Mohawk Valley Community College MVCC 333 Letter JUN 2015

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10 JULY 2015

Seyed Akhavi Dean of the Center for Science, Technology, Engi neering, and Mathematics

– STEM Mohawk Valley Community College 1101 Sherman Drive Utica, NY 13501

U .S. Department of Transportation Docket Management System 1200 New Jersey A ve., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 4 5.23(b); 14 CFR 61.315(c ); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 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)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Mohawk Valley Community Col lege

, 1101 Sherman Drive, Utica, NY, 13501

, operator of a small Unmanned Aircraft System ( s UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Mohawk Valley Community College, 1101 Sherman Drive, Utica, NY, 13501

, intends to conduct commercial operations of a sUAS for c ompensation or hire as described in the exemption request. The sUAS are equipped with camera(s), sensors, and other avionics that would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private u se including real estate, architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public events, cinematography (closed set operations

- s ee Appendix A for CSFOM) and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastru cture including but not limited to electrical power lines, wind turbines and cell towers.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the loca l authorities or government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to increase awareness and improve safety for current and future UAS operations within the N AS.

As described fully below, the requested exemption would per mit the safe and beneficial operation of the

s UAS as set forth in this document under controlled conditions in the NAS . Using the Maintenance, Operations, Safety, and Training (MOST) manuals of Mohawk Valley Community College

, ensure that the sUAS flight operations would be conducted in a limited, controlled, and predetermined manner in compliance with the conditions of approval and other FARs as applicable

.
Approval of this exemption would increase public education and awareness of sUAS operations, furthering aviation safety through Mohawk Valley Community College participation in voluntary safety reporting activities and data collection, and aid others in fulfilling the Secretary of Transpo rtation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

Sincerely,

Seyed Akhavi Dean of the Center for Science, Technology, Engi neering, and Mat hematics

– STEM Mohawk Valley Community College

The name and address of the applicant is:

Seyed Akhavi Dean of the Center for Science, Technology, Engi neering, and Mathematics

– STEM Mohawk Valley Community College 1101 Sherman Drive Utica, NY 13501 3 15.792.5469 sakhavi@mvcc.edu

Enclosure(s)Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## SUMMARY

FAR EXEMPTION REQUEST LIST

1. 14 CFR Part 21 subpart H

2. 14 CFR 45.23 (b)

3. 14 CFR 61.315 (c)

4. 14 CFR 91.7 (a)

5. 14 CFR 91.9 (b) (2)

6. 14 CFR 91.103

7. 14 CFR 91.109
8. 14 CFR 91.119 (c)

9. 14 CFR 91.121
10. 14 CFR 91.151 (a)

11. 14 CFR 91.203 (a) & (b)

12. 14 CFR 91.405 (a)

13. 14 CFR 91.407 (a) (1)

14. 14 CFR 91.409 (a) (2)

15. 14 CFR 91.417 (a) & (b)



### APPLICANT Seyed Akhavi Dean of the Center for Science, Technology, Engi neering, and Mathematics

– STEM Mohawk Valley Community College 1 101 Sherman Drive Utica, NY 13501



### sUAS OPERATIONAL DETAILS Mohawk Valley Community College will operate one or more of the following models of s UAS:

Aircraft DJI S900; DJI S1000; DJI Phantom 1, 2, 3; DJI Inspire; EOdrones HLH; EOdrones FTX; EOdrones 250 ; EOdrones FTW ; Lockheed Martin Desert Hawk; Lockheed Martin Indago; Prioria Maverick; 3dr Iris; 3dr Solo; 3dr Aero.

Primary Flight Control Systems
DJI aircraft use the DJI Autopilots; EOdrones and 3dr use the 3dr Autopilots; Lockheed Martin and
Prioria use the Lockheed Martin Kestrel autopilots.

Operations Risk Assessment
Given the small size of the s UAS in scope and the controlled environment provided, the proposed operations will adhere to the Reform Act’s safety requirements.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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The approval of this app lication presents no national security issues.

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the
request ed exemption is in the public interest.

Accordingly, the applicant requests that the FAA grant the requested exemption.



### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operat ions will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The UAS will weigh less than 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no more
than 55 knots.

