F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 1 of 10

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, D.C. 20590

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the

Federal Aviation Regulations, Seeking Exemption from:

14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 21.191(a); 14 C.F.R. § 45.23(b); 14

C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.l 19(c); 14 C.F.R.

§ 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l);

14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b).

THE AIRCRAFT

F.P. VILLANO CONSULTING ENGINEER, LLC specifically proposes to

conduct aerial photography and surveys for engineering studies, forensic 

engineering purposes, real estate, and insurance industries with sUASs 

including the DJI Phantom 3 Professional series rotorcraft.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), 

F.P. VILLANO CONSULTING ENGINEER, LLC (the operator), Frank P. Villano, P.E. (the

applicant), planned operator of Small Unmanned Aircraft Systems (sUASs) equipped to 

conduct aerial photography and survey for engineering studies, forensic engineering purposes, 

real estate, and insurance industries, hereby applies for an exemption from Federal Aviation 

Regulations (FARs) to allow commercial operation of their sUASs, so long as such operations 

are conducted within and under the conditions outlined herein or as may be established by the

FAA as required by Section 333.

This requested exemption follows the language of exemptions Pursuant to Section 333 that have 

previously been approved by the FAA.

As described more fully below, the requested exemption would permit the operation of sUASs 

by the applicant for commercial use that would provide the following benefits:

1. Operations would be performed in an area of operation limited in size suitable to the specific 

use, in advance of flight.

2. The flight would be planned in advance to minimize hazards to persons and property in the 

air and on the ground.

3. The operator would reasonably limit or control access to provide safety to those not involved 

in the operation.

4. Operation of a sUAS would provide significant safety, environmental and other 

enhancements not possible by larger sized aircraft.

5. An FAA licensed airman with a Private grade or higher pilot certificate would operate the 

sUAS or an FAA licensed airman with a Commercial grade or higher pilot certificate would 

directly supervise the operation (as per Exemption No. 11157).

6. Provide a beneficial and currently unavailable service to government organizations and the 

general public that would serve the public interest.
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 2 of 10

Approval of this exemption would thereby enhance safety and fulfil 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” Section 333(c) of the 

Reform Act.

It is possible to operate sUASs so to not create a hazard to users of the National Airspace System 

(NAS), the public or pose a threat to national security if done so safely and responsibly. The 

applicant has demonstrated their willingness to act safely and responsibly by not engaging in 

commercial sUAS operations. The applicant is currently a student private pilot with more than 

40 hours flight time and having passed the FAA written test and is a Licensed Professional 

Engineer. The Operator of the sUAS will hold a Private Pilot Certificate or higher. This

demonstrates that the applicant has a high regard to safe operations, as well as a necessary highlevel understanding of the NAS and FARs. The experience serves to add significantly to the level 

of safety in any operation performed by the applicant or the applicant’s employees.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the

characteristics of sUAS and that operate with the limitations listed herein. These limitations 

provide for at least an equivalent or higher level of safety to operations under the current 

regulatory structure as the proposed operations represent a safety enhancement to the already 

safe aerial commercial photography and survey operations conducted with conventional aircraft.

The sUASs planned to be operated are rotorcraft, each weighing 55 or fewer pounds including 

payload. They would operate, under normal conditions, at a speed of no more than 20 knots. 

Operations will be performed by a qualified sUAS PIC, as outlined below, to insure that the 

sUAS will “not create a hazard to users of the national airspace system or the public.” Given the 

small size of the UASs involved and the pre-planned environment within which they will 

operate, the applicant believes that these operations fall squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of UASs to commence immediately. Also, operation in a 

researched (to include applicable NOTAMs), pre-defined area will prevent the possibility of a 

national security issue. The operation of UASs by knowledgeable professionals with experience 

in the NAS will serve to enhance safety, add to the public benefit and reduce environmental 

impacts related to current methods of aerial photography and survey.

