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January 28, 2015

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, D.C. 20590-0001

Subject: Petition to the FAA for Section 333 Exemption

Dear Sir or Madam,

Turner Industries Group, L.L.C. hereby submits to the Federal Aviation Administration, pursuant to the 

FAA Modernization and Reform Act of 2012, an exemption petition, in accordance with Section 333 of 

the Act. 

This letter provides requested information as listed in the FAA’s “Public Guidance for Petitions for 

Exemptions Filed under Section 333” as described as of this date at the FAA website at 

https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/

Turner Industries Group, L.L.C. Background: 

Serving the Petrochemical, Chemical, Refining, Energy, Power Generation, Pulp & Paper and related 

industries, Turner Industries has built its reputation as a world class industrial contractor on safety, 

integrity, reliability, and project execution.

Turner Industries has provided a single vendor solution in heavy industrial construction, maintenance, 

pipe, module and vessel fabrication, equipment, rigging and heavy hauling, and associated specialty 

services for over 50 years. 

The company is privately owned by the Turner family, and headquartered in Baton Rouge, Louisiana. 

Turner Industries has facilities in Port Allen, Sulphur and New Orleans, Louisiana; Houston, Beaumont, 

Corpus Christi and Paris, Texas; and Decatur, Alabama, and works throughout the United States and 

abroad. 

Client recognition of our performance has consistently ranked us among the top industrial construction 

and maintenance service companies. We do a lot of things, but all with one purpose - helping our clients 

become more successful. More company information can be viewed at the company website at 

http://www.turner-industries.com/ .

Purpose for the Exemption

Turner Industries Group, L.L.C. desires to utilize an unmanned aircraft system (UAS), herein described, to 

accomplish aerial photography, surveys and assessments of industrial facilities and construction sites. 
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Contact Information:

William B. Bispeck

Independent Contractor/Consultant for

Turner Industries – Integrated Solutions Group Houston Office

3850 Pasadena Blvd.

Pasadena TX 77053

Mobile: 281-224-0861

Office: 281-282-0746

Email: bbispeck@gmail.com

List of Specific Sections of 14 CFR for which exemption is sought:

This listing matches the list on page 7 of the FAA’s “Public Guidance for Petitions Filed under Section 

333”, Rev. 9/25/2014. 

14 CFR 21, Subpart H –Airworthiness Certificates

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

14 CFR 91.7 (a), Airworthiness required for operation 

14 CFR 91.103 (b) (2), Preflight action 

14 CFR 91.105, Flight crewmembers at stations

14 CFR 91.109, Flight instruction

14 CFR 91.119 (c), Minimum safe altitudes

14 CFR 91.121, Altimeter settings

14 CFR 91.151, Fuel requirements for flights in VFR conditions

14 CFR 91.405 (a), Maintenance required

14 CFR 91.407 (a) (1), Operation after maintenance

14 CFR 91.409 (a) (2), Inspections

14 CFR 91.417 (a) and (b), Maintenance records

(See pages 8 through 10 for further details)
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In accordance with the outline given in the FAA’s “Public Guidance for Petitions Filed under Section 

333”, the following information is provided for each numbered item listed in that guidance:

1. Aircraft Description

Design and Operational Characteristics:

Turner plans to operate a Phantom 2 Vision+ comprised of an unmanned aircraft and a 

transportable ground station. This aircraft is a quad-copter design with gross weight (battery and 

propellers included) of 1242 g (2.74 lbs.). 

The Phantom 2 Vision+ has an integral lightweight camera for capturing aerial still photographs and 

videos. 

It is equipped with four rotors that are driven by battery-powered electric motors. Maximum

airspeed is 30 knots. 

The Phantom 2 Vision+ is equipped with a built-in Flight Control System which includes an integral 

inertial sensor and a barometric altimeter that measure both attitude and altitude. Included is a 

shielded, anti-static compass which reads geomagnetic information and assists in accurately 

calculating position and altitude. 

The Flight Control System includes a Failsafe Function. It activates if the Remote Control is powered 

off, the Phantom has flown outside effective control range, the signal between the Phantom and the 

Remote Control is blocked, or if there is interference causing a signal problem. When activated, the 

Failsafe Function automatically flies the Phantom back to the Home Point (the start location) and 

lands it. If GPS mode is not active, Failsafe will execute a controlled descend and automatic landing. 

