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AirCover 425 Safety Checklist

1. Introduction. The safety checklist is for the AirCover 425 in conjunction with its application 

for experimental airworthiness certification. 

2. Aircraft Segment.

a. Airframe

(1) Structure. The AirCover 425 is a small (4.4 pounds) unmanned aircraft craft with 

quad rotors powered by electric engines. The aircraft’s dimensions are 32” X 28” 

X 11”. The aircraft uses 10” fixed-pitch or 12”polymer propellers, each mounted 

on an arm of the aircraft protruding from its central hub.

(2) Composition. 

High Strength Composite Body

Carbon Fiber Legs, Landing Gear 

(3) The aircraft does not have any controllable surfaces other than the propellers. 

(4) There are no unique design characteristics such as a hydraulic system, 

environmental control system, parachute, or brakes.

(5) Measurements.

a. Length – 28”

b. Width – 28”

c. Height – 8”

d. Weight – 4.4 lbs
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b. UA Performance Characteristics. The following are the performance of the aircraft 

within the proposed flight envelope: 

(1) Maximum allowed altitude – 400 feet AGL

(2) Maximum endurance – 25-30 minutes

(3) Maximum range – 2,000 feet

(4) Airspeed.

a. Cruise - 0-20mph

b. Maximum – 32 mph

(5) Maximum rate of climb – 1,100 feet per minute

(6) Maximum rate of descent – 1,100 feet per minute

(7) Maximum bank angle - not applicable

(8) Turn rate limits – not applicable

(9) Identify any performance limitations due to environmental and meteorological 

conditions. Specifically, address the following items:

a. Wind speed limitations.

i. Headwind – 30 mph

ii. Crosswind – 30 mph

iii. Gusts – 30 mph

b. Turbulence restrictions – Not Applicable

c. Minimum visibility conditions – VFR VMC

d. Lighting (for example, daytime flights only) – Not Applicable.

e. Outside air temperature (OAT) limits – 0 degrees F to 110 degrees F

f. In-flight icing – Does not operate in known icing conditions.

c. Propulsion System.

(1) The aircraft uses four electric motors.

(2) Fuel-powered propulsion systems. – Not Applicable

(3) Electric-powered propulsion systems.

a. Brushless DC (BLDC) motor. Each motor shaft is fully supported by 

ball-bearings, and there are no brushes to wearout.

b. 50 watts each, nominally.

c. 0 to 120 watts range, each.

d. The UA avionics run off separate power converters from the motors. 

All load’s power is ultimately derived from the UA battery.

d. Fuel System. Not Applicable

e. Electrical System.

(1) The aircraft uses Lithium Polymer Battery-14.8V, a commercial available battery.
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f. Flight Control Surfaces and Actuators - The aircraft does not have flight control 

surfaces other than the propellers. Flight control, including altitude and directional 

control are managed by the varying speeds of the propellers. The system uses the 

AkrionTM onboard flight computer.

g. Payloads. The aircraft will use various COTS camera sensors that will keep the max gross 

weight of the vehicle at or under 4.4 lbs.

3. Control and Communications Segment.

a. Avionics. The aircraft uses the Akrion onboard flight computer. 

The Akrion handles on one single 4 oz micro circuit all of the avionics architecture, air 

data, telemetry, tracking, black box, GPS and Gyros.
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b. Navigation. – The aircraft is flown line of sight of the operator at or below 400 AGL. The 

onboard flight computer provides heading, GPS location and altitude to the operator. 

However, all information is verified through line of sight assessment of the aircraft.

c. UA Flight Controls.

(1) The RPM of each motor is varied (using electronic PWM motor control) to 

achieve desired UA pitch, roll, and yaw. There are no gears, belts, servo motors, 

or linkages to wear out or act as failure mechanisms. 

(2) The aircraft is either controlled autonomously through the Akrion autopilot or it 

may be manually controlled using the ground station. 

(3) Flight control computer.

a. The flight control computer has no other auxiliary controls that interfere 

in any of the flight control. Constant monitoring of controls is reported 

to the ground station for all movements; any actions are immediately 

reported to the ground station with warning and suggested messages to 

avoid unintended movement. 

b. GS300 provides RF commands to the Akrion which is onboard the 425 

aircraft. This communication is run via 256 encrypt and is written in 

firmware code that is tracking over 40,000 lines of motion control code 

every 100 seconds.

d. Autopilot.