Listed below are the limitations and conditions to which the operator, or its employees, acting as 

sUAS PIC agrees to be bound when conducting commercial operations under an FAA

issued exemption:

1. Safety will be the first and foremost consideration in any sUAS operation.

2. The sUAS pilot will be an FAA licensed airman with at least a Private Pilot 

certificate or the sUAS pilot will be directly supervised by an FAA licensed airman 

with at least a Commercial Pilot certificate (as per Exemption No. 11157).

3. The sUAS FAA licensed airman will be considered Pilot in Command (PIC), 

whether flying or supervising, and will be responsible for safe operation of the 

flight.
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 3 of 10

4. Flights will be operated within visual line of sight (VLOS) of the PIC and visual 

observer (VO).

5. The sUAS will weigh less than 55 lbs total.

6. Flights will be operated in Class G airspace whenever possible. If operation in 

other airspace is required, the relevant controlling agency will be notified at least

24 hours prior to the operation and, if required, any necessary permission 

obtained.

7. Flights will be operated under visibility and cloud clearance requirements 

equivalent to Visual Flight Rules (VFR).

8. The sUAS will at all times give way to any aircraft carrying persons.

9. Minimum crew for each operation will consist of the sUAS PIC and visual observer

(VO). The observer and PIC will at all times be able to communicate by voice.

10. Prior to a sUAS flight, an area of operation will be established. This area of 

operation will include a defined lateral and vertical area, where the sUAS will 

operate. Safety procedures will be established for persons, property and 

applicable airspace within the area of operation.

11. Flight planning will include flight completion with at least 20% battery power 

remaining as measured by the sUAS or appropriate timing.

12. The sUAS aircraft used will utilize GPS navigation, failsafe, return-to-home (RTH)

and/or flight abort safety features.

13. A briefing will be conducted in regard to the planned sUAS operations prior to 

operation at each new location. All personnel who will be performing duties within the 

boundaries of the area of operation will be present for this briefing.

14. All required permissions and permits will be obtained from appropriate state, county 

or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

15. Written (to include electronic, and/or oral) permission from the relevant property 

owners will be obtained prior to an operation.

16. The sUAS pilot will be trained in advance for the safe operation of the sUAS to be 

operated. This training will include a minimum of 100 takeoff/landing cycles, 25 hours of 

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

similar sUAS type. Prior to operations the PIC will have accumulated and logged a 

minimum of 5 hours as sUAS pilot operating the make and model of sUAS as well as 3 

takeoffs and landings in the proceeding 90 days. Specific training will include normal and 

emergency modes of operation and will include familiarization with the operation manual 

published by the sUAS manufacturer. Training will also include types of maneuvers to be 

performed during operations including safe operation in relation to persons, property and 

applicable airspace.

17.The sUAS PIC will establish a working relationship with a representative at the local 

FSDO with which to annually review safety procedures and other operations to further 

enhance safety.

18. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for 

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

sUAS, the sUAS will not be operated until the necessary maintenance has been

performed and the sUAS is found to be in a condition for safe flight. The Ground Control
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 4 of 10

Station will be included in the preflight inspection. All maintenance and alterations will 

be properly documented in the aircraft records.

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

operation or flight characteristics, e.g. replacement of a flight critical component, will 

undergo a functional test flight. The PIC who conducts the functional test flight will 

make an entry in the aircraft records.

20. The pre-flight inspection section in the operating documents will account for all 

potential discrepancies, e.g. inoperable components, items, or equipment, not already 

covered in the relevant sections of the operating documents.

21. The operator will follow the sUAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

22. The operator will carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts will be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the sUAS to service.

23. Each sUAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

24. The authorized person will make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

It is the applicant’s belief that the size, speed, operating environment, limitations 

and level of applicant’s experience in the NAS outlined provides an “equivalent 

level of safety” or better when operating a sUAS for the public interest as outlined 

in Section 333 in the FAA Modernization and Reform Act of 2012. It is requested 

that the FAA issue an exemption to permit safe, legal, commercial sUAS

operation by the applicant as soon as possible.

Sincerely,

F.P. Villano Consulting Engineers, LLC

Frank P. Villano, P.E.

