Steve Rhode

8301 Wycombe Ridge Way

Wake Forest, NC 27587

steve@psflight.org

RE: Docket No. FAA-2014-0799

Please accept the submission of the following clarifications and information to accompany my 

previously submitted Section 333 exemption request.

Supplemental Information

Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided.

No intentional operational will be conducted within 5 nautical miles of the geographic center of a 

non-towered airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained. The letter of agreement with the airport 

management will be made available to the Administrator upon request. The only exception to 

this would be if operations outside a 5 nautical mile radius resulted in a lost link situation which 

caused the UAS to pass under an edge of that 5 nautical mile radius in it’s direct route back to 

the takeoff point. If so, the PIC will announce the event on the non-towered airport CTAF/

Unicom and give the altitude, direction of travel, and position.

The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from 

a cloud or when visibility is less than 3 statute miles from the pilot in command (PIC).

The UAS will not be operated by the PIC from any moving device or vehicle.

There are no known agricultural flight activities or other low-level commercial flight activities 

within the area of operation.

The UAS will remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, hot air balloons, etc.).

The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents will be 

made available to the Administrator or any law enforcement official upon request.

Before conducting operations, the radio frequency spectrum used for operation and control of 

the UAS will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.
The UAS will be in compliance with all manufacturer Safety Bulletins.

Documentation and maintenance records of the UAS maintenance, preventative maintenance, 

alterations, status of replacement/overhaul component parts, and the total time in service of the 

UAS, will be kept.

AN assigned N-Number will be affixed to the UAS in a size that is as large as practical. The 

UAS will have an assigned serial number.

Operational awareness and training of UAS flight operations by PIC will be conducted with 

search and rescue, fire department, and EMS departments. The goal of this training is to 

familiarize these services with the presence, role, and safe operation of the UAS. At least one 

department at each scene will have completed this training. The departments that complete the 

training will issue the PIC a letter of agreement confirming permission to operate with or near 

them. This document will be kept on file for inspection. Considering the fact there may be distant 

or remote departments called in during large emergency incidents it is impractical to conduct 

such training with those unknown departments. Training will have at least been conducted with 

the department in charge of the scene.

Considering that the operation of the UAS will be for emergency situations it is impractical to file 

a NOTAM for operations below 400 feet for a real time critical event. Flight events typically are 

apparent in the area due to the number of emergency vehicles with multiple flashing lights which 

would be very apparent to any airman. If a training or other such planned exercise is scheduled 

in advance a NOTAM may be filed 24 hours before such an event. All training events will be 

conducted below 400 feet AGL.

The specific UAS craft will comply with the exemption requested and will have a corresponding 

manufacturer Pilot Operating Manual (POM) and/or Pilot Operating Handbook (POH) but at this 

time, with the uncertainty of the amount of time to process this exemption request, and the 

advancement in technology, it is impossible to know if a newer craft may be obtained prior to 

final processing. Any newer UAS obtained will meet or exceed the standards listed in this 

exemption request and will have a corresponding POM/POH.

If the UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, it will undergo a functional test 

flight. The PIC will make an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and aircraft record entry will be added to the operator’s 

manual.

UAS will have visible lighting which will include at least one bright white strobe light and green 

and red navigation lights. These lights will be visible from above or below the craft.

If search and rescue or emergency operations exceed 30 minutes of flight, in no way will flight 

continue past 25 percent of remaining battery life, which is constantly monitored by the PIC. The 

requirement for longer flights is requested so that the UAS does not need to unnecessarily land 

during a life saving or mission critical event if battery life is sufficient. 

Because of the life saving and urgent nature of incidents, flight operations at night in VFR 

conditions with enhanced UAS lighting as stated above, is requested. These operations will not 
be conducted over people, except emergency personnel at a safe distance, and would most 

likely be in a hover above structural fires or assisting in the search for missing children and/or 

dementia patients, typically in wooded areas or fields, using thermal imaging cameras onboard.

UAS Pilot in Command will hold a current FAA pilot license of at least a private pilot or above. 

While I understand some groups or associations would like to see the PIC hold a commercial 

license, the FAA has already determined, in previous exemptions granted, a private pilot license 

is sufficient for UAS operations as described. The minimum Medical Certificate will be 3rd 

Class.

The specific UAS craft will comply with the exemption requested and will have a corresponding 

manufacturer Pilot Operating Manual (POM) or Pilot Operating Handbook (POH) but at this 

time, with the uncertainty of the amount of time to process this exemption request, and the 

advancement in technology, it is impossible to know if a newer craft may be obtained prior to 

final processing. Any newer UAS obtained will meet or exceed the standards listed in this 

exemption request.

The UAS will NOT be used for any law enforcement surveillance activities.

Flight Checklists

Pre-Arrival Checklist

1. Verify location of incident using sectional and electronic aviation applications to confirm the 

flight operations will not be closer than 5 nm from any airport center.

2. Using electronic pilot applications, verify weather conditions are VFR and safe to fly.

Arrival Checklist

1. If day and operating out of back of vehicle, point vehicle into sun.

2. Remove case and place on level surface.

3. Verify distance to nearest airport and/or controlled airspace using smartphone or tablet app.

4. If required, use VHF aviation transceiver, to contact tower of field if required to inform tower / 

CTAF of UAS ops, location, and max height of flight.

Preflight Checklist

1. Remove transmitter.

2. Router - On

3. Transmitter - On

4. Toggle Switches - Up

5. Video Monitor - On

6. Case - Remove UAS

7. Inspect UAS for Inops - Check

8. Gimbal Lock & Lens Cap - Removed

9. Recording Device - Inserted or On

10. UAS Battery - Inserted

11. Launch and Recovery Location - Clear and Safe

12. UAS Battery - On

13. Wifi Connection to Monitor - Verified

14. Flight Application - Loaded and Checked

15. Flight Application - Connect to Camera
16. Recording Medium - Format

17. Camera - Full Up

18. Satellite Connections - Verified

19. UAS Battery Charge Levels - Safe for Flight

20. Video Recording - Start

21. Takeoff

After Takeoff Checklist

1. Hover approximately ten feet above the ground to confirm UAS is under control.

2. All sticks operate correctly while in hover - Verified

Pre-Landing Checklist

1. Camera - Full Up

2. Video Recorder - Stop

3. Landing Zone - Clear / Safe

Post-Landing Checklist - Returning to Flight Immediately

1. Battery - Remove & Replace

2. Wifi Connection to Monitor - Verified

3. Flight Application - Connect to Camera

4. Takeoff

End of Ops Checklist

1. Battery - Off

2. Transmitter - Off

3. Router - Off

4. Notify Tower/CTAF - If Required, End of Ops

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