**Crossfield	L.L.C.** Page 1 Daniel Kruetzfeldt Crossfield LLC 18475 Lambert Lake Rd. Sonora, Ca 95370 209 985 0003 Dank@crossfield.corp

May 20, 2015 U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590
Dear Sir or Madam: Crossfield is proposing to conduct S.U.A.S . ( Small Unmanned Aerial System) imaging operations for construction, mining, agriculture, and other co mmercial operations. P ursuant to section 333 the FAA Modernization and Reform Act of 2012, we request exemption from several provisions of the Fede ral Aviation Regulations , specifically portions of 14 C.F.R

. Parts 61 and 91 to allow commercial operations of our unmanned aerial vehicle

. Crossfield’s purpose of safely conducting UAV (Unmanned Aerial Vehicle) operations within the N.A.S. aligns itself with the intent of Congress, until final regulation governing their use is implemented. Also, as every exemption Crossfield is applying has been previously approved in similar operations, we respectfully request the “summary grant” process is utilized. Safety is absolutely at the forefront of all operations at Crossfield, and all of our operations are designed to protect people and property in the area of operation. Please read the following for a description of our operation and the explanation of the exemptions requested. Attached is the Crossfield F.O.M. (not for public view) and the user manuals for our proposed sUAS’s. **The Operation ; Public Benefit**  Precision imaging though the use of a small, unmanned aerial vehicle to benefit several industries including mining, agriculture, and construction. Our expertise in the us e of photogrammetry, LIDAR, infrared, and other imaging tools and combining those tools with powerful software will greatly benefit the public. This service will allow managers across the industry to make better informed decisions. Complex measuring, analy zing, and data collecting will greatly reduce the waste of resources. Adjusting watering rates, seeding rates, and chemical usage will assist farmers. Measuring mining and construction operations can benefit safety and efficiency

. Crossfield will utilize a F.O.M. ( Flight Operation Manual ) to guide all of its operations. The F.O.M. is attached , and it details the specific operational safety protocols we will use. The F.O.M. will be updated regularly as better processes are learned and new regulation is passed.**Crossfield	L.L.C.** Page 2

Crossfield’s flight operations will be managed by a highly experienced and rated Airline Transport Pilot (A.T.P.) , and the navigation and imaging system s will be managed by one of the nation’s premier experts. Both have decades of experience in their relative fields, and will bring a lot of expertise and an enhan ced safety culture to the operation. The professional use of UAS ’s will certainly benef it the public, as it will mean fewer larger, fuel carrying, higher noise footprint aircraft in the N.A.S. **The System** Crossfield is currently using, experienced with, and proposing to use the following tw o sUA S in a commercial capacity. Please refer to the user manuals and the F.O.M. for more detailed sUA S technical and operational information. The following links will access the user manuals for the sUAS’s:

f550_user_manual_v1.3_en.pdf S1000_Plus_User_Manual_v1.2_en.pdf

**DJI Flame Wheel**  **550** Wookong flight controller with GPS and attitude control DJI Ground Station waypoint software with 2.4 GHz Ground station transmitter and 2.4 GHz dat a receiver Frame Weight : 478g Diagonal Wheelbase : 550mm Takeoff Weight : 1200g ~ 2400g Propeller : 8 inch and 10 inch
Battery : 3S~4S LiPo

Motor : 22 × 12mm (Stator size)**Crossfield	L.L.C.** Page 3 **DJI Spreading Wings S100+** Diagonal Wheelbase: 1045mm Frame Arm Length: 386mm Frame Arm Weight (In cluding Motor, ESC, Propeller): 325g

Center Frame Diameter: 337.5mm Center Frame Weight (with Land ing Gear Mounting Base, Servos): 1330g Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm)

F oldable Propeller: High strength performance engineered plastics, Size 15×5.2inch Flight Parameters: Takeoff Weight6.0Kg ~ 11.0Kg , Total Weight 4.2Kg
Power Battery : LiPo (6S 、 10000mAh~20000mAh 、 15C ( Min), Max Power Consumption4000W Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight)

Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight) Working Environment Temperature

- 10 °C ~ +40 °C Both Models feature autonomous control and manual control abilities. Both can be programmed to lim it their altitudes, and to avoid airspace with lateral limitations They also feature the ability to automatically compensate for motor failures, and will automatically return to base for low battery situations and signal disruptions.