President

fvillano@basementshv.com

 mobile (201) 906-7711

116 West Meadow Wind Lane

Newburgh, NY 12550

(845) 564-0461
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 5 of 10

Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

F.P. Villano Consulting Engineers, LLC, requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of sUASs:

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the

FAA continues to work to develop airworthiness standards for sUAS, we request an 

experimental certificate be issued for the UASs operated by the applicant under either or both of 

the following provisions: 21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property and will only fly under strict operational 

requirements. Combined with the fact that any aircraft operated would be light weight and is 

constructed primarily out of plastic, we propose that a sUAS will be at least as safe, if not safer, 

than a conventionally certificated aircraft performing the same function.

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CFR Part21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be “displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew.” A sUAS is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent 

level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for 

this aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose the use of the 

sUAS’ unique manufacturers serial number, and a contact telephone number be mounted on the 

sUAS on a placard of reasonable size in relation to the sUAS. In the event that a unique

manufacturer’s serial number is not available, the previously mentioned placard will be affixed 

to the sUAS consisting of the model name and number of the sUAS, as well as a contact 

telephone number.
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 6 of 10

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display “N” and the aircraft’s registration

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

“EXPERIMENTAL” in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. A sUAS does not have an entrance in which the word “EXPERIMENTAL” can be 

placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word “EXPERIMENTAL” on the top or 

side of the aircraft, in the form of a placard. The label will be of a size that will not overwhelm 

the aircraft, but will be reasonably readable to someone near the sUAS. The placard outlined in

the previous paragraph will sufficient identify the aircraft should someone discover the aircraft on 

the ground.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. The intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to 

this requirement since the sUAS cannot carry such a manual, and if the sUAS did carry such 

manual, it would be unavailable to the crew for review. To obtain an equivalent level of safety 

and meet the intent of 91.9, we propose that a current, sUAS operation manual or equivalent be 

available the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight 

tests.

The regulation provides that “No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls.” The controls for a sUAS do 

not currently have a set of fully functioning dual controls. If a sUAS pilot is being trained, the 

pilot performing the training would be directly supervising and could take over the controls from 

the pilot in training if the need arose. This would be similar to the technique of a “throw-over 

type” control wheel in some fixed wing aircraft. We feel that this technique meets the intent of

91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer

than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of this sUAS 

would be photography or survey of persons, vessels, vehicles or structures it would be necessary 

to operate closer than 500 feet to the items listed. Operations will only be flown over property or 

persons where permission has been obtained, and careful pre-planning has been performed. 

Further, sUAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much 

space to operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and 

careful pre-planning would provide an equivalent level of safety.

14 CFR 9l.l21Altimeter settings.

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter

setting available within 100 nautical miles of the aircraft. The sUAS will always fly below 500 

feet AGL, and in line of sight of the PIC and visual observer (VO). This line of sight operation
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 7 of 10

will provide separation from other aircraft, obstructions and terrain, and would override the use 

of an altimeter for such a purpose. We feel that this will provide an equivalent level of safety.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph it to provide a reasonable 

reserve of energy to plan for a safe landing should there be a delay in landing. The close 

proximity to the ground station, the ability for both rotorcraft and small fixed wing aircraft to 

land in a very small space and the built in energy level monitoring of the sUAS we feel provide 

an equivalent level of safety if the flight is planned to be completed with 20% battery energy 

remaining. We request an exemption to the word “fuel” and ask for an equivalent interpretation 

with the word “energy”.

14 CFR Subpart E (91.401 -91.4171- Maintenance, Preventive Maintenance, and

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be “approved for return to service by a person authorized under 43.7”

after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and “be authorized to approve the aircraft for return to service.” Prior to 

every flight, the PIC will inspect the aircraft to ensure that it is in an airworthy condition. Any 

general maintenance procedures or replacement of consumable items outlined by the sUAS 

manufacturer, if applicable, will be complied with by the PIC. In no circumstance will a sUAS

be operated in a condition that is deemed, or suspected to be, unsafe. If such a determination is 

reached, and the problem cannot be remedied to the satisfaction of the PIC, the sUAS will not be 

operated until consulting with the manufacturer or one of its authorized dealers to complete 

necessary repairs. We feel that due to the size, construction, and simplicity of the aircraft, the

PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer

Medical.

