Mohawk Valley Community College MVCC 333 Letter JUN 2015-Summary Approval Process Filing 150710v2.docx 1 of 35

10 JULY 2015

Seyed Akhavi

Dean of the Center for Science, Technology, Engineering, and Mathematics – STEM

Mohawk Valley Community College

1101 Sherman Drive

Utica, NY 13501

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., 

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 45.23(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 College, 1101 Sherman Drive, Utica, NY, 13501, operator of a 

small Unmanned Aircraft System (sUAS), 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 compensation 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 use 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 - see 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 infrastructure including but not limited 

to electrical power lines, wind turbines and cell towers. 
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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 local 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 NAS. 

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

sUAS 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 Transportation’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, Engineering, and Mathematics – STEM

Mohawk Valley Community College

The name and address of the applicant is: 

Seyed Akhavi

Dean of the Center for Science, Technology, Engineering, and Mathematics – STEM

Mohawk Valley Community College

1101 Sherman Drive

Utica, NY 13501

315.792.5469

sakhavi@mvcc.edu

Enclosure(s)
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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, Engineering, and Mathematics – STEM

Mohawk Valley Community College

1101 Sherman Drive

Utica, NY 13501

sUAS OPERATIONAL DETAILS

Mohawk Valley Community College will operate one or more of the following models of sUAS: 

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 sUAS in scope and the controlled environment provided, the proposed 

operations will adhere to the Reform Act’s safety requirements. 
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The approval of this application 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 

requested 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 operations 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 the 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 120 minutes. Flights will be terminated at 25% battery power reserve or 5 minutes 

of flight time whichever occurs first during the flight operation.

5. Flights will be operated at an altitude of no more than 200 feet Above Ground Level (AGL) OR the 

height of the obstacle from which the PIC is operating, whichever is higher.

6. Minimum 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 (SO). 

7. The UAS pilot in command will be a FAA certificated pilot with at least a sport pilot's license 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 flight activities related to the PIC and VO will be logged using industry best practices of digital 

audio/video via the use of the Mobile Observation Based After Action Review System (MOBAARS) tools 

required by Mohawk Valley Community College flight operations policy.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 
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11. The flights will occur in Class 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 classified as 

restricted, private, or closed.

12. For the purposes of sUAS operations, Mohawk Valley Community College periodically conducts 

"closed set flight operations" (see Appendix A for the applicable CSFOM). When required, the 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 operations. 

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 Transportation 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 appropriate 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 predetermined 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, 

weather, or emergencies such as low battery. 
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FARS FROM WHICH EAGLE EYE SYSTEMS IS REQUESTING 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 procedural 

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 requirements 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 airworthiness 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 airworthiness 

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 civil 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 the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. 

Application 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. 
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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 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. 

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 will 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 others working with the UAS will see the identification of the 

UAS as “Experimental.” 
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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 certificate 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 equivalent level of safety as stipulated by current regulations because the applicant’s UAS do not 

carry any pilots 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 with the proposed operation 

of UAS is far less than the risk levels inherent in the piloting of manned aircraft for commercial activities 

outlined in 14 CFR 61. The PIC of the UAS will be, or be under the direct supervision of, a FAA 

certificated sport pilot with current third class 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 aircraft (sUAS) as intended by FAR and 

approved in preceding petitions.
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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 airworthiness 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 equivalent level of safety will be 

provided. 
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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 configuration 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 keeping the flight manual at the ground control point where the pilot flying 

the UAS will have immediate access to it. 
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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 the 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 weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight.
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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 free 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 equivalent 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. 
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14 C.F.R. § 91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation 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 exemption 

includes a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 

200 AGL, or not more than 200 above a structure involved in the flight operation is planned, an 

exemption may be needed 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 will never operate at higher than 200 AGL with the exception that in 

circumstances where the UAS is used to survey or photograph a structure whose height exceeds 200 

feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It 

will however 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 as 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 will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those 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 Section 91.119. 
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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 altimeter 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 list and live flight data monitoring, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 
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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 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.” 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 equivalent level of 

safety can be achieved 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. 
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14 C.F.R. § 91.203 (a) and (b): Carrying 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 appropriate 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 55lb limit and is operated without an onboard pilot. As such, there is no ability or place to 

carry certification and registration documents 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. 
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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 inspections, 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 because 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 200 

feet AGL. The operator 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 aircraft 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. 
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ADDITIONAL INFORMATION

The applicant, Mohawk Valley Community College, believes this exemption request and associated 

safety considerations 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 respective 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, Technology, Engineering, and Mathematics – STEM

Mohawk Valley Community College

Mailing Address:

Seyed Akhavi

Dean of the Center for Science, Technology, Engineering, and Mathematics – STEM

Mohawk Valley Community College

1101 Sherman Drive

Utica, NY 13501
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APPENDIX A - UASA CLOSED SET FLIGHT OPERATIONS MANUAL (CSFOM)

CLOSED SET FLIGHT 

OPERATIONS MANUAL

PROPRIETARY MATERIAL

JUNE 2015

Revision 4

© UAS Academy
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TABLE OF CONTENTS

(Page numbers in the TOC Reflect "as published" document when used stand-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 Communications 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 Director 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 Responsibilities: ......................................................................................30

APPENDIX A.1 - List of APPROVED PILOTS ..................................................................................................31
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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.................................................................35
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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 Regulations 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 "Mohawk 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 ITS 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 13501
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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 consenting, 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-consenting 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 writing 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 any form of liquid fuel or payload are not eligible for close-in operations.

An example 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 Community College approved area of operations will be the continental United States, 

including Alaska, Hawaii, and all federal territories and military operating bases worldwide.
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Any flight operation that originated in OR terminates in the US NAS or controlled territorial 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 to 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 and 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 owners 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 waived 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 prepared to explain in detail why the three (3) day notification is not practical.
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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 permission 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 obtaining 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 turned 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 with 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 filming 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, formally, 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:
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COMMUNICATIONS DURING FLIGHT 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 operation, 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 distribution 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 assessment 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 will have ATC and VO audio only, and the VO will 

have PIC and SD audio only.
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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 responsibility 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 of activities 

 Aircraft parking and starting 

 Taxi procedures 

 Radio communications 

 Takeoff procedures

 Aviation activities to be conducted during the filming production event 

 Approach and landing procedures 

 Recall procedures

 Mode verification checklist

 Emergency 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 closed 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.) will 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. 
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Pilot Personnel/Minimum Requirements 

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 applicable) 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 BRIEFING

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 briefed 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.

Accident 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.
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FLIGHT PLAN TERMINATION PROCEDURES

Flight Crew Initiated Abort

A simple challenge-response signal will be established for communicating through two modalities the 

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 to 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 assurance 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 Appendix 

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 

for 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 takeoff 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 provisions of the 

waiver. 
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FLIGHT OPERATIONS ORGANIZATION 

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 concerning 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 understand 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 each 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 

Community 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 on 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.
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APPENDIX A.1 - LIST OF APPROVED PILOTS

Pilot Name: James 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:
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APPENDIX A.2 - LIST OF APPROVED AIRCRAFT

REGISTRATION MAKE MODEL LAST sUAS INSPECTION
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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 91.119

SIGNATURE POC NAME POC PHONE POC EMAIL
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APPENDIX B.2 - LIST OF AIRSPACE OWNER WAIVERS GRANTED

GRANTOR ENITITY POC NAME POC PHONE POC EMAIL
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APPENDIX C.1 - DAILY PLAN OF FLIGHT OPERATIONS ACTIVITY