LAW OFFICES OF WAYNE A. JOHNSON 

WAYNE A. JOHNSON, ATIORNEY 

2901 W. PARKER ROAD #864434 

PLANO, TEXAS 75086 

214.454.3292 WAJ.USALAW@GMAIL.COM 

June 4, 2015 

Docket Management Facility 

U. S. Department ofTransportation 

1200 New Jersey Ave. 

SE West Building Ground Floor Room W12-140 

Washington, DC 20590 

Re: Exemption request under Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Drone Pilot, LLC hereby applies for an exemption from the Federal Aviation Regulations 

(F ARs) listed below and discussed in Appendix A. Exemption is being sought in order to allow 

Drone Pilot to 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 with potential hazards, eliminating the risk of injuries. They 

also allow the safe inspection of hard-to-access or environmentally sensitive areas without the 

use of trucks and other utility vehicles. Overall, sUAS can provide significant benefits to workers 

and customers over these traditional methods. 

Drone Pilot proposes to use rotor and fixed wing aircraft, which crafts have a maximum takeoff 

weight ofless than 55 pounds, will be operated at a speed of no 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 subject to strict operating parameters to ensure at least 

an equivalent level of safety to currently authorized operations using manned aircraft. 

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The name and mailing address of the petitioner, Drone Pilot, is: 

Drone Pilot, LLC 

Attn: Ed Tovar 

Ph.: 512.431.0545 

Email: etovar@dronepilot.io 

Address: 6905 Mesa Drive, Austin, Texas 78731 

The regulations from which the exemption is requested are listed below. These are more fully 

discussed in Appendix 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 aircraft produced by industry recognized companies that are 

placed on the market from time-to-time. All craft will (i) weigh under 55 pounds with energy 

sources and equipment, (ii) have stable platforms and common characteristics of reliability, 

stability and safety, and (iii) be supported by extensive manufacturers' operation manuals/user 

guides. 

Use of these sUAS is subject to 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 by the FAA 

• manufacturers' operation manuals/user guides for each aircraft 

• operating parameters, conditions and limitations contained in the Petition 

• flight and safety processes and procedures published by reputable UAS organizations 

such as the Academy of Model Aeronautics and the Association for Unmanned Vehicle 

Systems International. All courses will include both classroom and hands-on training. 

sUAS of this weight category generally have common characteristics. Each can be operated by 

toggle or entirely by a touch-screen, map-based interface. This means the operator only needs to 

command the system where to go, and the system does all the flying for the operator. They can 

be operated in both semi and fully autonomous flight modes, with the operator simply clicking 

on a map to create a pre-planned flight path for a flight. In addition, the operator can create no 

fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe 

or unnecessary to fly over. 

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In addition, the sUAS have built-in intelligent fault handling capabilities which allow them to 

detect a system fault while in the air and automatically fly back to its take-off location and land. 

Faults that can be detected include: loss of communication; exceeding pre-set wind thresholds; 

and low battery levels. 

All flight operations are global positioning system (GPS) controlled, making the systems easy to 

navigate. At any point if the operator is not explicitly commanding the rotorcraft system to 

move, the system automatically holds its GPS position. The flight control system employs not 

only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, 

wind speed and others to ensure stability so long as wind thresholds are not exceeded. 

Industry recognized producers of sUAS of this category generally maintain online product 

information portals with comprehensive downloadable operating and maintenance manuals, user 

guides, flight checklists, safety information and mission planning instructions. Often available 

are instructional product and training videos along with robust online blogs and product forums. 