Through the Phantom 2 Vision+ Assistant software, each flight operation will be programmed with a 

maximum radius distance and maximum altitude from the Home Point such that the flight control 

system will limit operations to within the confines of the property to be surveyed for Turner or 

Turner’s Clients. These performance limitation requirements are included in the UAS Operating 

Procedure contained in Appendix A herein. 

Manufacturer’s Documentation:

Detailed manufacturer’s design information (current to this date) is contained the in the following 

manuals in the appendices at the end of this document:

 Appendix B – Phantom 2 Vision+ Specifications 

 Appendix C – Phantom 2 Vision+ Quick Start Guide

 Appendix D – Phantom 2 Vision+ User Manual V1.6 

 Appendix E – Phantom 2 Vision+ Pilot Training Guide 

For ease of reference, the Phantom 2 Vision+ is included in FAA Section 333 Exemption No. 11138 

granted on January 5, 2015 to Douglas Trudeau, Realtor®.
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2. Procedures for Ensuring UAS Is In a Condition Safe for Flight

Preflight Checks: As a minimum, the following items will be checked prior to initiating any 

operation. (See Appendix A in this document for detailed procedures, Turner Procedure UAS-001.)

 Operations must be in daylight hours and under visual meteorological conditions (VMC).

 Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for 

each leg of the flight clearly marked.

 Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and 

structures unless protective barriers or structures are present, or permission is granted, or 

such operations present no hazard to the Pilot in Command, the Visual Observer, trainees, 

and other essential persons. 

 Flight plan and schedule has been reviewed with site leadership and communicated to all 

Turner and Client personnel in the area.

 Remote control, smart battery, range extender, and smart phone are fully charged.

 Propellers are mounted correctly.

 Gimbal clamp has been removed.

 Damping absorbers are in good condition, not broken or worn.

 Anti-drop kits have been mounted correctly.

 Camera lens cap has been removed.

 Micro-SD card has been inserted.

 Gimbal is functioning as normal.

 DJI Vision app can connect to the camera.

 Compass has been calibrated.

 Flight radius and altitude limits have been set with the Phantom 2 Vision+ Assistant 

software, not to exceed 400 ft. AGL altitude, and radius limited to the property boundaries 

of Turner or Turner Client site. 

 The Visual Observer (VO) is stationed at the required initial observation point according to 

the flight plan and in view of the Pilot in Command (PIC) and has means for continual verbal 

communication. 

 There are no inoperable components.

 All site required safety permits are approved in in possession of the PIC.

 A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and 

not less than 48 hours prior to the operation.

 Motors can start and function as normal.

 Flight Indicator Lights on the aircraft verify that the Home Point is set to current location.

 Record the Preflight Check, date and sign, and file it in the Equipment Inspection and 

Maintenance Record Book. 
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3. Radio Frequency (RF) Spectrum For Control

The Remote Control ground station operating frequency is 5.278 – 5.85 GHz and is FCC compliant 

with communication distance in an open area of 800 m (875 yds.)

Operating Frequency 5.728 GHz-5.85 GHz

Communication Distance (open area) FCC Compliance: 800m

Receiver Sensitivity (1%PER) -93dBm

Transmitter Power FCC Compliance: 100mW

Working Voltage 120 mA@3.7V

Built-in LiPo Battery Working Current/Capacity 3.7V, 2000mAh

4. Qualifications For The Pilot in Command (PIC)

Certifications: Operations will be conducted by a Pilot in Command (PIC) possessing at least a 

private pilot certificate and at least a current third-class medical certificate. 

Logged Hours: Prior to operations the PIC will have accumulated and logged a minimum of 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS. Training, proficiency, and experience-building flights in dedicated training sessions will 

be included in the accumulated and logged hours. 

Currency: Prior to operations, the PIC will have accumulated and logged a minimum of 5 hours as 

UAS pilot specifically operating the Phantom 2 Vision+. The PIC will have accomplished, during 

dedicated training sessions, 3 take-offs and landings in the preceding 90 days (for currency 

purposes). 

Emergency and Evasive Maneuvers: The PIC will have demonstrated the ability to safely operate the 

Phantom 2 Vision+ in a manner consistent with how it will be operated in surveying Turner and 

Turner Client properties, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. The logged hours reference above will 

document this. 