3. Flights will be operated within line of sight of t he Pilot in Command (PIC) and/or Visual Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS model in operation,
but will not exceed 12 0 minutes. Flights will be terminated at 25% battery p ower reserve or 5 minu tes of flig ht time whichever occurs first during the flight operation.

5. Flights will be operated at an altitude of no more than 2 0 0 feet Above Ground Level (AGL) OR the height of the obstacle from which the PIC is operating, whichever is higher.

6. Mi nimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Sensor Operator (S O).

7. The UAS pilot in command will be a FAA certificated pilot with at least a sport pilot's lic ense and a
FAA medical certificate OR a valid driver's license

.

8. A flight planning and safety briefing will be performed prior to each flight consisting of FAR required planning and notifications.

9. All f light activities related to the PIC and VO wil l be logged using industry best practices of digital audio/video via the use of the M obile O bservation B ased A fter A ction R eview S ystem (MOBAARS) tools required by Mohawk Valley Community College flight operations policy.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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11. The flights will occur in Cla ss G airspace no closer than a 3 nautical mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport not cla ssified as restricted, private, or closed.

12. For the purposes of sUAS operations, Mohawk Valley Community College periodically conducts
"closed set fl ight operations" (see Appendix A for the applicable CSFOM). When required, t he operator
will file FAA Form 7711

- 1 ( or its equivalent) with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned sUAS operation s

.

13

. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportatio n required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

14. The PIC and VO will have been trained in operation of UAS and receive up to date information for the particular UAS to be operated.

15

. The PIC and VO will be able to communicate by voice and/or radio at all times.

16

. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriat e governmental agencies as appropriate to flight operations.

17

. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre determined location within a designated location and land autonomously.

18

. The UAS will have the capability to abort a flight in case of emergencies with an automated “Return
Home and Land” function.

19

. The UAS will have the capability to abort a flight (forced landing) in case of unpredicted obstacles,

we ather, or emergencies such as low battery.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## FARS FROM WHICH EAGL E EYE SYSTEMS IS REQ UESTING EXEMPTION
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 C.F.R. § 91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the pro cedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the re quirements of an equivalent level of safety under Part 11 and
Section 333 of the Reform Act.

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthine ss certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular

UAS.

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthi ness certificate in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate
without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area.

Unlike other civ il aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to t he public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.

A pplication of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or "provisional," as applicable 14 C.F.R. § 45.23 (b). Marking of the A ircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the operator mus t also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two inch lettering wi ll be impossible.

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and other s working with the UAS will see the identification of the UAS as “Experimental.”Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 61.315 (c): Sport Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.315 (c ) (1), (2), (3), no person who holds a sport pilot certificat e may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire , operated for compensation or hire, or used in furtherance of a business

. The proposed UAS operations will achieve an equiva lent level of safet y as stipulated by current r egulations because the applicant’s UAS do not carry any pilo ts or passengers for hire, and any property carried would be so insignificant as to not be measureable in terms of aeronautical/operational risk . The risk associated w ith the proposed operation
of UAS is far less than the risk levels inherent in the piloting of manned aircraft for commercial ac tivities
outlined in 14 CFR 61. The PIC of the UAS will be, or be under the direct supe rvision of, a FAA
certificated s port pil ot with current third c lass or higher medical certificate OR a valid driver’s license

. It is believed that the operation and limitations set forth in the operators training program and flight operations manuals will equate to the safe operation of the air craft (sUAS) as intended by FAR and approved in preceding petitions

.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As
there will be no airworth iness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight, an equivalen t level of safety will be provided.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 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. The UAS, given its size and configur ation has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by k eeping the flight manual at the ground control point where the pilot flying
the UAS will have immediate access to it.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure t he safety of flight. As FAA approved aircraft flight manuals will not be provided for the aircraft an exemption will
be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing w eather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight

.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 91.109: Flight Instruction.

Section 91.109 provides that no person may operate a civil aircraft (except a manned f ree balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design may not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio
communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The e quivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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

Section 91.119 establishes safe altitudes for o peration of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exempti on i ncludes a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to

2 00 AGL, or not more than 200 above a structure involved in the flight operation is planned, an exemption may be n eeded to allow such operations. For the purposes of waiver of the minimum safe altitudes, Mohawk Valley Community College further constrains it's flight operations to comply with the UASA Closed Set Flight Operations Manual (see Appendix A).