(1) The Autopilot system was modeled after the UAS military reports and tests that 

have been published and the direct development from the more advanced work 

with our engineering that has experience in DOD UAV uses and combined with 

Aviation Standards of VFR private pilot experience. In addition, we researched 

Los Angeles Police Department, Aviation Programs.

(2) The autopilot is not COTS. The autopilot is a proprietary system designed 

specifically for this class of UA.

(3) Correct installation is verified on several levels to provide redundant verification. 

First, a visual inspection is performed. Next, automatic diagnostics are 

performed which ensure proper mounting orientation and connectivity prior to 

powering motors. Then a functional test is performed while the UA is held in 

place. In this manner, all autopilot connections, wiring, mounting, and 

orientation are verified before the any flight is performed. 

(4) The autopilot employs input limit parameters to keep the aircraft within 

structural limits. There are limits on motor RPM, thrust, angular rotation rate, 

absolute attitude orientation angles, ground speed, airspeed, climb rate, and 

rate of descent.

(5) Autopilot commands are passed through the GCS and stored and in and 

executed by the UA autopilot.

(6) Akrion control is based on the imbedded chip technology that operates firmware 

control of all hardware functions. Akion is an advanced motion control 
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architecture that is designed to control vertical takeoff and landing, thrust 

vectored systems in flight. SIL and HIL simulations are carried out in over 9000 

events or simulated and physical flights that control power, coordinated thrust 

to lift the aircraft in control position. Some of the outcomes included; timing of 

opposing prop rotation, sable flight characteristics with increasing load, cross 

wind component testing, vibration dampening and intended introduction of 

system failures and the reaction of firmware, hardware and flight components. 

Extensive years and months have been dedicated to SIL and HIL calculations on 

simulations that allow full 3 D simulated results to be displayed on screen. The 

results provide a minimum of 40,000 attributes in 100 seconds that can be 

plotted on graphical data charts. 

e. Communications.

(1) A time-triggered embedded system is employed to provide extremely robust, 

predictable behavior with absolute worse-case autopilot latency of 9mS and 

worse-case control latency of 27mS.

(2) Communications datalink(s) connecting the UA and the control station. 

a. 900 MHz ISM frequency band is used for control and telemetry. 

Frequency Hopping Spread Spectrum is used to obtain robust link even in 

noisy environments.

b. 256-Bit AES encryption on both control of aircraft as well as telemetry 

data.

c. The maximum data link budget was tested at 5,000 MSL (ground level) 

and with the ground station powered on – the test unit was driven(in the 

back of a pickup truck) while holding by hand the unit. At various 

intervals and in constant voice communication the ground station gave 

commands to operate all systems which was a max – 7 feet above ground 

level. Max distance was 1.2 miles. 

d. The system includes constant monitor of the signal health at all times. 

e. The signal strength is determined by constant communication algorithms 

in the Akrion to determine and report any weakling of signal. The report 

of any signal heath is immediate to the ground station.

f. The system employs redundant communications and constant 

communication validations of the system, its location, performance of all 

system on a millisecond level of detail. All indications of any anomaly are 

reported to the ground station with immediate reporting

g. For satellite links, estimate the system communications latencies 

associated with using the satellite link for aircraft control and for air 

traffic control (ATC) communications. The use of SATCOM is optional and 

has been developed with a program that cannot be reported in this 

communication. The native system does not require any use of any 

SATCOM system. 

h. The signal interference is assessed to be minimal – however as policy we 

assess with customer questions of what frequencies they use or have 
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observed. We include a spectrum analysis to assess. The 900Mh and 

2.4GH can be adjusted according to communications requirements, 

bleed-over from other RF systems. Provided we can verify the signal is 

within acceptable bands for unmanned system – safe operation and total 

control. 

(3) Design characteristics or procedures are in place to prevent or mitigate the loss 

of the control data link due to the following:

a. RF or other interference? Frequency Hopping Spread Spectrum(FHSS), is 

utilized to reduce susceptibility to interference. In addition, 256 bit AES 

encryption ensures rejection of stray, random, and unfriendly radio signal 

intrusion.