This policy provides that both the PIC and observer must have a valid FAA second-class medical

certificate issued under Part 67 in order to perform as a pilot or observer. Requiring the crew to 

meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft 

is an unnecessary burden. We propose that the minimum medical requirements for the PIC be a 

valid FAA third-class medical certificate and for the visual observer (VO) be vision corrected to

20/20 and a valid, state-issued driver’s license. The risk of both the PIC and observer becoming 

incapacitated at the same time and suddenly is very low. Further, since the sUAS is operating 

close to the ground, it could be brought in for landing in a very short time if incapacitation was 

suspected. Finally, the UASs used will be equipped with an automatic return to home feature 

which would provide a final level of safety. We feel this would provide an equivalent level of 

safety.
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 8 of 10

FLIGHT RESTRICTIONS

(a) No flight will be made with a sUAS Gross weight exceeding 55 pounds;

(b) Most operations will occur in FAA Class G airspace at no more than 200’ AGL, at an airspeed of

no more than 20 knots and within visual line of sight (VLOS) of the PIC;

(c) All operations will utilize a visual observer (VO). The VO and PIC will be able to communicate 

verbally at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of the property 

owner;

(e) The PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a

minimum of 100 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at least ten 

hours logged as a sUAS pilot with a similar sUAS type; 5 hours as sUAS pilot operating the make 

and model of sUAS as well as 3 takeoffs and landings in the proceeding 90 days.

(f) All required permits will be obtained from state and local government prior to operation; 

(g) The sUAS System will not be operated over densely populated areas;

(h) The sUAS System will not be operated at air shows;

(i) The sUAS System will not be operated over any open-air assembly of people; 

(j) The sUAS System will not be operated over heavily trafficked roads;

(k) The sUAS System will not be operated within 5 NM of an airport or heliport unless the operator

has a CoA with the airport operator and within 48 hours, but not more than 72 hours issues an 

appropriate NOTAM;

(l) Operations will be restricted to day only and weather conditions equivalent to VFR;

(m) The PIC will brief the VO and property owner about the operation and risk before the first flight 

at each new location;

(n) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

operation to ascertain that the sUAS is in a condition safe for flight.

PRE-FLIGHT CHECKLIST

(1) Determine that sUAS battery is fully charged in order to prevent unexpected premature descent;

(2) Check all wiring connections are tight;

(3) Check all propellers are undamaged and no cracks exist in any structural members of the sUAS; 

(5) Turn on radio controller, check for adequate voltage, set it to connect to the sUAS, move all

control switches the appropriate preflight position;

(6) Connect the sUAS main battery, check for radio contact with sUAS’s radio receiver;

(7) At a location different from previous flight, re-set GPS and compass to current location; 

(8) Turn on transmitter, gimbal and camera.

OPERATING DOCUMENTS

Petitioner submits its Operations Manual and Training Syllabus as Confidential documents under

14 C.F.R. § l l .35(b) as they contain proprietary information that Petitioner has not and will not 

share with others. The documents contain operating conditions and procedures that are not 

available to the public and are protected from release under the Freedom of Information Act, 5

U.S.C. § 552.
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 9 of 10

The petition and the following supporting documentation are referred to as the operating 

documents:

1) Training Syllabus including:

Cautions, Warnings, Basic Flight Maneuvers, Advanced Flight Maneuvers as per 

the DJI Pilot Training Guide and Mission Specific Flight Maneuvers

2) Operations Manual including:

Phantom 3 Professional User Manual: 

3) Forms including:

FPVCE Flight Authorization form 

FPVCE Job Safety Assessment form 

FPVCE Preflight Briefing Sheet

FPVCE Aircraft Flight Log And Maintenance Record

FPVCE UAS Defect Sheet

Materials to be readily available to the PIC:

Operations Manual including:

· Phantom 3 Professional User Manual:
F.P. VILLANO CONSULTING ENGINEER, LLC

June 15, 2015 Page 10 of 10

· Sectional and TAC Aeronautical charts

· sUAS logbook and Defect Sheet(s)

· Personal pilot logbook

Petitioner submits its Operations Manual and Training Syllabus as 

Confidential documents under 14 C.F.R. § l l .35(b) as they contain 

proprietary information that Petitioner has not and will not share with 

others. The documents contain operating conditions and procedures that are 

not available to the public and are protected from release under the Freedom 

of Information Act, 5 U.S.C. § 552.

