### 1 Robert M. Serino

FAA Private Pilot Certificate Number 33442220



## Safety Protocols and System Controls Required Best Practices – Extracted and Adapted from F AA Exemption 11138

1.0 Safety Protocols and System Controls. Safety of the public - on the ground and in the air - is the most important consideration for the Pilot-In-C ommand, and safety must be considered before/during /after conduct of all flight-related activity. The followi ng safety protocols and system controls must be imp lemented for each flight event.

1.1 Pre-Flight Aircraft Protocol:

• Insure PIC and Observer are both in place and read y.

• Insure NAZA-M Software is preset with 150 feet max imum altitude and 750 feet maximum range.

• Insure NAZA-M Software is preset to Intelligent Or ientation Control to allow both manual and automate d activation of Fail-Safe and the Low-Battery mode to result in a Return-to-Home.

• Insure First Person Viewing is enabled.

1.2 Pre-Flight Ground Protocol:

• Check Smart Batteries manually and via Ground Stati on to insure fully charged and ready for use.

• Inspect batteries for damage, lumps, or leakage tha t may affect proper operation.

• Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or unmanageable/uncontrolled flight.

• Check weather forecasts for wind advisory or other conditions that my impact flight.

• Consult five (5) mile radius map for airport vicini ty.

• Contact respective airport to advise of estimated f light time, estimated flight duration, estimated el evation of flight, and any other pertinent information.

• Conduct Compass Calibration for every flight.

• Conduct GPS lock to at least 6 satellites and regis tration of Home Point on Ground Station for every f light.

1.3 Pre-Flight Ground Control Station Protocol:

• Insure Ground Control Station is linked to aircraf t.

• Ground Control Station signal strength is OK.

• Battery level monitoring and low-battery warning is OK.

• GPS signals are OK with not less than 6 satellites.

• Real-time monitoring of Altitude/Speed/Geo-Location are OK.

• Fail-Safe. Auto-Land, Return-to-Home, Home-Lock, Co mmand Shut-Off, and Software-Based Altitude and Range Maxima are confirmed OK and operable.

1.4 Inspect Flight Area:

• Vicinity of public safety helipads/heliports.

• Vicinity of medical helipads/heliports.

• Vicinity of light poles.

• Vicinity or utility wires.

• Vicinity of trees.

• Flocks of birds that may cause interference and pot ential flight impact.

• Vicinity of any elevated obstructions that may pose potential flight hazard.

• Vicinity of roadways with moderate to heavy traffic that can be distracted.

### 2

• Public gatherings that may attract viewers.

• Optional point of control for best visual site of U AS while in flight.

1.5 Takeoff and Landing:

• Inspect area for best and safest point of takeoff a nd landing.

• If in a subdivision or area that is within 150 feet of a residential street, post warning sign(s)/stan d(s) "Attention Aerial Photography In Progress - Remain Back 150 Feet ".

1.6 In-Flight Protocol:

• Takeoff and land from same location.

• Reporting of Ground Control Station signal strength is OK.

• Reporting of battery level monitoring and low-batte ry warning is OK.

• Reporting of GPS signals are OK with not less than 6 satellites.

• Reporting of Altitude/Speed/Geo-Location are OK.

• Remain alert to birds, sound or aircraft, curious p ublic, and approaching vehicles.

• Do not allow anyone to engage in conversation or di stract the remote control pilot.

• Restrict flight to minimal elevation sufficient to acquire desired results.

• Remain prepared for emergency landing at all times.

• Pay attention to flight time.

• Set a timer or have a clock as a safety alert.

• Land UAS and shut down propulsion immediately follo wing landing.

1.7 Post flight:

• Remove battery to prevent accidental activation of propulsion system.

• Remove props to prevent accidental activation of pr opulsion system.

• Secure UAS in a safe location.

• Remove all warning signs from public access areas.

1.8 Emergency Situation or Suspected Hazard or Pote ntial Problem ...

 Immediately land UAS at safest and closet ground l ocation in the event of any of the following:

• Manned aircraft is heard or seen in vicinity of fli ght.