Operating Documents. Comprehensive operation manuals/user guides for aircraft of this 

category are always available on the internet at the 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 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, in a manner consistent with 14 

CFR 61.51(b), a minimum of25 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 of fixed wing aircraft, have accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), a minimum of25 hours of total time as a sUAS fixed wing pilot 

and at least 10 hours logged as a sUAS pilot with a similar sUAS type 

• have accumulated and logged a minimum of five hours as a sUAS pilot with the make 

and model of sUAS to be utilized for operations under the exemption and three take-offs 

and landings in the preceding 90 days prior to an operation 

• as noted below in "Operating Parameters; Conditions and Limitations", the operator will 

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 under the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

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Visual observers must have demonstrated that they understand the conditions and limitations of 

flight noted below in "Operating Parameters; Conditions and Limitations". 

Operating Parameters; Conditions and Limitations. Grant of the exemptions will be subject 

to the following conditions, which provide at least an equivalent or higher level of safety than 

under the current conditions. These conditions are drawn from Exemptions 11 062 through 

11067, 11080, 11109 and 11110. For purposes of this listing, Drone Pilot is referred to as the 

operator. 

1. Operations authorized by the grant will be limited to the sUASs described above and 

manufacturers' upgraded versions. 

2. The sUAS must weigh 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 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. 

5. The sUAS must be operated within visual line of sight (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. 

6. All operations must utilize a visual 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 that the VO can perform the functions prescribed in the 

operating documents. 

7. The operating documents and this 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 to the Administrator upon request. If there 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. If the operator determines that any update or revision would affect the 

basis upon which the FAA grants this exemption the operator must petition the FAA 

for amendment to the exemption. 

8. Prior to each flight the PIC must inspect the sUAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 

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. 

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9. Any sUAS that has undergone maintenance or alterations that affect the sUAS 

operation or flight 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 of the flight. 

10. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable 

components, items or equipment not already covered in the relevant sections of the 

operating documents. 

11. The operator must follow the sUAS manufacturer's aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

12. 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 of work done, 

discrepancies between inspections, and the identification of the authorized person 

returning the sUAS to service. 

13. Each sUAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

14. The PIC must hold either a current FAA recreational or sport pilot certification or 

higher FAA pilot certification and a valid driver's license The PIC must also meet 

the flight review requirements 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 published by reputable UAS organizations such as the Academy of Model 

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 demonstrated that 

the PIC is able to safely operate the sUAS in a manner consistent with how the sUAS 

will be operated under the 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 of time 

the sUAS can be flown and still maintain a reserve battery power of no less than 20%. 

18. The operator will file a request for a Notice to Airmen (NOT AM) 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 with the 

FCC or other appropriate governmental oversight agency requirements. 

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20. 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, where necessary or appropriate. 

Currently flight training is being conducted at an AMA field in the Austin, Texas 

area. 

21. If the sUAS loses communications or loses the GPS signal, the sUAS must return to a 

pre-determined location or take-off point or be recovered in accordance with the 

operator's manual. 

22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this grant of 

exemption. 

24. All aircraft operated in accordance with this 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. 

25. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the ground control station of the sUAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

26. The sUAS must remain clear and yield the right of way to manned aviation operations 

and activities at all times. 

27. sUAS operations may not be 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 may not be operated by the PIC from any moving device or vehicle. 

29. The sUAS may not be operated less than 500 feet below or less than 2,000 feet 

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

30. The sUAS may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport's management is obtained, and the operation is conducted in 

accordance with a NOT AM as required by the operator's COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, VO, operator trainees or essential persons) 

vessels, vehicles and structures, unless: 

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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 ensure 

that nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the sUAS, 

flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119( a). 

32. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the 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. 

