are instructional product and training videos along withrobust online blogs andproductforums. OperatingDocuments. Comprehensive operationmanuals/user guides for aircraft ofthis category are always available onthe internet atthe manufacturers' website. Attached as Appendices "B", "C" and "D", being submitted under confidentiality protection request, are Standard Operating Procedures, Pre-flight Checklist and Post-flight Checklist. The PIC (pilot in command). The PIC will:

• hold either a current FAArecreational or sportpilot certification orhigher FAApilot certification

• hold a valid driver's license

• ,in the case ofrotorcraft, have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of25 hours oftotaltime as a sUAS rotorcraft pilot and at least 10 hours logged as a sUAS pilotwith a similar sUAS type

• ,inthe case offixed wing aircraft, have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of25 hours oftotal time as a sUAS fixed wingpilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• have accumulated and logged a minimum offive hours as a sUAS pilot withthe make and model ofsUAS to be utilized for operations under the exemption and three take-offs and landings inthepreceding 90 days priorto an operation

• as noted belowin "OperatingParameters; Conditions and Limitations", the operator will not allow a PIC to operate unless the PIC has demonstrated thatthe PIC is able to safely operate the sUAS in a manner consistent withhowthe sUAS will be operated under the exemption, including evasive and emergencymaneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 31PageVisual observers musthave demonstrated thatthey understand the conditions and limitations of flight noted below in "Operating Parameters; Conditions and Limitations". Operating Parameters; Conditions and Limitations. Grant ofthe exemptions will be subject to the following conditions, whichprovide at least an equivalent orhigher level ofsafetythan underthe current conditions. These conditions are drawn from Exemptions 11062 through 11067, 11080, 11109 and 11110. Forpurposes ofthis listing, Drone Pilot is referred to as the operator. 1. Operations authorizedbythe grant will be limitedto the sUASs described above and manufacturers' upgraded versions. 2. The sUAS mustweigh less than 55 pounds, including energy source(s) and equipment. 3. The sUAS may not be flown at an indicated ground speed exceeding 50 knots. 4. Flights mustbe operated at an altitude ofno more than 400 feet above ground level (AGL). Altitudes reportedto Air Traffic Control must be infeet AGL. 5. The sUAS must be operated withinvisual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use humanvisionunaided by any device otherthancorrective lenses, as specified onthe PIC's FAA-issuedmedical certificate. 6. All operations mustutilize a visual observer (VO). The VO may be usedto satisfythe VLOS requirement as long as the VO and PIC always maintain VLOS capability. The VO and PIC mustbe able to communicate verbally at all times. The PIC mustbe designated beforethe flight and cannot transferhis orherdesignation during the flight. The PIC must ensure thatthe VO canperform the functions prescribedinthe operating documents. 7. The operating documents and this grant ofexemptionmustbe made available to the Administratoruponrequest. The operatormayupdate orrevise its operations manual. Itis the operator's responsibilityto track suchrevisions andpresent updated and revised documents to the Administratoruponrequest. Ifthere is a discrepancy betweenthe exemption conditions and limitations andthe procedures outlined inthe operating documents, the conditions and limitations hereintake precedence and must be followed. Ifthe operator determines that anyupdate or revisionwould affectthe basis upon whichthe FAA grants this exemptionthe operatormustpetitionthe FAA for amendmentto the exemption. 8. Priorto each flight the PIC must inspectthe sUAS to ensure itis in a condition for safe flight. Ifthe inspectionreveals a conditionthat affects the safe operation ofthe sUAS, the aircraft will beprohibited from operating until the necessarymaintenance has beenperformed andthe sUAS is found to be in a condition for safe flight. The ground control stationmustbe included inthepreflight inspection. All maintenance and alterations mustbe properly documented inthe aircraftrecords.
41Page