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b. The system will power on with a full system diagnostics report on 

operating cycles, engine cycles and lost link. It also includes Akrion 

Firmware revision control and GCS firmware Rev Level. This screen clears 

after any of the control sticks are moved in order for us to proceed with a 

flight. 

c. Flight beyond communications range? Alert Message and Signal Strength 

is constantly reported.

d. Antenna masking during turns and pitch angles? The system is designed 

with antenna type and arrangement to optimize signal strength about all 

allowable orientations and minimize null effects. 

e. Loss of control station functionality? If the station is inoperable or the 

functions are disabled for any reason, the aircraft will stay in a hover and 

remain on station until: 1. The problem is rectified or 2. the aircraft 

depletes the power and will auto land, or 3. The user can optionally cut 

power to the GCS to force the aircraft into lost link mode (see section 

“Lost Link and Flight Recovery”)
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f. Loss of UA functionality? In case of loss of UA communication functions 

the aircraft will perform safe recovery (For details, see section “Lost Link 

and Flight Recovery”). In the case a payload malfunctions, the remainder 

of the aircraft will remain operable. For example, in the extreme 

condition that a payload shorts out the power rail, the UA electronics will 

continue to operate due to isolated power subsystems.

f. Lost Link and Flight Recovery.

(1) Lost link.

a. The screen display alerts lost data link, not able to connect with UA. The 

system continues to attempt to establish reconnect until power is 

exhausted or successful connection. The status display is in the lower left 

side of the screen. The range has been tested to 1.1 miles from ground 

station to UA on ground hold of 9’ MSL, which provides headroom for the 

specified decreased operational range.

b. In the condition of lost link – the 425 will continue to seek connection. If 

connection remains lost for 3 or more seconds, the aircraft will go into 

lost link mode. In this mode, the aircraft will perform one of two 

operations, depending on whether the operator has enabled Emergency 

Return (E-return): 

1.) If the operator has E-return enabled, then upon lost link occurrence, 

the UA will first stop the current flight maneuver. Next it will climb to the 

clearance altitude previously set by the operator (if it is not already at 

least as high as the clearance altitude). Next it will fly to the home 

location. Finally, it will descend and land at the home position. At any 

time, if communication is re-established, the operator can optionally 

regain control. 

2.) If E-return is not enabled, then upon lost link occurrence, the aircraft 

will first stop the current flight maneuver. Next, it will hold a hover 

indefinitely until either a.) communication is re-established or b.) the 

battery gets low. In the case the battery gets low, the aircraft will then 

auto land at its current location. At any time, if communication is reestablished, the operator can optionally regain control. 

In addition, the system also reports the GPS location at all times and will 

give the last known position at the time communications were lost. 

c. The system reports on the ground station loss of data link, alert messages 

and continue until successful or the system lands with no further 

movement. If temporary loss link occurs and then link recovers, an alert 

message is displayed for the remainder of the flight to alert the operator 

that a loss link has occurred in the past during the current flight.
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d. The E-return system previously described allows the operator to 

determine in advance the type of obstacle conditions present, and decide 

accordingly the proper clearance altitude and whether or not to enable Ereturn. This results in safe lost-link operation even when operated at 

ultra low altitudes or near structures, while simultaneously preventing 

the aircraft from climbing to an unintended altitude. It allows for auto 

return and land capability, but only when it makes sense to do so, and 

when it can be done safely.

e. If the control joysticks are engaged while in return home mode the 

operator command override will cancel the return home. The return 

home can be reengaged at any time by pressing the home button.

f. The lost link message is displayed in the control station in simple 

language and has been tested with untrained persons who can see and 

understand the command report “lost data link.”

(2) Flight recovery system (FRS). – Not Applicable 

g. Control Station.

(1) The flight platform and Ground Control Station (GCS) unit folds into a small 

footprint for under 5 lbs.. The AirCover®425 complete system (aircraft, 1410 

grams with battery and camera options). 

(2) The pilot has a standardized screen set up at the initiation of each phase of 

flight. The screen is initialized with GPS location if GPS is accessible, altitude, 

power on 425 and power on GS300, camera system, virtual radar, artificial 

horizon 

(3) The attitude and position are highly precise – synthetic horizon bar and 

orientation of 425 is reported on GS 300 at all times.

(4) Inadvertent activation of safeguards is managed by a safety cover on kill switch 

and separate power on off switch
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(5) The following inadvertent inputs could the pilot enter to cause an undesirable 

outcome: the aircraft power can be killed by pulling the spool up switch. The 

master key can be switched off and the aircraft will continue to establish 

contact until the GS300 is turned back on, if the kill switch is off the system will 

wait until the command clears and kill switch is on. At that time the kill switch 

can disable the 425. 