As set forth herein, the UAS wil l never operate a t higher than 2 00 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exc eeds 2 00 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It
will h owever be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS a s well as the location where it is operated. No flight will be taken without the permission of the property owner or
local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals wi ll be aware of the planned flight operations. Compared to flight operations wi th aircraft or rotorcraft weigh ing far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than th ose presently presented with conventional aircraft operating at or below 500 AGL.

In addition, the low altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Se ction 91.119.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 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 altim eter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check lis t and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from begin ning “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.” The applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. The applicant believes that an equivalen t level of safety can be ac hieved by limiting flights to 5 minutes or 25% of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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14 C.F.R. § 91.203 (a) and (b): Carryi ng Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An app ropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section 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. The UAS fully loaded weighs well under the proposed 55 lb limit and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration docume nts or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspe ctions, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved becau se the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 2 00 feet AGL. The operato r will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircr aft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## ADDITIONAL INFORMATI ON
The applicant, Mohawk Valley Community College , believes this exemption request and associated safety cons iderations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, providing sufficient justification for the granting of commercial operations of the applicant’s UAS.

The applicant, Mohawk Valley Community College , requests your re spective approval of this Section 333 exemption petition request.

Please notify Mohawk Valley Community College of your actions, and or approvals.

Thank You for your interest in this request.

Sincerely,

Seyed Akhavi Dean of the Center for Science, Tec hnology, Engi neering, and Mathematics

– STEM Mohawk Valley Community College

Mailing Address:

Seyed Akhavi Dean of the Center for Science, Technology, Engi neering, and Mathematics

– STEM Mohawk Valley Community College 1101 Sherman Drive Utica, NY 13501Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## APPENDIX A

- UASA CLOSED SET FLIG HT OPERATIONS MANUAL (CSFOM)



# CLOSED SET FLIGHT
OPERATIONS MANUAL

PROPRIETARY MATERIAL

JUNE 2015 Revision 4

© UAS AcademyMohawk Valley Community College MVCC 333 Letter JUN 2015

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## TABLE OF CONTENTS (Page numbers in the TOC Reflect "as published" document when used s tand

- alone)

INTRODUCTION

................................ ................................ ................................ ................................ ........... 22

Purpose

................................ ................................ ................................ ................................ ................... 22

Waiver of Authorization

................................ ................................ ................................ .......................... 22

Owner

................................ ................................ ................................ ................................ .................. 22

Operator

................................ ................................ ................................ ................................ .............. 22
Director of Operations

................................ ................................ ................................ ........................ 22

Persons Authorized

................................ ................................ ................................ ............................. 23
Area of Operations

................................ ................................ ................................ ................................ .. 23

Plan of Activities

................................ ................................ ................................ ................................ ...... 24

Permission to Operate

................................ ................................ ................................ ............................ 25

Security

................................ ................................ ................................ ................................ ................... 25

STERILE COCKPIT and CREW RESOURCE MANAGEMENT

................................ ................................ ....... 25

COMMUNICATIONS DURING FLIGHT OPERATIONS

................................ ................................ ................ 26
Lessons Learned Impact Closed Set Operations

................................ ................................ ................. 26
Recommended Cockpit Communicat ions Infrastructure

................................ ................................ ... 26
Briefing of Pilot/Production Personnel

................................ ................................ ................................ ... 27
Certification/Airworthiness

................................ ................................ ................................ .................... 27
Pilot Personnel/Minimum Requirements

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

FLIGHT PLANNING

- SET PERSONNEL BRIEFING

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

Accident Notification

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

FLIGHT PLAN TERMINATION Procedures

................................ ................................ ................................ 29
Flight Crew Initiated Abort

................................ ................................ ................................ .................. 29

Set Direc tor Initiated Termination

................................ ................................ ................................ ...... 29
Aerobatic Competency

................................ ................................ ................................ ........................... 29
Special Provisions

................................ ................................ ................................ ................................ .... 29

FLIGHT OPERATIONS ORGANIZATION

................................ ................................ ................................ ......... 30
DIRECTOR OF OPERATIONS Duties and Responsibilities:

................................ ................................ ....... 30
Pilot in Command Duties and Responsibilitie s:

................................ ................................ ...................... 30

APPENDIX A.1

- List of APPROVED PILOTS

................................ ................................ ................................ .. 31Mohawk Valley Community College MVCC 333 Letter JUN 2015

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APPENDIX A.2

- List of APPROVED AIRCRAFT

................................ ................................ ............................. 32

APPENDIX B.1

- List of WAIVERs FOR CLOSE

- IN OPERATIONS

................................ ................................ .... 33

APPENDIX B.2

- List of AIRSPACE OWNER WAIVERs GRANTED

................................ ................................ .. 34

APPENDIX C.1

- DAILY PLAN OF FLIGHT OPERATIONS ACTIVITY

................................ ................................ . 35Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## INTRODUCTION

Purpose This manual has been developed by the UAS Academy to facilitate sUAS operations with reduced distances defined in Federal Aviation Regulati ons 14 CFR 91.119. This manual contains specific operational requirements BEYOND THOSE NORMALLY USED in the operation on sUAS under FAR, MOST, and UASA policy and procedure. The operator is " Mohawk Valley Community College ", hereafter
referred to as " Moh awk Valley Community College ", who is operating a sUAS in conjunction with either (1) an approved PL112

- 95 Section 333 Exemption and COA, or (2) an application for a Certificate of Waiver of Authorization of the provisions of FAR 91.119 (b) and (c) for the purposes of filming.

THIS MANUAL WHEN ADOPTED IN IT S ENTIRITY IS THE ALTERNATE MEANS OF COMPLIANCE WITH THE INTENT OF FAR 91.119 IN ORDER TO ACHIVE AN EQUIVALENT LEVEL OF SAFETY



### Waiver of Authorization Mohawk Valley Community College pilots and other company personnel when applicable will comply with the policies, procedures and conditions of this manual, whenever motion picture or television flight operations are performed that require a Waiver of Authorization as mentioned above.

Owner Mohawk Valley Community College 1101 Sherman Drive Utica, NY 13501

Operator Mohawk Valley Community College 1101 Sherman Drive Utica, NY 13501

Director of Operations Jim Blanchard , ScD Special Assistant to the Dean of the Center for

– STEM Mohawk Valley Community College 1101 Sherman Drive Utica, NY 13501Mohawk Valley Community College MVCC 333 Letter JUN 2015

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Persons Authorized FAR 91.119 (c) can be waived only with respect to those persons, vehicles and structures directly involved in the performance of the actual filming. The certificate holder shall ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. Each flight operation will complete the table in Appendix B.1 for all those conse nting, and those not consenting will be required to remain at least 500 feet or more away from the operation in accordance with FAR 91.199 minimum distances as appropriate.

For flight operations requiring sUAS operations closer than 500 feet to non

- conse nting persons or property owners, this provision may be reduced to no less than 200 feet if an equivalent level of safety can be achieved and the Administrator or designated representative has approved it. For example, an equivalent level of safety may be determined by an FAA Aviation Safety Inspector's (ASI) evaluation of the filming production area to note terrain features, obstructions, buildings, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) and non

- consenting property owners from sUAS vehicles or moving debris in the event of an accident.

In order to operate inside the 200' barrier either a flight line operational path and trajectory assessment completed by the pilot in command and agreed to in writ ing by the operator's director of operations, OR an approved physical barrier rated for impact forces is required for non

- participating person protection.

Aircraft carrying an y form of liquid fuel or payload are not eligible for close

- in operations.

An ex ample of non

- participating persons would a flight demonstration filming operation where an audience is involved. Typical protective barriers include mesh netting that meets or exceeds the following specification:



### Area of Operations Mohawk Valley Commun ity College approved area of operations will be the continental United States, including Alaska, Hawaii, and all federal territories and military operating bases worldwide.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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Any flight operation that originated in OR terminates in the US NAS or controlled t erritorial airspace areas without regard for the enroute or operational area is considered to be an operation required to comply with the operational procedures in this closed set flight operations manual.



### Plan of Activities At least three (3) days prior t o any scheduled filming, Mohawk Valley Community College will submit a written plan of activities to the local FSDO having jurisdiction over that area. The plan of activities should include the following:

(1) Dates and times for all flights.