• Public gathering within established safety boundary wanting to observe flight.

• Pilot is being distracted from focusing on flight a nd safety.

• Sudden change in weather (wind bursts) or visibilit y.

• Sudden increase in vehicular traffic in vicinity of flight.

• Birds enter into proximity of flight.

• Sudden unpredicted and unsafe event that can cause collision, distraction or interruption of control.



## 2.0 Required Best Practices – Extracted and Adapted f rom FAA Exemption 11138

2.1 Operations authorized by this grant of exemption a re limited to the following aircraft described in t he operating documents which is a quad-rotor aircraft weighing less than 3 pounds: PHANTOM 2 Unmanned Aircraft System (UAS). Proposed operations of any o ther aircraft will require a new petition or a peti tion to amend this grant.

2.2 The UA may not be flown at an indicated airspeed e xceeding 30 knots.

### 3

2.3 The UA must be operated at an altitude of no more than 300 feet above ground level (AGL), as indicate d by the procedures specified in the operating documents . All altitudes reported to Air Traffic Control (AT C) must be

in feet AGL.

2.4 The UA must be operated within visual line of sigh t (VLOS) of the Pilot In Command (PIC) at all times . This requires the PIC to be able to use human vision una ided by any device other than corrective lenses, as specified

on the PIC’s FAA-issued airman medical certificate.

2.5 All operations must utilize a visual observer (VO) . The UA must be operated within the visual line of sight (VLOS) of the VO at all times. The VO may be used t o satisfy the VLOS requirement as long as the PIC a lways maintains VLOS capability. The VO and PIC must be a ble to communicate verbally at all times. The PIC m ust be designated before the flight and cannot transfer hi s or her designation for the duration of the flight . The PIC must ensure that the VO can perform the functions prescr ibed in the operating documents.

2.6 The operating documents and this grant of exemptio n must be accessible during UAS operations and made available to the Administrator upon request. If a d iscrepancy exists between the conditions and limita tions in this exemption and the procedures outlined in the operat ing documents, the conditions and limitations herei n take precedence and must be followed. Otherwise, the ope rator must follow the procedures as outlined in its operating documents. The operator may update or rev ise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if he petitions for extension or amendment to this grant of exemption. If the operat or determines that any update or revision would aff ect the basis upon which the FAA granted this exemption, th en the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80 ) may be contacted if questions arise regarding upd ates or revisions to the operating documents.

2.7 Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from operating u ntil the necessary maintenance has been performed and the UA S is found to be in a condition for safe flight. Th e Ground Control Station must be included in the pref light inspection. All maintenance and alterations m ust be properly documented in the aircraft records.

2.8 Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. repl acement of a flight critical component, must undergo a func tional test flight. The PIC who conducts the functi onal test flight must make an entry in the aircraft records.

2.9 The preflight inspection section in the operating documents must account for all discrepancies, i.e. inoperable components, items, or equipment, not alr eady covered in the relevant sections of the operat ing

documents.

2.10 The operator must follow the UAS manufacturer’s ai rcraft/component, maintenance, overhaul, replacemen t, inspection, and life limit requirements.

2.11 The operator must carry out its maintenance, inspe ctions, and record keeping requirements, in accorda nce with the operating documents. Maintenance, inspecti on, and alterations must be noted in the aircraft r ecords, including total flight hours, description of work a ccomplished, and the signature of the authorized pe rson returning the UAS to service.

2.12 Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins and all

manufacturer Software/Firmware Downloads.

2.13 The authorized person must make an entry in the ai rcraft record of the corrective action taken agains t discrepancies discovered between inspections.

### 4

2.14 UAS operations must be conducted by a PIC possessi ng at least a private pilot certificate and at leas t a
current third-class medical certificate. The PIC mu st also meet the flight review requirements specifi ed in 14 CFR

61.56 in an aircraft in which the PIC is rated on h is or her pilot certificate.