5. Medical Standards And Certification Of The PIC

As described above, in “4. Qualifications for the Pilot in Command (PIC)”, the PIC will possess at least 

a current third-class medical certificate. 

6. Description Of Intended UAS Operations

Operations will be restricted to Class G airspace. 

No operations will occur within 5 miles of a non-towered airport reference point as denoted on a 

current FAA-published aeronautical chart, unless a letter agreement with the airport’s management 
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is obtained, and the operation is conducted in accordance with a Notice to Airman (NOTAM) as 

required by the Certificate of Waiver or Operation (COA). 

The Phantom 2 Vision+ will be utilized to survey construction sites and industrial facilities in 

Petrochemical, Chemical, Refining, Energy, Power Generation, Pulp & Paper industries. The use of 

small unmanned aircraft systems provides more immediate and thorough information than is 

presently available by other means. In some circumstances scaffolds are otherwise erected to 

accomplish personnel access for inspections of areas very difficult to view from the ground or from

existing stairways, ladders, platforms, and from protective enclosures lifted by cranes. Expense for 

scaffolding, rental of manned aircraft, rental of equipment, and lost time is saved. Safety is 

improved by reducing fall risk for workers and reducing potential for manned aircraft accidents. 

As described in “2. Procedures for Ensuring UAS Is in a Condition Safe for Flight”, altitude and 

distance limits will be entered into the Flight Control System prior to commencement of flight. This 

will restrict the operation to the Turner or Turner Client property. The Failsafe Function integral with 

the Phantom 2 Vision+ will assure this aircraft stays within the area deemed safe for operation. 

Industrial facilities of the type mentioned above have strict safety procedures which must be 

satisfied. Turner’s respect for compliance with these procedures, and Turner’s own safety

performance record, are vital to assuring positive Client relationships and continuing business. All 

safety procedures for personnel and process safety will be strictly adhered to as well as all laws and 

regulations. 

7. Proposed Speed, Altitude, Visibility And Distances

Speed: The Phantom 2 Vision+ is capable of a maximum speed of 15m/s (29.2 knots). In order to 

conserve power, and thereby maximize flight time, and to assure good quality still photographs and 

video, the Phantom 2 Vision+ will be operated at a slow speed along the flight path, typically 2m/s 

(3.9 knots) or below. Higher speeds may be used from time to time when traversing a section of the 

property of no interest and not included in a given study. 

Altitude: Altitudes below 400 ft. AGL are adequate for the complete range of facilities and 

structures to be surveyed. The integral Flight Control System will be set to limit the altitude to 

always be below that level. 

Distances: The integral Flight Control System will be set to limit the radial distance from the Home 

Point (point of flight commencement) such that the Phantom 2 Vision+ will stay within the boundary 

of the property lines. The PIC will operate the equipment to assure those limits are not reached and 

will maneuver the Phantom 2 Vision+ to follow the preplanned flight path within the property 

boundaries. 

The Phantom 2 Vision+ will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud when visibility is less than 3 statute miles from the PIC. 

Operations will be aborted immediately if the PIC encounters unpredicted obstacles or emergencies. 

Safe descent and landing procedures will be followed in accordance with operating documents. 
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8. Description Of The Area Of Intended Operations

As described in “6. Description of Intended UAS Operations”, the Phantom 2 Vision+ operation will 

be restricted to Turner or Turner Client property and not taken into public areas. Turner and Client 

personnel on the site will be made fully aware of the operation prior to commencement of 

operations.

9. Proximity Of Airports

Operations will be restricted to Class G airspace. 

No operations will occur within 5 miles of a non-towered airport reference point as denoted on a 

current FAA-published aeronautical chart, unless a letter agreement with the airport’s management 

is obtained, and the operation is conducted in accordance with a Notice to Airman (NOTAM) as 

required by the Certificate of Waiver or Operation (COA). 

10. Operation Within Visual Line-of-Sight (VLOS)

In addition to the Pilot in Command (PIC), all operations will include a Visual Observer (VO). The VO 

will assure that the Phantom 2 Vision+ is always within their visual line-of-sight (VLOS), as well as the 

PIC’s, at all times. The VO and the PIC will be able to communicate verbally at all times utilizing twoway radios available at Turner and Turner Client sites. 