(2) Name an d phone number of person responsible for the filming production event.

(3) Name and phone number of person responsible for aircraft.

(4) Make, model, and serial or N

- number of aircraft to be used and type of airworthiness certificate, including category.

(5) Name and certificate number of pilots involved in the filming production event, including any notation of external load endorsements or aerobatic competency, if required.

(6) A statement that the waiver holder has obtained permission from property o wners and/or local officials to conduct the filming production event. The list of those who gave permission must be made available to the inspector upon request from the waiver holder.

(7) Signature of waiver holder or representative.

(8) A description of the flight activity including maps or diagrams of any area, city, town, county, and/or State over which filming will be conducted and the minimum altitudes essential to accomplish the operations.

The three (3) day notification requirements may be waiv ed by the Mohawk Valley Community College Director of Operations (operator) and the FSDO by mutual written agreement. Should the 3

- day requirement pose a production delay the operator should contact the FSDO as soon as possible with this request and be pr epared to explain in detail why the three (3) day notification is not practical.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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### Permission to Operate Before any flight operations is conducted at less than the minimum distances specified in FAR 91.119, or closed than the 500 feet specified under the provisions of the certificate of waiver and this manual, the operator will obtain permission to conduct these operations from property owners and/or local officials as necessary or appropriate. When possible, a written record (such as text message, email, etc) is to be kept with the full name and contact information of those from whom permission was granted. When not possible, the pilot in command or the director of operations is to log the conversation in Appendix B.2 of this manual. Persons from whom p ermission may be required are listed below:

 Property owners

 Law enforcement officials

 Fire department officials

 Local, State and Federal government

 Air traffic control

A standard permission form is provided in Appendix B.2 and may be used when obtain ing written permission. Mohawk Valley Community College personnel will assure a sufficient number of those forms are available at the job site. Written permission forms will be maintained at the job site until flight operations are completed, and then tu rned into the chief pilot to be kept on file for a minimum of six (6) months. These forms will be made available for inspection by the FAA or other official personnel
upon request.



### Security Prior to any flight operation the operator will coordinate wit h appropriate production personnel to devise a plan of securing the area(s) of operation from all unauthorized persons and vehicles. Provisions will be made to immediately discontinue operations should the area(s) become unsecured or for any
other reason in the interest of safety.



### STERILE COCKPIT and CREW RESOURCE MANAGEMENT All flight operations are to be conducted with the utmost concern for avoiding distractions of the flight crew. In filming operations, it is often the case that the director of film ing will seek to inject operational commands into the flight crew environment in order to gain improved filming results. Therefore, it is a requirement that anyone who can gain access to the flight crew during airborne operations is briefed in advance, fo rmally, on the concept and federal regulations regarding interference with, and distraction of a flight crew while performing its duties. To the extent possible, the following operational procedures and settings will be used:Mohawk Valley Community College MVCC 333 Letter JUN 2015

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### COMMUNICATIONS DURING FLIG HT OPERATIONS Flight crew should be isolated from set operations, connected by headsets tied to the single point of contact for the filming and/or direction of camera/sensor.

Lessons Learned Impact Closed Set Operations
In a traditional manned aircraft o peration, the dynamic control of the aircraft is handled by the Pilot Flying (PF) while to operational control and radio communications of the mission or flight plan is handled by the Pilot Not Flying (PNF). This has been shown to be the appropriate distr ibution of workload while reducing the probability of human error and increasing cockpit communications effectiveness. Part of the constraint in manned aviation is the space on the flight deck available for additional flight crew. sUAS operational assess ment data indicates that on closed set operations where space for additional personnel is available the most effective and safe method of distributing workload
is to have a 2

- person flight crew. Retaining the conventions of manned aviation for the naming of the positions within the crew, Mohawk Valley Community College will use the term PF and PNF as an indicator of workload task assignments, not implying who is the PIC or VO within that context.