(6) The ground station is running simple commands to the Akrion control, this 

reporting is intended to simplify the flight control. The ground station is 

providing commands that can override the autonomious control of up down 

left right f If so, what precautionary measures are used to ensure that flightcritical processing will not be adversely affected?

(7) Control position lock-up is not possible unless 256 encryption and signal 

hopping is hacked for only seconds. 

(8) No primary flight controls are based on the Windows operating system?

(9) The system provides constant reporting on battery for the aircraft and battery 

for the ground station. Signal strength, virtual radar and distance from ground 

station. 

(10) Primary power is closed lead acid battery, backup is trickle charge from AC 

power for extended and persistent use.

(11) If the ground station loss of power occurs, first the imagery is lost with test 

pattern screen and alert of signal is displayed. Second the system on board the 

aircraft continues to re-establish contact and holds position until reestablished, if unsuccessful the system will consume aircraft power in the 

hover while reporting its last GPS position; the aircraft will conduct an auto 

land procedure.

4. Ground Support Equipment. Not Applicable

5. Processes and Procedures.

a. Configuration Management

(1) All configurations are rev controlled with affectivity rolls to the next higher level 

change according to documented approvals. 

(2) Describe the procedures used for controlling drawings, test procedures, 

engineering changes, etc. Part Number, Rev Level, Date and configuration 

control using CADCAMCAE control files for all hardware and firmware .

(3) All systems undergo a 100% AQL level of inspection. We have team members 

with extensive backgrounds from Hewlett Packard and Caterpillar Management. 

We employ re-qualification of all parts both internal and external. We take full 

advantage of proto

b. Software Management.

(1) 100% of all software functions were developed by AirCover.
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(2) Software development process(es) have been used in the development of 

software components for the aircraft and the ground control station, and 

software lifecycle data is available for review - Applied configuration control, 

software practices used at Agilent and Hewlett Packard. All version control 

changes or enhancements undergo extensive regression testing. All firmware 

life cycle data can be reviewed including all onboard flight history of all flights 

within the flight data recorder.

(3) System software updates configuration control is based on serial number, part 

number, documented supply chain parts for the particular period build. 

Updates are documented in control documents, drawings, CAD,CAM,CAE 

math.

(4) The function of software, is in effectly referred to as firmware that is computer 

programing at the level (no windows or other proprietary tools). The design of 

Akrion is based on raw chip programing, firmware that is imbedded and 

software that interfaces to present and full system that is coded. The 

commands between akrion controller, speed controllers, power management, 

and motors is highly advanced and proven in design and testing for over 7 

years.

(5) Firmware and software are validated in virtual simulations, tested on test sleds 

inside out test hanger. The other testing is conducted on measurement test 

sleds, dyno test sleds and other fixed testing platforms indoors at our testing 

lab and hanger.

(6) The supplier oversight includes research into the supplier, history review, 

sample materials testing to include significant destructive testing. 

Configuration is managed with control documents specifications and formal 

drawings.

(7) The control of loading is conducted with naming conventions, block builds of 

product in controlled areas using JIT/KANBAN and Rolling Carts for each 

specific unit build. The software components are loaded via lead firmware 

engineer. The lead firmware engineer approves the block build and the 

naming of each controller for the named components to be loaded. This 

results in a named unit, date, and approval signoff.

(8) The following software quality assurance processes are used in the 

development of the system software - AirCover uses two person integrity and 

control logs for testing, changes, and effectivity rolling of system 

firmware/software. Suppliers are vetted based on detail technical review. One 

part sampling and destructive testing validation before they can be approved.

(9) Reporting is conducted on a daily basis and collected via testing reports, field 

reports customers and logged into a master data base for priority testing. How 

are suppliers integrated into the problem reporting system? Suppliers are 

integrated by furnishing reports on part test results, destructive testing and 

AirCover pilot test unit testing before acceptance from suppliers.

(10) Configuration changes are handled by three levels, inline change, roll to the 

next level of interchangeability, and change to the top level. Each level has 
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review of the part numbers, CAD FILEs and CAM programs if machined. 

Documentation of procedures are defined as resident assembly procedures to 

build. And, engineering procedures to address effectivity as described above. 