CONCLUSION

Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight,

and national security, provide more than adequate justification for the grant of the requested

exemption allowing operation of Petitioner's sUAS for aerial photography and survey for real estate 

and real estate and various industries pursuant to the Operations Manual.

Respectfully,

Frank P. Villano, P.E.

Frank P. Villano, P.E.

President

fvillano@basementshv.com

 mobile (201) 906-7711

116 West Meadow Wind Lane

Newburgh, NY 12550

(845) 564-0461

Attachments:
TIMES:

LAUNCH 1:

RECOVERY 1:

LAUNCH 2:

RECOVERY 2:

LAUNCH 3:

RECOVERY 3:

JOB ASSESSMENT:

ESTIMATED TOTAL HOURS:

ACTUAL TOTAL HOURS:

SPECIAL INSTRUCTIONS:

PROPERY OWNER INFORMATION:

NAME:

OWNER ADDRESS:

OWNER PHONE:

OWNER SIGNATURE: DATE:

AIRCRAFT TYPE/MODEL:

VISUAL OBSERVER (VO)

PILOT IN COMMAND (PIC) FLIGHT NOTES:

DATE:

LOCATION

TASK DESCRIPTION:

* FORENSIC ENGINEERING

* LITIGATION SUPPORT

* STRUCTURAL CONDITION ASSESSMENT

* MARINE & COASTAL EVALUATIONS

F.P. Villano, Consulting Engineer, LLC

116 West Meadow Wind Lane

FLIGHT AUTHORIZATION FORM

Newburgh, NY 12550

Tel: (845) 564-0461 Fax: (845) 913-9010
SERIAL No TYPE

COMMENTS:

PILOT IN COMMAND SIGNATURE: DATE:

NEAREST FLIGHT CONTROL CENTER

PILOT IN COMMAND

VISUAL OBSERVER

PROPERTY OWNER

EMERGENCY CONTACT NUMBERS:

IDENTIFICATION OF ALTERNATE LANDING AREA

IDENTIFICATION OF SAFE ZONE

ACTION FOLLOWING AN INCIDENT/NOTIFICATION OF AUTHORITIES

ACTION PERFORMED

OVERVIEW OF THE MISSION PLANNED

SPECIFIC TASKS FOR CREW MEMBERS/PIC/VO. PERSON TASKED WITH OBSERVING FOR PEOPLE ENTERING WORK AREA

POSSIBLE ISSUES AND IDENTIFICATION OF HAZARDS ASSOCIATED WITH THE MISSION INCLUDING PLANNED ACTION

HOW THE CONTROLLER WILL COMMUNICATE ANY PROBLEMS AND/OR SUBSEQUENT ACTIONS

Tel: (845) 564-0461 Fax: (845) 913-9010 * MARINE & COASTAL EVALUATIONS

UNMANNED AIRCRAFT (sUAS) BRIEFING FORM

DATE: MODEL

F.P. Villano, Consulting Engineer, LLC * FORENSIC ENGINEERING

116 West Meadow Wind Lane * LITIGATION SUPPORT

Newburgh, NY 12550 * STRUCTURAL CONDITION ASSESSMENT
SERIAL No TYPE

PILOT IN COMMAND SIGNATURE: DATE:

DEFECT No. DESCRIPTION OF DEFECT OR MAINTENANCE REQUIRED NAME REPAIRS MADE SIGNATURE

Tel: (845) 564-0461 Fax: (845) 913-9010 * MARINE & COASTAL EVALUATIONS

UNMANNED AIRCRAFT (sUAS) DEFECT FORM

DATE: MODEL

F.P. Villano, Consulting Engineer, LLC * FORENSIC ENGINEERING

116 West Meadow Wind Lane * LITIGATION SUPPORT

Newburgh, NY 12550 * STRUCTURAL CONDITION ASSESSMENT
TASK:

SKETCH OF AREA: CHECK THE FOLLOWING AND ADDRESS AS NEEDED:

MAPS AND CHARTS AVAILABLE AND VERIFIED

WEATHER (VFR MIN. AS REQUIRED)

NOTAMS

POSSIBILITY OF PUBLIC MOVING INTO WORK AREA

FOOTPATHS/RIGHTS OF WAY

LANDING AREA (PRIMARY)

LANDING AREA (ALTERNATE)

ABILITY TO MAINTAIN 100 FEET FROM PUBLIC

OBSTRUCTIONS (TREES, LAMP POSTS, TOWERS, ETC)

POWER LINES/ANTENNAS

ABILITY TO MAINTAIN VISUAL LINE OF SIGHT 

CONTROLLERS ABILITIES 

PERMISSION OF PROPERTY OWNER

PRIVACY

LOCAL PERMITS/RESTRICTIONS

BEYOND AIRPORT LIMITS

OTHER

COMMENTS:

PILOT IN COMMAND SIGNATURE: DATE:

Tel: (845) 564-0461 Fax: (845) 913-9010 * MARINE & COASTAL EVALUATIONS

JOB SAFETY ASSESSMENT FORM

DATE: LOCATION:

F.P. Villano, Consulting Engineer, LLC * FORENSIC ENGINEERING

116 West Meadow Wind Lane * LITIGATION SUPPORT

Newburgh, NY 12550 * STRUCTURAL CONDITION ASSESSMENT
PILOT IN COMMAND SIGNATURE: DATE:

POST-FLIGHT 

INSPECTION

FLIGHT TOTAL 

(HOURS)

DAILY TOTAL 

(HOURS)

SERVICE 

REQUIRED (Y/N)

DEFECT 

NUMBER COMMENT

DATE OF MANUFACTURE:

DATE PILOT DAILY 

INSPECTION

SERIAL No. AIRCRAFT MODEL:

Tel: (845) 564-0461 Fax: (845) 913-9010 * MARINE & COASTAL EVALUATIONS

AIRCRAFT FLIGHT LOG & MAINTENANCE RECORD

DATE: AIRCRAFT TYPE:

F.P. Villano, Consulting Engineer, LLC * FORENSIC ENGINEERING

116 West Meadow Wind Lane * LITIGATION SUPPORT

Newburgh, NY 12550 * STRUCTURAL CONDITION ASSESSMENT
RISK CALCULATION SHEET

UNDESIRED OUTCOME SEVERITY LIKELIHOOD RISK FACTOR

1 MEMBERS OF THE PUBLIC ENCROACHING AREA OF OPERATION 2 4 4

2

3

4

5

6

7

8

9

Tel: (845) 564-0461 Fax: (845) 913-9010 * MARINE & COASTAL EVALUATIONS

UNMANNED AIRCRAFT (sUAS) RISK ASSESSMENT

F.P. Villano, Consulting Engineer, LLC * FORENSIC ENGINEERING

116 West Meadow Wind Lane * LITIGATION SUPPORT

Newburgh, NY 12550 * STRUCTURAL CONDITION ASSESSMENT
RISK ASSESSMENT MATRIX - LEVEL OF RISK

Consequence

People

Injuries or ailments 

not requiring 

medical treatment.

Minor injury or First 

Aid Treatment Case.

Serious injury causing 

hospitalisation or 

multiple medical 

treatment cases.

Life threatening injury or 

multiple serious injuries 

causing hospitalisation.

Multiple life threatening 

injuries. Less than 10 

fatalities.

Multiple fatalities, 10 

or more

Reputation

Internal Review Scrutiny required by 

internal committees 

or internal audit to 

prevent escalation.

Scrutiny required by 

external committees or 

Auditor General’s 

Office, etc.

Intense public, political 

and media scrutiny. Eg: 

inquest, front page 

headlines, TV, etc.