Recommended Cockpit Communications Infrastructure Typically the Pilot In Command (PIC) will have an open microphone to the Visual Observer (VO), and vice versa. The PIC will have a push to talk switch for ATC communications, while the VO will have a push to talk switch for Set Director (SD) communications. PIC w ill have ATC and VO audio only, and the VO will have PIC and SD audio only.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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### Briefing of Pilot/Production Personnel Prior to the start of any operation under the provisions of this manual, the pilot in command will conduct a briefing of all procedures to participating personnel of the risks involved, emergency procedures, and safeguards to be followed during the filming production event. Personnel will also be briefed on additional provisions that may be issued by the FSDO that has geographic responsib ility for the operational area, including the location of boundaries or time limits. The briefing shall cover:

 FAA Form 7711

- 1, Authorization for motion picture and television certificate of waiver  FAA waiver special provisions  Operations manual  Plan o f activities  Aircraft parking and starting  Taxi procedures  Radio c ommunications  Takeoff procedures  Aviation activities to be conducted during the filming production event  Approach and landing procedures  Recall procedures  Mode verification checklist  E mergency procedures  Risks to participating personnel  How to control nonparticipating persons



### Certification/Airworthiness

All Mohawk Valley Community College aircraft used in operations requiring a waiver of FAR 91.119 (b) and (c) for the purpose of cl osed set filming will be properly certified and hold airworthiness certificates or exemption under Section 333 including the appropriate airworthiness certification statement. The
aircraft will be maintained in a periodic comprehensive progressive 50/100 / annual inspection program designed for the sUAS as a system

. Other required tests and inspections ( Ground Station, Telemetry,

etc. ) w ill be performed as per FAR when necessary and scheduled in the progressive maintenance

program . Each aircraft will have a flight log containing upcoming scheduled maintenance and inspections and the dates or times they must be performed. Aircraft progressive maintenance is documented using MOBAARS. A section for discrepancies is also found in the flight log as required by

FAR . The pilot in command will assure the sUAS (as a system

- ground station, telemetry, and aircraft ) to be flown is in airworthy condition and all required inspections and maintenance has been completed before each flight.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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### Pilot Personnel/Minimum Re quirements The pilot/operator shall establish and specify the minimum pilot requirements. Minimum requirements shall meet or exceed the following:

 A current U.S. Commercial pilot certificate with ratings appropriate to the category, class and type (if a pplicable) of aircraft to be used.

 A minimum of 100 hours in the category of aircraft to be used, for sUAS the category is Fixed Wing OR MultiCopter

.

 A minimum of 5 hours in the make and model aircraft to be used.



### FLIGHT PLANNING

- SET PERSONNEL BRIEFI NG Prior to the start of any operation covered by this manual, the pilot in command will reaffirm the sterile cockpit rule, Crew Resource Management (CRM) culture, and document (using MOBAARS or some other appropriate AVD recorder) the flight plan in order to provide CRM capability to all participants during the actual operation and filming.

Oral, visual, ground control station telemetry, and radio communications used to facilitate required operational communications are required to be specifically briefe d to ensure the methods are effective and are capable of keeping the participants continuously informed of the current status of the operation, ultimately ensuring effective aeronautical decision making in accordance with FAR and safety practices.



### Acciden t Notification Should an accident or incident requiring notification of the NTSB occur, the notification requirements of FAR Part 830 would apply to all flight crew, as would any additional requirements of the sUAS exemption terms and conditions placed on the operator by the FAA or applicable safety management system or safety reporting system.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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### FLIGHT PLAN TERMINATION P R OCEDURES

Flight Crew Initiated Abort A simple challenge

- response signal will be established for communicating through two modalities t he intent to "abort" the flight operation. Line of sight flag movements by the flight crew combined with a broadcast of "Aborting Flight Operations

- Returning to Home" or "Aborting Flight Operations

- Landing In Place" will be communicated by the flight crew to the Set Director as soon as practical.

Set Director Initiated Termination In the event the Set Director chooses to recall the sUAS, that request will be sent to the flight crew using the statement "Request Aircraft Recall" to which the flight crew will respond timely with "ROGER; WILCO; Aborting Flight Operations

- Returning to Home" or another response as appropriate.



### Aerobatic Competency If the filming operations require the issuance of FAA Form 8710

- 7, Statement of Aerobatic Competency,
refer t o Volume 5, Chapter 9, Issue/Renew/Rescind a Statement of Aerobatic Competency.