Both of these models have operational speeds and weights that are well in line with the FAA limitations (less than 25 pounds max with payload , around 40 knots max speed) and they have been previously approved on multiple occasions. Crossfield chose DGI as a manufacturer due to their industry leading expertise and experience. These models have thousands of hours of operational history behind them, and are inherently safer due to their having 6

- 8 rotors for redundancy, rigid construction, and light weight.**Crossfield	L.L.C.** Page 4 **The Flight Man**  **agement**

Crossfield’s flight operation will be managed by an experienced Airline Transport Pilot and certified Flight Instructor (M.E.I.I.) His qualifications include over 10,000 hours of mostly commercial aircraft operations and he is currently a Captain at an airline that is renowned for its safety culture. He holds a Flight Instructor certificate with instrument and multiengine ratings, and has been an I.O.E

. pilot for FAA part 135 operations. His extensive experience started with a B.S. degree in Aviation Operations, the operating of a flight school, and an accumulation of ratings and type ratings in several aircraft through careers in everything from freight to corporate aviation. The in tent of Crossfield is to use our unique aviation qualifica tions to enhance the safety culture of flying UAV’s in the N.A.S., by bridging the gap between drone operators on the ground, and manned aircraft above. We believe that years of operating aircraft backed by all of the scientific research that create safety pro tocols, and having a thorough understanding of the complexities of the airspace system will benefit our operation. Our pilots will be highly trained, will practice emergency procedures regularly, and will always have the safety of the public as the prim ary concern. **Exemptions requested**

**14CFR 61.**  **23(a) 14CFR 61.101(e)(4)&**  **(5) 14CFR 61.113**  **(a) 14CFR 61.315(a**  **) 14CFR 91.7(a)**  **14CFR 91.119**  **(c) 14CFR**  **91.121 14CFR**  **91.151 (b**  **) 14CFR**  **91.203(a)&(b) 14CFR**  **91.401**

**- 417** 

**Reasons for requesting the above exemptions**  **61.23(a)** The P.I.C. may have a valid U.S. driver’s license in lieu of a medical certificate. This is per FAA guidance. As the sUAS can land itself the physical integrity of the PIC is not as important as that of a manned aircraft. Also, redundancy in the f orm of a visual observer will certainly add to safety. See previous Exemption No. 11343. **61.101(e) (4)&(5) Crossfield	L.L.C.**  Page 5

Recreational pilot limitations are not being applied to the use of sUA S. Though Crossfield’s flight operations are managed by an A.T.P., we also request the ability to utilize recreational pilots. They will be held to the same training standards, as dictated by the F.O.M.See previous Exemption No 11343.

**61 .113(a)**  The petiti oner requests relief in order to facilitate the utilization of pilots who h old a private pilot certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to th e previously gr anted exemptions; it must also be noted that the aircraft carries no people, is flown over a controlled environment , and that a training program exists along with operational guidelines. See Exemption No. 11213 **61.315(a )**  Sport pilot limitations on commercial activity are not being applied to sUAS. . Though Crossfield’s flight operations are managed by an A.T.P., we also request the ability to utilize sport pilots. They will be held to the same training standards, as dictated by the F.O.M. See previ ous Exemption No 11407 **91.7(a)** The sUAS will be operated only when it has been deemed airworthy in accordance with the F.O.M. and manufacturer’s manuals; however it will not be assigned an airworthiness certificate. Therefore, relief is needed. See Exemption Nos. 11062, 11063, 11064, 11065 etc. **91.119(c)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU) , o perations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects tha t would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. The Petitioner requests waiver for this condition to allow reason able and responsible operations near persons or property as needed. It should be noted that due to the small weight, controlled area of operation, lower speeds, computer backup, and lack of flammable fluids the sUAS is inherently safer than equivalent

mann ed aircraft.

**91.121** As discussed in Exemption 11138 (DOUGLAS TRUDEAU ) It is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. The altitude has been proven accurate, and limits will be programmed (fencing) into the controller.