2.15 Prior to operations conducted for the purpose of a erial videography/cinematography and augmenting rea l estate listing videos (or similar operations), the PIC must have accumulated and logged, in a manner c onsistent with 14 CFR 61.51(b), a minimum of 25 hours of tota l time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experi encebuilding flights can also be conducted under this g rant of exemption to accomplish the required flight time. However, said training operations may only be condu cted during dedicated training sessions. During tra ining, proficiency, and experience-building flights the PI C is required to operate the UA with appropriate di stances in

accordance with 14 CFR 91.119.

2.16 Prior to operations conducted for the purpose of a erial videography/cinematography and augmenting rea l estate listing videos (or similar operations), the PIC must have accumulated and logged, in a manner c onsistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS p ilot operating the make and model of the UAS to be used in operations under the exemption; 5 hours make and model time may be included in the 10 hours of mult i-rotor time prescribed above. The PIC must accomplish 3 ta ke-offs and landings in the preceding 90 days (for currency purposes). Training, proficiency, experience-buildi ng, and take-off and landing currency flights can b e conducted under this grant of exemption to accomplish the req uired flight time and 90 day currency. However, sai d training operations may only be conducted during dedicated t raining sessions. During training, proficiency, and experience-building flights the 24 PIC is required to operate the UA with appropriate distances in acc ordance
with 14 CFR 91.119.

2.17 The operator may not permit the PIC to operate the UAS for the purpose of aerial videography/ cinematography and augmenting real estate listing v ideos (or similar operations), unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emerge ncy maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and structures.

2.18 UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be conducted under visual meteorological conditions (V MC).

2.19 The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart.

2.20 The UA may not be operated less than 500 feet belo w or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from t he PIC.

2.21 If the UA loses communications or loses its GPS si gnal, it must return to a predetermined location wi thin the planned operating area and land or be recovered in accordance with the operating documents.

2.22 The PIC must abort the flight in the event of unpr edicted obstacles or emergencies in accordance with the operating documents.

2.23 The PIC is prohibited from beginning a flight unle ss (considering wind and forecast weather condition s) there is enough power to fly at normal cruising spe ed to the intended landing point and land the UA wi th 30% battery power remaining.

2.24 The operator must obtain an Air Traffic Organizati on (ATO) issued Certificate of Waiver or Authorizat ion (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours pr ior to the operation.

### 5

2.25 All aircraft operated in accordance with this exem ption must be identified by serial number, register ed in accordance with 14 CFR part 47, and have identifica tion (NNumber) markings in accordance with 14 CFR p art 45, Subpart C. Markings must be as large as practic able.

2.26 Before conducting operations, the radio frequency spectrum used for operation and control of the UA m ust comply with the Federal Communications Commission ( FCC) or other appropriate government oversight agen cy requirements.

2.27 The documents required under 14 CFR 91.9 and 91.20 3 must be available to the PIC at the Ground Contro l Station of the UAS any time the UAS is operating. T hese documents must be made available to the Administrator or any law enforcement official upon request.

2.28 The UA must remain clear and yield the right of wa y to all manned aviation operations and activities at all

times.

2.29 The UAS may not be operated by the PIC from any mo ving device or vehicle.

2.30 The UA may not be operated over congested or dense ly populated areas.

2.31 Flight operations must be conducted at least 500 f eet from all nonparticipating persons, vessels, veh icles,

and structures unless: a. Barriers or structures ar e present that sufficiently protect nonparticipatin g persons from

the UA and/or debris in the event of an accident. T he operator must ensure that nonparticipating perso ns remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease im mediately and/or; b. The aircraft is operated near vessels,

vehicles or structures where the owner/controller o f such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the ris k of operating closer to those objects and determin ed that it does not present an undue hazard, and; c. Operation s nearer to the PIC, VO, operator trainees or essen tial persons do not present an undue hazard to those per sons per § 91.119(a).

2.32 All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Perm ission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

2.33 Any incident, accident, or flight operation that t ransgresses the lateral or vertical boundaries of t he operational area as defined by the applicable COA m ust be reported to the FAA’s UAS Integration Office (AFS80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per

instructions contained on the NTSB Web site: www.nt sb.gov.