The Public Interest. The public interest in granting this exemption request is served by, among 

others, the following: 

• Congress has established a national policy that favors early integration of sUAS into 

the NAS- pending completion of the statutorily required rulemaking for such 

integration, exemption requests such as this one by Drone Pilot (and many others) are 

integral in developing and in moving this policy along 

• The use of sUAS improves public safety and reduces 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 commercialization of the NASby sUAS will provide additional job and 

career opportunities for our nation's population 

• Resulting ecological and environmental benefits such as precision inspections and 

assessments of fuel-laden pipelines, rights-of-way, energy production platforms, along 

with coastal marine environment observations for conservation purposes 

• Harnessing the power of new technologies and providing challenges to our nation's 

entrepreneurs and developers 

• Drone Pilot's pilot and visual observer training (as noted in operating parameter #15 

above) will enhance the safety of sUAS flight and will serve to minimize the risk to the 

NAS and to persons and property on the ground 

Summary for publication. For publication in the Federal Register Drone Pilot provides the 

following summary. An exemption is requested from the following regulations in order to allow 

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commercial operations of its unmanned aircraft systems involving aerial applications such as 

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. Given the small size of the sUASs involved and the restricted environment within 

which they will operate, this petition falls squarely within that equivalent level of safety in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs 

to commence immediately. 

Too, given the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, the strong equivalent level of safety surrounding the proposed operations, 

and the significant public benefit of the various applications, including enhanced safety, 

reduction in environmental impacts by fuel laden vehicles, including reduced emissions, the 

public value of the unmanned aerial vehicle industry, the grant of the requested exemption is in 

the public interest. 

Drone Pilot seeks an exemption from the listed and discussed F ARs to operate commercially the 

small unmanned aircraft systems in the aerial operations set forth herein. 

Thank you. 

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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) limit private pilots to non-commercial operations. Section 61.133(a) 

requires an individual with a commercial pilot's license to be pilot in command of an aircraft for 

compensation or hire. 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 or cargo 

on board. 

Drone Pilot respectfully requests exemptions from these requirements based on the particular 

characteristics of the sUAS that will be used. The risks associated with the operation of the 

sUAS described above (given the size, speed, operational capabilities and lack of combustible 

fuel) are much lower than the risks associated with commercial operations contemplated by Part 

61 with conventional aircraft. Accordingly, a recreational or sport pilot, adequately trained in the 

proper use of sUAS, possesses the requisite skills and knowledge of the NAS and FAA 

regulations to assure the safe operation of the sUAS. In addition, Drone Pilot will use the 

identified sUAS with a high degree of control and various built-in technical capabilities that 

strictly limit the potential for operation outside of the operating conditions set forth in this 

Petition. 

Drone Pilot emphasizes sUAS training and flight experience for those PICs who will operate 

these aircraft in the proposed commercial applications. By requiring extensive flight experience 

with these aircraft prior to conducting commercial operations, these PICs will have a better grasp 

of the handling of the aircraft than they would by holding a commercial pilot license for an 

entirely different type of airborne system. 

Given the inherently lower-risk nature of the sUAS and these training, experience and safety 

features, Drone Pilot proposes that operators should not be required to hold a commercial pilot 

certification. Instead operators should be required to hold only a recreational or sport pilot 

certification and have the experience with the sUASs as indicated in this Petition. 

The risks associated with the operation of the sUAS identified herein (given their size, weight, 

speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of 

risk associated with commercial operations contemplated by Part 61 with conventional aircraft 

(rotorcraft or fixed wing) that allowing operations of the sUAS as set forth above meets or 

exceeds the present level of safety provided under 14 CFR § 61.113(a) and (b) and does not rise 

to the level of requiring a commercial pilot to operate under§ 61.133(a). 

Given these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of the sUAS identified herein with a private pilot's certificate, under the 

conditions set forth in this Petition. The FAA has granted exemption to conduct similar 

operations in Exemptions 11062 through 11067, 11080, Ill 09 and 11110. 