**91.151(b )**  Due to the small size and the confined areas the sUAS will be operated, the risks associated with them are far less than manned aircraft. The shorter duration of flight of sUAS also makes adherence to 91.151(b ) impossible. As per our F.O.M., however, a strict adherence to a 5 minute reserve wi ll be followed, or longer if required by the manufacturer. Safety is enhanced too, with auto returning software**Crossfield	L.L.C.** Page 6 programme d into the controller when battery conditions warrant. See exemptions Nos. 8811, 10808, 10673, etc. **91.203 (a) & (b)** The sUAS fully loaded weigh less than 55 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on board the aircraft. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS wil l have immediate access to them, as detailed in the F.O.M. The FAA has issued numerous exemptions to this regulation. A representative sample of other

exc eptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **91.405(a) ;**  **91.407(a)(1) ;**  **91.409 (a)(1) & (2) ;**  **91.417(a) & (b)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), the operator will perform all maintenance as specified in the F.O.M. , or it will be carried out by the manufacturer. This will be done in accordance with the manufacturer’s recommendations, and records will be maintained of all maintenance performed. Crossfie ld will actively engage in risk mitigation, and believes our own protocols when coupled with the manufacturers will equate to a level of safety required in CFR 91. This, along with the nature of the flight over controlled areas, with a small vehicle, and the ability to land quickly when a malfunction occurs should benefit safety as a whole.

**Attention:** *****We are not seeking a waiver on FAR45.23 as it is understood from previously approved exemptions that the registration numbers will be as large as**  **practicable.** *****We are not seeking a waiver on FAR 91.9(b)(2) as it**  **is understood from previously approved exemptions that the required manuals may be located in the vicinity of the PIC,**  **not onboard the aircraft**

**.**
**Federal registry summary**

Mr. Daniel Kruet zfeldt , Airline Transport Pilot , Crossfield LLC , 18475 Lambert Lake Rd., Sonora, Ca , petitioned the FAA on behalf of Crossfield LLC for an exemption from part 61.23(a), 61.101(e)(4)&(5), 61.113(a) , 61.315(a) 91.7(a), 91.119 (c), 91.121, 91.151(b ), 91.203(a ) and (b), 91.405(a), 91. 407(a)(1), 91. 409(a) (1)& (2), 91. 417(a) and (b) of Title 14, Code of the Federal Regulations (14 CFR). The exemption would allow comm ercial operation of the DJI 550 and DJI S1000+ small Unmanned Aircraft Systems (sUAS ) for precision aerial surveys.**Crossfield	L.L.C.** Page 7 **International Authorization** Crossfield wishes to extend the exemption privileges to include international operations. Specifically, we wish to include the ability to operate within the countries of Canada and Mexico. These requested ar eas will enable Crossfield to operate into known, identified markets that will equally benefit from our operation. Our intended type of operation in the agricultural, commercial, and mining operations is not confined to country borders. Several companies we intend to work with have multiple locations throughout North America. Crossfield will, of course, work with the controlling agencies to ensure compliance with local regulation. Securing the necessary requirements initially will allow unencumbered operations for Crossfield. Should approval for international operations slow or otherwise encumber the approval of our 333, we respectfully request that domestic approval takes precedence and that the international requirements are dealt with at a later date.

**Summary** The inclusion of sUAS into the N.A.S. should be done in a methodical, professional manner to protect persons on the ground and in the air. This can only be accomplished when the operators are intimately familiar with the complexities and hazards presented when operating an aircraft. Crossfield not only promises to safeguard the public during this critical implementation of sUAS into the FAA system, but we intend to enhance the level of training and knowledge that currently exists in the field. Our Unique c ombination of aviation and technical system expertise will benefit the public with a safe, useful product. The reduction of necessary manned aircraft flights to collect imagery from above will provide a cost benefit, safety benefit, and noise impact reduction benefit.**Crossfield	L.L.C.** Page 8 

## Appendix A *******
*****Please do not publish in the public forum. The following is proprietary information.**  **Please protect from release under the Freedom of Information act 5 U.S.C. 552 et.seq. Thank you.** **Crossfield	L.L.C.** Page 9 

## Crossfield, L.L.C. Small Unmanned Aerial System **Flight Operations Manual**
**Section 1) General Section2) Flight Crew Maintenance and Qualifications**  **Section 3) Preflight Section 4) Normal Operations/Operating limitations**  **Section 5) Abnormal/Emergency Procedures**  **Section 6) Maintenance Crossfield	L.L.C.**  Page 10