Government inquiry or 

Commission of inquiry or 

adverse national media in 

excess of 1 week.

Government inquiry 

and ongoing adverse 

international exposure

Organisational / 

Client impact

Small delay, internal 

inconvenience only.

May threaten an 

element of the service 

delivery function. 

Business objective 

delayed. Easily 

remedied, some impact 

on external 

stakeholders.

Considerable remedial 

action required with 

disruption to a Group 

for period up to 1 

month. Some business 

objectives not 

achieved.

Significant loss of 

critical information. 

Disruption to one or 

more Groups for up to 3 

months. Some major 

objectives not achieved. 

Permanent loss of critical 

information, substantial 

disruption to CASA or 

external intervention for 

over 3 months. Threatens 

existence of a Group 

within CASA. Major 

objectives not achieved

Threatens ongoing 

existence of CASA.

Insignificant Minor Moderate Major Severe Catastrophic

Numerical Historical 0 1 2 3 4 5 

Probability

>1 in 10

Is expected to occur in most 

circumstances Almost Certain (5) 5 6 7 8 9 10

1 in 10 – 100 

Will probably occur

Likely (4) 4 5 6 7 8 9 

1 in 100 – 

1000

Might occur at some time in 

the future Possible (3) 3 4 5 6 7 8 

1 in 1000 – 

10000 

Could occur but considered 

unlikely or doubtful Unlikely (2) 2 3 4 5 6 7 

1 in 10000 - 

100000 

May occur in exceptional 

circumstances Rare (1) 1 2 3 4 5 6 

< 1 in 

100000 

Could only occur under 

specific conditions and 

extraordinary circumstances

Extremely 

Rare (0) 0 1 2 3 4 5 

>7: Extreme risk 

– detailed treatment plan required

6,7: High risk 

– needs senior management attention 

and treatment plan as appropriate

4,5: Medium risk 

– manager level attention and 

monitoring as appropriate 

<4: Low risk

 

 

 

 

 
RISK ASSESSMENT

Overview

The evaluation of risk is the process known as “Risk Assessment”. 

The UAS Controller should perform this assessment.

The Risk Assessment should be performed during the feasibility planning phase to 

determine if the flight is viable. It should then be validated on the day prior to the flight. Any

assumptions made during the initial Risk Assessment (such as forecast weather/wind,

location of persons etc.) should be confirmed.

The Risk Assessment involves calculating a risk factor based on both the severity of any 

undesired outcome and the likelihood of that outcome. Where the risk factor is unacceptably 

high a mitigating factor or control measure is needed to reduce the likelihood or 

consequence to manage the risk back to an acceptable level/factor. Even if the risk is 

acceptable you should consider any factor that could be applied to reduce the risk further.

Determining the Risk

A detailed diagram of the site (Google maps may also be used) and the Risk Assessment 

Tool Prompt Sheet are used to identify possible risks. These risks are recorded on the Risk 

Calculation Sheet.

Next the score for both the likelihood and consequence is determined using the Risk Score 

Table below and the scores are entered on the Risk Calculation Sheet. The Risk factor is 

then calculated by multiplying these two scores.

Note - other elements such as local by Laws etc. which may prevent the flight should also be 

considered.

Risk Management

The calculated Risk Factor for each identified risk is then reviewed

Where the risk factor is unacceptably high a mitigating factor or control measure is needed 

to reduce the likelihood or consequence to manage the risk to an acceptable level/factor. 

Multiple control measures may be needed to reduce the risk to an acceptable level. Even if 

the risk is acceptable you should consider any factor that could be applied to reduce the risk 

further.

The control measure is recorded on the Risk Calculation Sheet and a new Risk Factor 

calculated.

Note – The risk assessment should also include any risk to the Controller, Observer and 

anyone else involved in the operation of the UAS.

Where the residual risk is unacceptable the flight should not proceed.
Validation of Risk Assessment

Once “on site” the Risk Assessment must be validated prior to the flight proceeding. Any 

assumptions made during the initial Risk Assessment (such as forecast weather/wind, 

location of persons etc.) should be confirmed. Where there are differences a new Risk factor 

must be calculated and control measures adjusted to manage the risk to an acceptable level 

prior to the flight.