### 9. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry inthe sUAS aircraft records ofthe flight. 10. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items orequipmentnot already covered in the relevant sections ofthe operating documents. 11. The operator must follow the sUAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 12. The operator must carry out its maintenance, inspections, and record keeping requirements in accordance withthe operating documents. Maintenance, inspection, alterations and status ofreplacement/overhaul componentparts mustbe noted in the aircraft records, including total time in service, description ofwork done, discrepancies between inspections, and the identification ofthe authorized person returning the sUAS to service. 13. Each sUAS operated underthis exemption must comply with all manufacturer safety bulletins. 14. The PIC must hold either a current FAArecreational or sport pilot certification or higher FAApilot certification and a valid driver's license The PIC must also meet the flight reviewrequirements specified in 14 CFR 61.56 as the sUAS. 15. sUAS flight training will include comprehensive instruction on such matters as (i) sUAS rules, regulations, requirements and guidelines published by the FAA, (ii) manufacturers' operation manuals/user guides for each aircraft, (iii) these operating parameters, conditions and limitations, and (iv) flight and safety processes and procedures publishedby reputable UAS organizations such as the Academy ofModel Aeronautics and the Association for Unmanned Vehicle Systems International. All courses will include both classroom and hands-on training. 16. The operator may not permit any PIC to operate unless the PIC has demonstratedthat the PIC is able to safely operate the sUAS in a manner consistent with howthe sUAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 17. Maximum flight time for each operational flight will be limited to the amount oftime the sUAS canbe flown and still maintain a reserve battery power ofno less than 20%. 18. The operatorwill file a request for a Notice to Airmen (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 19. The radio frequency spectrum used for operation ofthe sUAS must comply withthe FCC or other appropriate governmental oversight agency requirements.

SjPage20. All flights must be conducted overproperty that is private orcontrolled access property withpermission from the land owner/controller or authorized representative. Permission will be obtained for each flight, where necessary or appropriate. Currently flight training is being conducted at anAMA field inthe Austin, Texas area. 21. Ifthe sUAS loses communications or loses the GPS signal, the sUAS mustreturnto a pre-determined location ortake-offpoint orbe recovered in accordance withthe operator's manual. 22. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) prior to conducting any operations under this grant of exemption. 24. All aircraft operated inaccordance with this exemptionmust be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (Nnumber) markings in accordance with 14 CFRpart 45, Subpart C. Markings mustbe as large as possible. 25. The documents required under 14 CFR §§ 91.9 and 91.203 mustbe available to the PIC at the ground control station ofthe sUAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official uponrequest. 26. The sUAS must remain clear and yield the right ofwayto manned aviation operations and activities at all times. 27. sUAS operations maynotbe conducted during night, as defined in 14 C.F.R 

### § 1.1. All operations must be conducted under visual meteorological conditions. Flights under special visual flight rules are not authorized. 28. The sUAS maynot be operated bythe PIC from any moving device or vehicle. 29. The sUAS maynot be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 30. The sUAS may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter of agreement withthe airport management must be made available to the Administrator uponrequest. 31. Flight operationsmustbe conducted at least 500 feet from all nonparticipating persons (persons otherthan the PIC, VO, operatortrainees or essential persons) vessels, vehicles and structures, unless: 

### 61Pagea. Barriers or structures are presentthat sufficiently protectnonparticipating persons from the sUAS and/or debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe sUAS, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present anundue hazard, and;

c. Operations nearer to the PIC, VO, operatortrainees or essential persons do not present anundue hazard to those personsper § 91.119(a). 32. Any incident, accident, orflight operation thattransgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COAmustbe reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to the National Transportation Safety Board (NTSB) perinstructions contained ontheNTSB Website: www.ntsb.gov. The Public Interest. The public interest in granting this exemptionrequest is served by, among others, the following:

• Congress has established a national policythat favors early integration ofsUAS into the NAS- pending completion ofthe statutorilyrequired rulemaking for such integration, exemptionrequests such as this one by Drone Pilot (and many others) are integral in developing and inmoving this policy along

• The use ofsUAS improves public safety andreduces risk by alleviating the public's exposure to danger and emissions associated with traditional aerial methods (full size aircraft) that carry passengers and flammable fuel

• Allowing the commercializationofthe NASby sUAS will provide additionaljob and career opportunities for ournation's population

• Resulting ecological and environmental benefits such as precision inspections and assessments offuel-laden pipelines, rights-of-way, energy productionplatforms, along with coastal marine environment observations for conservation purposes

• Harnessing the power ofnewtechnologies and providing challenges to ournation's entrepreneurs and developers

• Drone Pilot's pilot and visual observertraining (as noted in operating parameter#15 above) will enhance the safety ofsUAS flight and will serve to minimizethe risk to the NAS and to persons and property onthe ground Summary for publication. Forpublication inthe FederalRegister Drone Pilotprovides the following summary. An exemption is requested from the following regulations in orderto allow 71Pagecommercial operations ofits unmanned aircraft systems involving aerial applications suchas photography, inspections, surveying, and demonstrations.