**Section 1) General The following F.O.M. specifies the operating policies, procedures, and practices to**  **be used by Crossfield, LLC during all S.U.A.V. commercial operations and training flights.**  **The Crossfield F.O.M. will comply with the following guidelines: 1)**  **The following rules are in addition to all applicable F.A.R.’s, and local and state regulations.**  **2) Where any regulation, local, or state guideline is more restr**  **ictive, the more restrictive regulation will be controlling.**  **3) Aircraft limitations that are more restrictive than the F.O.M. will apply.**  **4) The F.O.M. will be updated as new and better practices are discovered, and**  **new regulations become effective. 5)**  **A copy of the F.O.M. will be kept in the immediate vicinity of the P.I.C. during all commercial and training flights.**  **6) Crossfield LLC will make available the F.O.M upon request by any**  **controlling agency including law enforcement officials and the FAA.**

**The Purpose of the Crossfield F.O.M. is to set forth the guidelines that will ensure all flight operations place the**  **utmost importance on public safety. Public safety will always be the paramount consideration in all operations. The protection of property and the**  **insurance of public confidence in the safety of our operations are also of prime consideration.** **Crossfield	L.L.C.** Page 11

**Section 2) Flight crew maintenance and qualifications 1)**  **The PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate.**  **2) The PIC must hold a current FAA airman medical certificate or a valid U.S.**  **driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government.**  **3) The PIC must meet the flight review requirements specified in 14 CFR § 61.56**  **in an aircraft in which the PIC is rated o n his or her pilot certificate.**  **4) Qualification flight hours and currency must be logged in a manner**  **consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience** 

**- building) and determining the PIC’s ability**  **to safely operate the UAS in a manner consistent with how the UAS will be operated.**  **However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience** 

**- building flights, all persons not essential**  **for flight operations are considered nonparticipants, and the PIC must operate the UA with**  **appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 5)**  **The operator may not permit any PIC to operate unless the PIC demonstrates the a**  **bility to safely operate the UAS in a manner consistent with how the UAS will be operated, including evasive and emergency maneuvers and maintaining appropriate**  **distances from persons, vessels, vehicles and structures. 6)**  **The PIC will have logged a minimum of 10 hrs of experience with UAV’s prior**  **to operating in a commercial environment. Crossfield	L.L.C.**  Page 12

**Section 3) Preflight 1)**  **The aircraft will be thoroughly checked prior to any flight. The check will include, but not be limited to:**  **a) The PIC is prohibited from beginning a flight unless (considering wind and**  **forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve**  **power recommended by the manufacturer if greater. b)**  **Condition of rotors ensuring no cracks, nicks, excessive abrasion, and security.**  **c) Security of all mounted sensory equipment. All equipment will have a**  **secondary mounting to prevent separation during flight. This can be in the form of a cable or other means that adequately supports the weight of the sensor should the main**  **mounting sys tem fail.**  **d) Security of all aircraft components to prevent load shift and or possible**  **failure. e)**  **The operator must follow the UAS manufacturers; maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircra**  **ft components.**  **f) Any UAS that has undergone maintenance or alterations that affect the UAS**  **operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations**  **. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from**  **other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.**  **g) Prior to**  **each flight, the PIC must conduct a pre**

**- flight inspection and**  **determine the UAS is in a condition for safe flight. The pre**

**- flight inspection must account**  **for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection re**  **veals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the**  **UAS is found to be in a condition for safe flight. h)**  **Each UAS operated must comply with a ll manufacturer safety bulletins.** 

**2) The operating area will be evaluated and secured by the following means:**  **a) Reasonable precautions will be made to protect people and property under**  **the flight path. b)**  **Current FAA charts will be referenced to c heck for all restricted and special**  **use airspace prior to any flight. Permission from the controlling agency will be acquired prior to flying.**  **c) Current NOTAMs will be checked prior to each flight.** **Crossfield	L.L.C.** Page 13

**d) A manual test flight will be conducted at each o**  **perational location to evaluate actual weather conditions, equipment functionality, and frequency security.**  **e) A visual inspection of all areas to be flown to check for, at a minimum:**  **Schools, airports, heliports, open assemblies of people, power lines, towers, etc.**  **f) The owner/controller of any vessels, vehicles or structures has granted**  **permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it**  **does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered**  **nonparticipating persons. g)**  **All operations shall be conducted over private or controlled**

**- access**  **property with permission from the property owner/c ontroller or authorized**  **representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.**  **h) The designated takeoff and landing area will be clearly marked and secured**  **to within a 2 0’ radius of the UAS.** **Crossfield	L.L.C.** Page 14