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14 CFR § 91.7(a): Civil Aircraft Airworthiness 

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the named 

aircraft without an airworthiness certificate, no standard will exist for airworthiness of the 

aircraft. Given the size of the aircraft and the requirements that the operator has agreed to as 

relates to airworthiness, as set forth herein and in the various operating documents, an equivalent 

level of safety will be achieved by ensuring compliance with the aircraft manuals and operating 

documents for each flight. The FAA has 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 of civil aircraft. Section 91.119 (c) 

prohibits operations below 500 feet above the surface, or closer than 500 feet to any person, 

vessel, vehicle or structure. As this exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. The equivalent level of safety will 

be achieved given the size, weight, speed of the sUAS as well as the location where it is 

operated. No flight will be taken without the permission of the property owner or local officials, 

where required. Because of the advance notice to the property owner and participants, all 

affected individuals will be aware of the planned flight operations as set forth in the plan of 

operations. Drone Pilot therefore requests a waiver from Section 91.119(c) for all participating 

persons, i.e., persons associated with the operations. 

Drone Pilot will also ensure that non-participating persons are kept at least 500 feet from the 

operating area, or seek approval from the Administrator for less separation if an equivalent level 

of safety can be achieved. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maximum of less than 55 pounds proposed herein and the lack of flammable fuel, 

any risk associated with these operations is far less than those risks associated with the 

conventional methods. In addition, the low-altitude operations of the sUAS will ensure 

separation between these sUAS operations and the operations of any conventional aircraft that 

must comply with Section 91.119. 

14 CFR §91.121: Altimeter Settings 

This regulation requires 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." As the sUAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the operator confirming the acquisition of GPS signals and an initial ground 

level altitude of zero prior to take-off. The FAA has granted exemptions to conduct similar 

operations in Exemptions 11062 through 11067 and 11080. 

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "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." 

10 I Page 
APPENDIX B 

Drone Pilot, LLC 

Standard Operating Procedures 

For Small Unmanned Aircraft Systems (sUAS) 

The flight team. The flight team will consists of a pilot in command (PIC}, a visual 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 of total 

time as a sUAS rotorcraft pilot and at least 10 hours logged as a sUAS pilot with a similar 

sUAS type 

• ,in the case of fixed wing aircraft, have accumulated and logged a minimum of 25 hours 

of total 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 under the exemption and three take-offs 

and landings in the preceding 90 days prior to an operation 

• the operator will 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 under the 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 of flight 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 5 
2. 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 of sight (VLOS} of the 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 a visual 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 that the 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 to the Administrator upon request. If there 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. If the 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. Prior to each flight the PIC must inspect the sUAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 

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 or flight 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 of the 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 of the operating documents. 

sUAS Standard Operating Procedures, page 2 of 5 
10. 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 of work 

done, discrepancies between inspections, and the identification of the authorized 

person returning the sUAS to service. 

12. Each sUAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. The PIC must hold either a current FAA recreational or sport 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 under the 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 prior to the operation. 

18. The radio frequency spectrum used for operation of the 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. If the sUAS loses communications or loses the GPS signal, the sUAS must return to a 

pre-determined location or take-off point or be recovered in accordance with the 

operator's manual. 

sUAS Standard Operating Procedures, page 3 of 5 
21. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

22. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to 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 of the 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 of way 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 under visual 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 or vehicle. 

28. The sUAS may not be operated less than 500 feet below or less than 2,000 feet 

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

29. The sUAS may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport's management is obtained, and the operation is conducted in 

accordance with a NOT AM as required by the operator's COA. The letter of 

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 other than 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 5 
ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet 

of the sUAS, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per§ 91.119(a). 

31. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be 

reported to the 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 Flight Authority. Obtain proper authority to fly in the airspace of the 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 of the 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 last flight, 

(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. Power off 

once calibration is completed. 

0 Inspection of sUAS. 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 may feel resistive in 

that spot or move more freely. All motors should have the same feel of rotational 

resistance. If there is an issue with a motor DO NOT FLY! 

sUAS Pre-flight Checklist, page 1 of 2 
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 or worn. 

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

sUAS. 

0 Command and Control. Ensure that the 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. If applicable 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 ON sUAS and have a safe flight. 

In the event of a hard landing or crash you should perlorm a preflight calibration and 

inspection again. 

sUAS Pre-flight Checklist, page 2 of 2 
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