14 CFR 

### § 61.113 (a) and (b) 14 CFR 

### § 61.133 (a) 14 CFR 

### § 91.7 (a) 14 CFR 

### § 91.119 (c) 14 CFR 

### § 91.121 14 CFR §91.151 (a) 14 CFR 

### §91.405 (a) 14 CFR 

### § 91.407 (a) (1) 14 CFR 

### § 91.409 (a) (1) and (2) 14 CFR 

### § 91.417 (a) and 

### (b) 

### ********** Conclusion. Giventhe small size ofthe sUASs involved andtherestricted environment within which they will operate, this petition falls squarely withinthatequivalent level ofsafety in which Congress envisionedthat the FAAmust, by exemption, allow commercial operations ofsUASs to commence immediately. Too, giventhe clear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal AviationAct, the strong equivalent level ofsafety surrounding the proposed operations, and the significantpublic benefit ofthe various applications, including enhanced safety, reduction in environmental impacts by fuel ladenvehicles, including reduced emissions, the public value ofthe unmanned aerial vehicle industry, the grant ofthe requested exemptionis in the public interest. Drone Pilot seeks an exemption from the listed and discussed FARs to operate commerciallythe small unmanned aircraft systems inthe aerial operations set forth herein. Thankyou.

8jPage

## APPENDIX A 14 CFR § 61.113(a) and (b); 61.133(a): Private Pilot Privileges and Limitations: Pilot in Command; Commercial Pilot Privileges and Limitations Sections 61.113(a) and (b) limitprivate pilots to non-commercial operations. Section 61.133(a) requires an individual with a commercialpilot's license to bepilot in command ofan aircraft for compensation orhire. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the sUAS proposed for use by Drone Pilot are remotely controlled with no passengers orcargo onboard. Drone Pilotrespectfully requests exemptions from these requirements based onthe particular characteristics ofthe sUAS that will be used. The risks associated with the operation ofthe sUAS described above (giventhe size, speed, operational capabilities and lack ofcombustible fuel) are much lowerthanthe risks associated with commercial operations contemplated by Part 61 with conventional aircraft. Accordingly, a recreational or sportpilot, adequately trained inthe proper use ofsUAS, possesses the requisite skills and knowledge oftheNAS and FAA regulations to assure the safe operation ofthe sUAS. In addition, Drone Pilot will use the identified sUAS with a high degree ofcontrol and various built-intechnical capabilities that strictly limitthe potential for operation outside ofthe operating conditions set forth inthis Petition. Drone Pilot emphasizes sUAS training and flight experience for those PICs who will operate these aircraft inthe proposed commercial applications. Byrequiring extensive flight experience with these aircraft priorto conducting commercial operations, these PICs will have a better grasp ofthe handling ofthe aircraft than they would byholding a commercialpilot license for an entirely different type ofairborne system. Giventhe inherently lower-risk nature ofthe sUAS and these training, experience and safety features, Drone Pilotproposes that operators should not be required to hold a commercial pilot certification. Instead operators shouldbe required to hold only a recreational or sport pilot certification and have the experience with the sUASs as indicated inthis Petition. The risks associated withthe operation ofthe sUAS identifiedherein (giventheir size, weight, speed, operational capabilities, and lack ofcombustible fuel) are so diminished from the level of risk associated with commercial operations contemplatedbyPart 61 with conventional aircraft (rotorcraft or fixed wing) that allowing operations ofthe sUAS as setforth above meets or exceeds the present level ofsafetyprovided under 14 CFR § 61.113(a) and (b) and does notrise to the level ofrequiring a commercialpilotto operate under§ 61.133(a). Given these conditions and restrictions, an equivalent level ofsafety will be providedby allowing operation ofthe sUAS identified herein with a private pilot's certificate, underthe conditions setforth inthis Petition. The FAA has granted exemptionto conduct similar operations in Exemptions 11062 through 11067, 11080, Ill09 and 11110.

91Page14 CFR § 91.7(a): Civil Aircraft Airworthiness This regulation requires that no person may operate a civil aircraft unless itis in airworthy condition. Shouldthe exemptionbe granted allowing commercial operation ofthe named aircraft without an airworthiness certificate, no standard will exist for airworthiness ofthe aircraft. Giventhe size ofthe aircraft and the requirements that the operatorhas agreedto as relates to airworthiness, as set forth herein and inthe various operating documents, an equivalent level ofsafety will be achieved by ensuring compliance with the aircraft manuals and operating documents for each flight. The FAAhas granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080, 11109 and 11110. 14 CFR §91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (c) prohibits operations below 500 feet above the surface, orcloserthan 500 feet to any person, vessel, vehicle or structure. As this exemptionrequests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the locationwhere it is operated. No flight will be taken withoutthe permission ofthe property owner orlocal officials, where required. Because ofthe advance notice to the property owner and participants, all affected individuals will be aware ofthe planned flight operations as set forth inthe plan of operations. Drone Pilottherefore requests a waiver from Section 91.119(c) for all participating persons, i.e., persons associated with the operations. Drone Pilot will also ensure thatnon-participating persons are kept at least 500 feet from the operating area, or seek approval from the Administrator for less separationifan equivalent level ofsafety canbe achieved. Comparedto flight operations with aircraft orrotorcraft weighting far more thanthe maximum ofless than 55 pounds proposed herein and the lack offlammable fuel, any risk associated withthese operations is far less than those risks associated withthe conventional methods. In addition, the low-altitude operations ofthe sUAS will ensure separation between these sUAS operations and the operations ofany conventional aircraftthat must comply with Section 91.119. 14 CFR §91.121: Altimeter Settings This regulation requires eachpersonoperating 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." As the sUAS maynothave a barometric altimeter, butinstead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved bythe operatorconfirmingthe acquisition ofGPS signals and an initial ground level altitude ofzero priorto take-off. The FAAhas granted exemptions to conduct similar operations inExemptions 11062 through 11067 and 11080. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits anindividual from beginning "a flight in anairplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly after that for at least 30 minutes; or (2) Atnight, to fly after that for at least 45 minutes." 10 