**Section 4) Normal Operations/Operating limitations 1)**  **Operations for the purpose of closed**

**- set motion picture and television**  **filming are not permitted. 2)**  **The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to**  **determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airsp**  **eeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.**  **3) The UA must be operated at an altitude of no more than 400 feet above**  **ground level (AGL). Altitude must be reported in feet AGL. 4)**  **The UA must be operat ed within visual line of sight (VLOS) of the PIC at all**  **times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA** 

**- issued airman medical certificate or**  **U.S. driver’s license**

**. 5)**  **All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to**  **satisfy the VLOS requirement as long as the PIC always maintains VLOS capabili ty. The VO**  **and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and**  **cannot transfer his or her designation for the duration of the flight. The PIC must ensure**  **that the VO can perform the duties required of the VO. 6)**  **The PIC will be as visible as possible to the public. He/she will be readily identifiable as the operator of the UA.**  **7) UAS operations may not be conducted dur**  **ing night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC).**  **Flights under special visual flight rules (SVFR) are not authorized. 8)**  **The UA may not operate within 5 nautical miles of an airpor t reference**  **point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the**  **current FAA**

**- published aeronautical chart, unless a letter of agreement with t**  **hat airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder.**  **The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.**  **9) The UA will not be operated within 1,000’ of an active school or an open**  **air assembly of people not affiliated with the operation. 10)**  **Operations within 2 miles of a heliport, seaplane base, or private runway will coordinate such activities with the**  **owner or operator of such facilities. 11)**  **Operations within the lateral boundaries of class B and C airspace, and within 30n.m of a class B airport will get authorization from the controlling A.T.C. (see FAR**  **91.215) for flights without an approved transpo nder.** **Crossfield	L.L.C.** Page 15

**12) Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).**  **All operations shall be conducted in accordance with an ATO**

**- issued COA. The operator**  **may apply for a new or amended COA if it intends to conduct operations that cannot be**  **conducted under the terms of the attached COA. 13)**  **All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification**  **(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as**  **large as practicable. 14)**  **Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the**  **PIC at the Grou nd Control Station of the UAS any time the aircraft is operating. These**  **documents must be made available to the Administrator or any law enforcement official upon request.**  **15) The UA must remain clear and give way to all manned aviation operations and**  **acti vities at all times.**  **16) The UAS may not be operated by the PIC from any moving device or vehicle.**  **17) All Flight operations must be conducted at least 500 feet from all**  **nonparticipating persons, vessels, vehicles, and structures unless: Barriers or struct ures are**  **present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain**  **under such protection. If a situation arises where nonparticipating per sons leave such**  **protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons.** **Crossfield	L.L.C.** Page 16

**Section 5) Weather Limitations 1)**  **The UA may not be operated less than 500 feet below or less than 2,000 feet**  **horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 2)**  **UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual me**  **teorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.**  **3) The UA will not be operated when weather conditions prevent the UA from**  **being able to return to base with a minimum of 20kts ground speed. 4)**  **The UA will not be operated with more than a 10 knot wind gust.**  **5) The UA will not be operated in visible moisture or active precipitation.** **Crossfield	L.L.C.** Page 17

**Section 5) Emergency/Abnormal Operations 1)**  **If the UAS loses communications or loses its GPS signal, the UA will be**  **programmed to return to a pre**

**- determined location within the private or controlled** 

**** **access property. 2)**  **The PIC must abort the flight in the event of unpredicted obstacles or emergencies.**  **3) Any incident, accident, or flight operation**  **that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be**  **reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety B**  **oard 4)**  **The PIC will practice emergency procedures each calendar month. Procedures for evading manned aircraft, assuming manual control, automatic return to base, and**  **equipment failure scenarios will be practiced. 5)**  **The PIC will execute an immediate vert ical descent if a manned aircraft of any**  **type encroaches on the vicinity of the UA. Crossfield	L.L.C.**  Page 18

**Section 6) Maintenance The UV will be kept in a safe, airworthy condition. The operator may replace parts,**  **but the parts themselves will be repaired or supplied by the manufacturer. The following**  **will always apply: 1)**  **The UA will be inspected prior to each flight. 2)**  **The UA will have a thourough inspection every 10 Hrs. flight time which will include:**  **a) Battery condition inspection.**  **b) Full**  **control functionality check. c)**  **Lights d)**  **Emergency programming checks e)**  **Rotor inspection f)**  **Overall structural condition 3)**  **Any other inspection as required by the manufacturer’s manual. 4)**  **The Inspections will be recorded, and all maintenance performed will be**  **documented including the date, item effected, and maintenance performed.**