How are they documented? CAD CAM file naming linked to part files used in 

fabrication and assembly.

(11) C++ programming language is used.

(12) Control logs, tracking, self-audit, revision change control and unit / regression 

testing and formal documented test procedures.

c. Electronic Hardware Design and Testing.

(1) The following standards and processes are used to design, test, and modify electronic 

hardware system elements - IEC 65A Structured programing for control systems which 

has evolved to IEC SC 65A Control Programming 

(2) All parts are 100% testing in simulation and physical tests within our secure test 

facility indoors. All safety features are testing to limits beyond recommended 

levels of use. All are documented and majority are recorded in full motion view 

from the UA and from placed camera angles for testing monitoring. 

6. Operations.

a. National Airspace System (NAS) Integration and Interaction

(1) Surveillance and Aircraft Visibility.

a. Is the UA equipped with TSO approved Mode-C or Mode-S transponder? 

No. It will not be flown in Class B, C or D airspace.

b. Does the UA have a high-visibility paint scheme that enables other pilots 

to see and avoid the UA and enables the observer(s) to visually acquire 

and track the UA? – Not the aircraft is a small UAS.

c. Does the UA have anti-collision lights? Does the UA have position lights? 

What are the procedures if the lights are inoperative? Not Applicable

(2) Air traffic control and crewmember communications.

a. How does the pilot communicate with ATC? – The pilot will call ATC prior 

to operations. The pilot will have two way communication capability 

using cell phones. The pilot will also have a handheld VHF radio.

b. How does the pilot communicate with other users of the airspace? – The 

pilot will have a hand held VHF radio.

c. Is there an intercommunication system that allows for communication 

between the pilot(s), ground support personnel, crewmembers, and 

observers? – Direct communications as all flight team members will be 

immediately next to each other.
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d. What procedures have been established in the event of intercom failure? 

Not Applicable.

(3) Sense and avoid. Not Applicable – The aircraft is flown line of sight at all times.

(4) Chase aircraft operations. – Not Applicable

b. Flight Phases.

(1) Preflight/taxi operations.

a. All participants in a flight operation will attend a pre-flight briefing that 

will discuss the nature of the mission, the duration of the flight, any risks, 

emergency procedures and objectives. The preflight mission will include 

a weather briefing. 

b. Describe your coordination procedures with ATC before takeoff by 

addressing at a minimum:

i. Notices to Airmen (NOTAM). – If requested by the FAA, a longterm NOTAM may be filed indicating the possibility of UAS 

operations at or below 400AGL in the vicinity of operations.

ii. Filing the flight plan. – Not Applicable 

iii. Transponder codes - Not Applicable

iv. ATC will be notified of all flight operations at least 1 hour prior to 

launch and immediately prior to launch. The notification will 

include the location, duration, maximum altitude, and emergency 

contact information. 

c. Describe UAS preflight activities and the system and support equipment 

required by addressing at a minimum:

i. See Attached Safety Checklist

ii. See Attached Operations Manual 

d. The mapping is immediate reporting of ground location by as many as 16 

GPS SATCOM interfaces. However in GPS denied space, the system still 

performs accurate position sensing. The mapping data is available 

through multiple interfaces. First, a “virtual radar” map is visible on the 

primary GCS display at all times. This display is driven by a real-time 

embedded system which is highly reliable and not dependent on a 

windows operating system (or similar). In addition, if further mapping 

capabilities are required for a particular mission, the GCS can be 

connected to a PC running Google Earth or other paid for services for 
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mapping. The mapping updates can be immediate and reported by 

porting from ground station to computer laptop accessible to web based 

mapping software.

e. How do you ensure the area is clear for taxi? Visual inspection

f. Describe the procedures to ensure the engine isn’t started in a manner 

that could cause injury to ground personnel. – The engines are not 

activated until all personnel are clear of the aircraft.

(2) Take off/launch. The aircraft is a VTOL UAS that permits gradual safe takeoff 

from a confined area.

(3) Flight.

a. The aircraft is flown using the ground control station. The aircraft is 

maintained via line of sight at all times. The pilot can control the aircraft 

manually or through autonomous flight using the ground control station. 

b. Describe the method for switching between pilot-controlled (manual) 

and autonomous flight modes. At what points during the flight will this 

happen? Not Applicable

a. What indication does the pilot have that they are in control of the 

aircraft? There is a visual indication on the ground station showing data 

link. In addition, the aircraft is within line of sight such that the operator 

can see the aircraft’s response to direct control inputs.