## IPage

## APPENDIX B 

## Drone Pilot, LLC Standard Operating Procedures For Small Unmanned Aircraft Systems (sUAS)

The flight team. The flight team will consists ofa pilot in command (PIC}, avisual observer (VO), and such other members as may be designated for any particular mission. The P/Cwill:

• hold either a current FAA recreational or sport pilot certification or higher FAA pilot certification

• hold a valid driver's license

• ,in the case of rotorcraft, have accumulated and logged a minimum of 25 hours oftotal time as a sUAS rotorcraft pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• ,in the case offixed wing aircraft, have accumulated and logged a minimum of 25 hours oftotal time as a sUAS fixed wing aircraft pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• have accumulated and logged a minimum offive hours as a sUAS pilot with the make and model of UAS to be utilized for operations underthe exemption and three take-offs and landings in the preceding 90 days priorto an operation

• the operatorwill not allow a PIC to operate unless the PIC has demonstrated that the PIC is able to safely operate the sUAS in a manner consistent with how the sUAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures The PIC and the VO must have demonstrated that they understand the conditions and limitations offlight noted below in "Operating Parameters; Conditions and Limitations". Operating Parameters; Conditions and Limitations. The following matters apply to all sUAS being operated by Drone Pilot (referred to below as the operator): 1. The sUAS must weigh less than 55 pounds, including energy source(s) and equipment.

sUAS Standard Operating Procedures, page 1 of 52. The sUAS may not be flown at an indicated ground speed exceeding 50 knots. 3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL}. Altitudes reported to Air Traffic Control must be in feet AGL. 4. The sUAS must be operated within visual line ofsight (VLOS} ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical certificate. 5. All operations must utilize avisual observer (VO}. The VO may be used to satisfy the VLOS requirement as long as the VO and PIC always maintain VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or her designation during the flight. The PIC must ensure thatthe VO can perform the functions prescribed in the operating documents. 6. The operating documents and any grant of exemption must be made available to the Administrator upon request. The operator may update or revise its operations manual. It is the operator's responsibility to track such revisions and present updated and revised documents tothe Administrator upon request. Ifthere is a discrepancy between the exemption conditions and limitations and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted an exemption the operator must petition the FAA for amendment to the exemption. 7. Priorto each flight the PIC must inspect the sUAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe sUAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The ground control station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8. Any sUAS that has undergone maintenance or alterations that affect the sUA$ operation orflight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the sUAS aircraft records ofthe flight. 9. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items or equipment not already covered in the relevant sections ofthe operating documents.

sUAS Standard Operating Procedures, page 2 of 510. The operator must follow the sUAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 11. The operator must carry out its maintenance, inspections, and record keeping requirements in accordance with the operating documents. Maintenance, inspection, alterations and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description ofwork done, discrepancies between inspections, and the identification ofthe authorized person returning the sUAS to service. 12. Each sUAS operated underthis exemption must comply with all manufacturer safety bulletins. 13. The PIC must hold either a current FAA recreational orsport pilot certification or higher FAA pilot certification and hold a valid driver's license. 14. The PIC must also meet the flight review requirements specified in 14 CFR 61.56 as the sUAS. 15. The operator may not permit any PIC to operate unless the PIC has demonstrated that the PIC is able to safely operate the sUAS in a manner consistent with how the sUAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 16. Maximum flight time for each operational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 20%. 17. The operator will file a request for a Notice to Airmen (NOTAM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. 18. The radio frequency spectrum used for operation ofthe sUAS must comply with the FCC or other appropriate governmental oversight agency requirements. 19. All flights must be conducted over property that is private or controlled access property with permission from the land owner/controller or authorized representative. Permission will be obtained for each flight. 20. Ifthe sUAS loses communications or loses the GPS signal, the sUAS must return to a pre-determined location ortake-off point or be recovered in accordance with the operator's manual.