### Special Provisions

1. The controls, procedures, and conditions set forth in the Mohawk Valley Community College motion picture and television operations manual is the primary as surance that persons on the surface will not be jeopardized.

2. The aircraft and pilots used under this authorization and/or waiver will only be those specified in the Mohawk Valley Community College motion picture and television operations manual (see Appen dix A.1) or associated plan of activities.

3. Each pilot’s name and certificate number shall appear on each daily plan of activity (Appendix C.1).

4. All civil aircraft and pilot(s) participating in the activity shall be listed in Appendix A.2 and available
fo r FAA inspection before the scheduled event.

5. Each pilot

- in

- command conducting operations authorized under this certificate understands the conditions of issuance, and that it constitutes a waiver of FAR 91.119 (b) and (c) (see Appendix B.1).

6. Rotorcraft t akeoff and landing areas will be protected in a manner that will prevent unauthorized persons from entering the takeoff and landing area.

7. Mohawk Valley Community College will ensure that the participating persons involved in the operations are thoroughly briefed on special procedures, communication, emergency procedures, and on the provisions of the authorization and/or waiver before beginning the activities. No person may participate in any event unless that person has received a briefing on the provision s of the

waiver.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## FLIGHT OPERATIONS OR GANIZATION

DIRECTOR OF OPERATIONS Duties and Responsibilities:

1. Required to be a named and qualified pilot in all aircraft stated in this manual and FAR.

2. Final word in the formulation of policy and procedures concer ning this manual.

3. Act as liaison between Mohawk Valley Community College and the FAA on matter concerning this
manual.

4. Assure that each approved pilot is issued a copy of this manual and obtain a signed statement from each that they have read and underst and its contents.

5. Maintain a current copy of this manual at the main base of operations for Mohawk Valley Community College

. 6. Responsible for assuring that all revisions to this manual are distributed and processed properly.

7. Must approve or disapprove ea ch proposed job or operation performed by Mohawk Valley Community College under the provisions of this manual.

8. The director of operations may delegate functions to other personnel but retains responsibility.



### Pilot in Command Duties and Responsibilities:

1. Assure that aircraft to be flown are in airworthy condition and all inspections and required maintenance have been performed as per appropriate FAR's and Mohawk Valley Community College MOST documents.

2. Acquire permission from the director of operations before any operation under the provisions of
this manual.

3. Have demonstrated knowledge, skill, and abilities to comply with the contents of this manual and abide by the procedures, policies and conditions contained herein and within the Mohawk Valley

Commu nity College MOST documents.

4. Coordinate with movie and television personnel to formulate plans, routes, locations, etc. with safety of all persons involved in the primary concern.

5. Maintain their copy of this manual in the most recent version and have it o n site at any job or operation where closed set flight operations are being conducted.

6. The pilot in command may delegate functions to other personnel, but retains responsibility.Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## APPENDIX A.1

- LIST OF APPROVED PIL OTS

Pilot Name : J a mes W. Blanchard

Certificate Number: 225988299

Grade : Commercial

Medical Class/Date : 06/2014

Contact Number : 703 856 8400

Pilot Name :

Certificate Number:

Grade :

Medical Class/Date :

Contact Number :

Pilot Name :

Certificate Number:

Grade :

Medical Class/Date :

Contact Number :Mohawk Valley Community College MVCC 333 Letter JUN 2015

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## APPENDIX A.2

- LIST OF APPROVED AIR CRAFT

REGISTRATION MAKE MODEL LAST sUAS INSPECTIONMohawk Valley Community College MVCC 333 Letter JUN 2015

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## APPENDIX B.1

- LIST OF WAIVERS FOR CLOSE

- IN OPERATIONS

By Entering My Name Below I Agree To sUAS Operations Closer To Me Than Specified in FAR 9 1.119

SIGNATURE POC NAME POC PHONE POC EMAILMohawk Valley Community College MVCC 333 Letter JUN 2015

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## APPENDIX B.2

- LIST OF AI RSPACE OWNER WAIVERS GRANTED

GRANTOR ENITITY POC NAME POC PHONE POC EMAILMohawk Valley Community College MVCC 333 Letter JUN 2015

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## APPENDIX C.1

- DAILY PLAN OF FLIGHT OPERATIONS ACTIVITY