(4) Landing/recovery. The aircraft it a VTOL UAS that will hover to its landing zone. 

No additional equipment or personnel are needed to secure landing. 

(5) Post flight.

a. Describe the process for a post-flight inspection. – The aircraft is 

inspected after each flight to ensure all system are physically intact and 

operational. Any damage components will be replaced. In the event the 

aircraft suffers an incident, the aircraft will undergo a full inspection by 

AirCover engineering.

b. Describe the process for incident/accident reporting. Any aircraft incident 

or accident that involves lost link or substantial damage to the aircraft or 

other property or contact with an individual will be reported to the FAA 

as soon as possible.

c.
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c. Operating Areas.

(1) How do you ensure that there is no unusual ground activity under the flight 

operations area? For example, are there any weekend events scheduled? Are 

there housing areas or public gathering places? The aircraft is flown on private 

land with a secure perimeter. 

(2) See attached documentation for the operating areas.

d. Flight Envelope and Test Plans.

(1) Describe the conditions under which flight envelopes will be tested. How close 

will operations be to any populated areas and major highways? See attached 

documentation for operating areas. The flight will be operated over rural land 

that is privately owned. 

(2) Describe how you plan to meet test objectives under the proposed flight 

envelope and operating area. Include test plans, if possible.

i. See FAA Test Area Submission for Whiskey Town Lake application 

ii. See FAA Iowa Test Area application

iii. See FAA 7 Hills Cattle Ranch Testing Area application.

iv. Conduct stable flight missions for imagery

v. Conduct medium altitude testing for flight duration

vi. Conduct high wind testing to hold in close urban area’

vii. Conduct extended range flights to determine limits on range in different 

weather conditions

viii. Conduct flight with extended down-range control

e. Operating History. 

(1) The test bed and prototypes UA’s have undergone 5 years of testing and over 

6,000 power-on or flight events. Estimated total test flight time exceeds 150 

hours with flights averaging 5 minutes to 23 minutes.

(2) Destructive testing resulted in changes to inner body, placement of UA 

controller, leg and arm re-design. 

f. Manuals.

(1) Is there an operating manual for the aircraft? See Attached

(2) Does the manual have a section with all of the aircraft limitations in one 

location? See Attached

(3) Does the operating manual have bolded or underlined procedures for 

emergencies for memory item steps? See Attached

(4) Is there an operational checklist for all phases of the operation? See Attached
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(5) Are there separate checklist items for normal, abnormal, or emergency 

procedures? See Attached

7. Organizational Considerations.

a. Pilot/Crew Qualifications/Training Reference: 14 CFR part 61 – Certification: pilots, 

flight instructors, and ground instructors; part 63 – Certification: flight crewmembers 

other than pilots; part 65 – Certification: airmen other than flight crewmembers.

(1) Crew. Is there a crew resource management training program? If so, describe the 

program. AirCover provides a training program for its operators. See Attached. 

The CRM is managed through standard process for pre-flight, flight planning, 

mission execution and post-flight briefing. The operators will include a pilot and 

observer. 

(2) Pilot.

a. Do the pilots have a current pilot certificate? Yes, commercial and private 

pilot certificated pilots.

b. Do the pilots have a current medical certificate? 2nd class medical 

certificates.

c. Describe in detail and reference any procedures that show that the pilots 

are properly trained. – In addition to FAA pilot knowledge exams, the 

pilots will also complete the attached AirCover training. 

d. Is there an established formal training curriculum for all pilots including 

PIC, supplemental, or chase pilots(s)? Yes. See Attached.

e. Is the pilot type rated for the aircraft being flown? Not Applicable.

(3) Observer.

a. Do the observers have a current pilot certificate? If so, what type of pilot 

certificate? Yes, commercial and private pilot certificated pilots.

b. Do the observers have a current medical certificate? If so, what class of 

medical certificate? 2nd class medical certificates.

c. Does the observer understand the applicable aviation regulations such as 

see and avoid, clear of clouds, and right of way rules? Yes

d. Is the observer a current pilot or have a training curriculum? Is there an 

established formal training curriculum for all observers? If so, please 

provide it during the site visit.