Other Factors

As this is a generic Risk Assessment process it cannot consider all possible areas of risk for 

every situation. There may be other areas that need consideration in addition to the Risk 

Assessment Sheet prompts. Therefore this risk assessment process should be considered a 

guide as to the minimum areas for inclusion in your Risk Assessment.
likelihood of other aircraft in area

likely failure modes, alternate 

landing site, emergency procedures, 

battery fire following crash (dry 

grass)

noise, ability to communicate with 

participants, distrations, possiuble 

distraction to the public (drivers)

9

POSSIBLE IMPACT

Possible low sun, fading light, 

orientation, ability to maintain 

visual line of sight

check forecast, temperatures, wind 

directin, wind strength, impact on 

battery lift (cold battery, flying into 

wind) aircraft wind limit, fire

person moving into landing area 

during flight, footpath, right of way, 

suitable take-off and landing areas, 

ability to maintain separation with 

people/property

permission from land owner, 

privacy, buildings, antennas, trees, 

obstructions, ability to maintain 

visual line of sight, controllers 

ability matches location, local 

restrictions and laws

7 ENVIRONMENT

8

5 OTHER AIRCRAFT

6 EQUIPMENT FAILURE

3 PUBLIC

4 PROPERTY

1 TIME OF DAY

2 WEATHER

Tel: (845) 564-0461 Fax: (845) 913-9010 * MARINE & COASTAL EVALUATIONS

UNMANNED AIRCRAFT (sUAS) RISK ASSESSMENT

RISK CALCULATION SHEET

CONSIDERATION RISK

F.P. Villano, Consulting Engineer, LLC * FORENSIC ENGINEERING

116 West Meadow Wind Lane * LITIGATION SUPPORT

Newburgh, NY 12550 * STRUCTURAL CONDITION ASSESSMENT
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Aircraft Weight (Including Battery And Propellers) 1280 g

Diagonal Size (Including Propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy • Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

• Horizontal: +/- 1.5 m

Max Speed 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level 6000 m

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

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Camera

Gimbal

Vision Positioning

Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range 100-3200 (video) 100-1600 (photo) 

Shutter Speed 8s -1/8000s

Image Max Size 4000 x 3000

Still Photography Modes • Single Shot

• Burst Shooting: 3/5/7 shots

• Auto Exposure Bracketing (AEB): 3/5

• Bracketed Frames at 0.7EV Bias

• Time-lapse

Video Recording Modes Phantom 3 Professional

• UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

• FHD: 1920x1080p 24/25/30/48/50/60

• HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

• FHD: 1920x1080p 24/25/30/48/50/60

• HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate Of Video Storage Phantom 3 Professional

60 Mbps

Phantom 3 Advanced

40 Mbps

Supported File Formats • FAT32/exFAT

• Photo: JPEG, DNG

• Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature 0°C to 40°C

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

Max Velocity Less than 8 m/s (when 2 m above ground)

Altitude Range 30 cm-300 cm

Operating Range 30 cm-300 cm

Operating Environment Surface with clear pattern and adequate lighting (Lux > 15)

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Remote Controller

Battery Charger

Intelligent Flight Battery

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance 2000m (outdoors and unobstructed)

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Transmitter Power (EIRP) • FCC: 20 dBm

• CE: 16 dBm

Working Voltage 1.2 A @7.4 V

Voltage 17.4 V

Rated Power Phantom 3 Professional

• 100 W

Phantom 3 Advanced

• 57 W

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes 

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

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App / Live View Mobile App DJI Pilot

EIRP 100mW

Live View Working Frequency 2.4GHz ISM

Live View Quality 720P @ 30fps (depending on conditions and mobile device)

Latency 220ms (depending on conditions and mobile device)

Required Operating Systems • iOS 8.0 or later

• Android 4.1.2 or later

Recommended Devices • iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 

2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and 

iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and 

iPhone 6 Plus

• Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, 

Mi 3, Nubia Z7 mini

• *Support for additional Android devices available as testing and development 

continues

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