sUAS Standard Operating Procedures, page 3 of521. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 22. The operator must obtain an AirTraffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operations under any grant of exemption. 23. All aircraft operated in accordance with an exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (Nnumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as possible. 24. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the ground control station ofthe sUAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 25. The sUAS must remain clear and yield the right ofway to manned aviation operations and activities at all times. 26. sUAS operations may not be conducted during night, as defined in 14 C.F.R § 1.1. All operations must be conducted undervisual meteorological conditions. Flights under special visual flight rules are not authorized. 27. The sUAS may not be operated by the PIC from any moving device orvehicle. 28. The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute miles from the PIC. 29. The sUAS may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letterof agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letterof agreement with the airport management must be made available to the Administrator upon request. 30. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons otherthan the PIC, VO, operator trainees or essential persons) vessels, vehicles and structures, unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident. The operator must

sUAS Standard Operating Procedures, page 4 of 5ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe sUAS, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearerto the PIC, VO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 31. Any incident, accident, orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported tothe FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: www.ntsb.gov.

sUAS Standard Operating Procedures, page 5 of 5

### APPENDIX C Drone Pilot, LLC Pre-flight Checklist For Small Unmanned Aerial Systems (sUAS)



## 0 FlightAuthority. Obtain proper authority to fly in the airspace ofthe intended flight. 

## 0 Documentation. Copies of all required documentation are available. 

## 0 Eye Protection. Wear safety glasses or other suitable eye protection. 

## 0 Environment. Evaluate the current weather conditions (temperature, wind speed, humidity). Determine that they are within the capability ofthe sUAS and the flight team. 

## 0 Site Assessment. Perform a site assessment to identify any hazards like power lines, trees, cell towers, structures, and hills which could affect GPS reception. If equipped, check for Radio Frequency Interference (RFI). 

## 0 Calibration. If (i) your location has changed more than 

### 200 miles since your lastflight, (ii) you are using your sUAS for the first time out of the box, (iii) you are using your sUAS for the first time since material maintenance has been performed on your sUAS, or (iv) you are using your sUAS for the first time following a hard landing or drop, calibrate the compass. Refer to manufacturers' instruction manual for details. Poweroff once calibration is completed. 

## 0 Inspection ofsUAS. Inspect the sUAS from top to bottom to make sure the frame/canopy is free of cracks or damage. Check that the payload (FPV gearNideo Downlink) is properly secured, all frame screws are present and secured and landing gear is not cracked or damaged. 

## 0 Motors. With the sUAS not powered rotate each propeller slowly by hand for at least one complete revolution. The feel should be slightly bumpy; although it is bumpy it should be consistently bumpy. If a magnet is missing or damaged it mayfeel resistive in that spot or move more freely. All motors should have the same feel of rotational resistance. Ifthere is an issue with a motor DO NOT FLY!

sUAS Pre-flight Checklist, page 1 of2

## 0 Propellers. Inspect all propellers making sure they are installed correctly on the CW or CCW motors. See instruction manual for details. Check propellers for damage on each blade and at the hub. Replace any that are cracked orworn. 

## 0 Battery. Ensure thatthe sUAS flight battery is fully charged and properly installed in the sUAS. 

## 0 Command and Control. Ensure thatthe transmitter is fully charged and powered on. If using ground station (GS) ensure that the system is fully charged and powered. Ensure that the flight programs are running and functioning correctly. Ifapplicable open preprogramed flight plan and ensure all waypoints are set to desired parameters. Disable screen savers. 

## 0 CameraNideo Recording System. Ensure video downlink monitoring system is fully charged and powered. Remove lens caps, power on sUAS on board camera, ensure video downlink is transmitting to GS monitor. Start recording sUAS camera for flight. LAST .........POWER ONsUAS andhave a safe flight. 

### In the eventofa hardlanding orcrash you shouldperlorm a preflightcalibration and inspection again.

sUAS Pre-flight Checklist, page 2 of2

### APPENDIX D 

### Drone Pilot, LLC Post-flight Checklist For Small Unmanned Aircraft Systems (sUAS) 

## 0 Stop recording/power off camera 

## 0 Power OFF sUAS FIRST 

## 0 Power OFF transmitter SECOND 

# 0 Power OFF ground station 

## 0 Document flight in logbook