11. Procedures For Preflight Safety Assessment

Prior to each flight, the PIC will inspect the Phantom 2 Vision+, including the ground control station, 

in accordance with the Preflight Checklist (see “2. Procedures for Ensuring UAS Is In a Condition Safe 

for Flight”). If the Preflight Check indicates any unsafe conditions or a non-functioning safety-critical 

part, the flight will not commence until the needed maintenance is performed and a satisfactory 

Preflight Check can be completed. All maintenance and alterations performed will be documented 

and filed in the Equipment Inspection and Maintenance Record Book.

12. Notifications

In accordance with the COA, a Notice to Airmen (NOTAM) will be requested not more than 72 hours 

in advance and not less than 48 hours prior to an operation.

In addition, any notifications required by the FAA Flight Standards District Office will be made. 

13. Certificate Of Waiver Or Authorization (COA)

Prior to conducting any operations, an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Operation (COA) will be obtained for each aircraft. Services will start with one aircraft, with 

additional units added as needs for operations increase over time. Each Phantom 2 Vision+ aircraft 

will be identified with its 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 will be 

as large as practicable. 
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Specific Regulations for Which Exemption is Sought:

1. 14 CFR 21, Subpart H –Airworthiness Certificates

Part 21 covers certification procedures for products and parts. Subpart H specifies requirements for 

Airworthiness Certificates for various aircraft types. Small unmanned aircraft systems are not 

specifically called out and addressed in these rules.

Turner will, in lieu of airworthiness certification by aforementioned rule, if exemption is granted,

ensure that the Phantom 2 Vision+ system is in compliance with its operating documents as 

described herein. The PIC will assure that all Preflight Checks are completed and documented and

thee is full compliance with all manufacturer’s operation and maintenance documents. 

Due to consideration of the size, weight, speed, and limited operating area associated with Turner’s 

proposed Phantom 2 Vision+, we believe it will not create a hazard to users of the National Airspace 

System (NAS) or the public. Therefore, a request is made for exemption from 14 CFR part 21, and 

any associated noise certification and testing requirements of part 36. 

2. 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

14 CFR 61.113 (a) and (b) prohibit private pilots from fulfilling the role of PIC if the aircraft is carrying 

property for compensation, unless the flight is only incidental to that business or employment. 

Turner believes that due to the size, weight, speed, and limited operating area associated with 

Turner’s proposed Phantom 2 Vision+ operation, a PIC possessing a private pilot certificate and a 

current third-class medical certificate, and also having the aforementioned training and logged 

hours, would ensure safety and prevent creating any hazard to users of the National Airspace 

System (NAS) or the public. We therefore request an exemption from these parts of 14 CFR.

3. 14 CFR 91.7 (a), Airworthiness required for operation 

If the exemption from 14 CFR 21, Subpart H (item 1 above) is granted, no airworthiness certificate 

will be required. On this basis, exemption from 14 CFR 91.7 (a) is requested, presuming that 

airworthy condition by definition in the rule means having an airworthiness certificate. Turner will, 

in lieu of airworthiness certification by 14 CFR 21, ensure that the Phantom 2 Vision+ system is in 

compliance with its operating documents as described herein. The PIC will assure that all Preflight 

Checks are completed and documented and execute full compliance with all manufacturer’s 

operation and maintenance documents. 

4. 14 CFR 91.103 (b) (2), Preflight action 

14 CFR 91.103 (b) (2) specifies that the PIC be familiar with aircraft performance under expected 

values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. 
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Since the Phantom 2 Vision+ will not be operating out of airports this rule is not applicable. On this 

basis, and on the basis that the operating documents cover requirements for operation safety, an 

exemption from this rule is requested. 

5. 14 CFR 91.105, Flight crewmembers at stations

This part requires certain actions by onboard crewmembers. Since the Phantom 2 Vision+ is 

unmanned, an exemption from this rule is requested. 

6. 14 CFR 91.109, Flight instruction

14 CFR 91.109 describes requirements for flight instruction and requires that the aircraft used for 

flight instruction have fully functioning dual controls. The details pertain to manned airplanes and 

are not applicable to a small unmanned aircraft system such as the Phantom 2 Vision+. Flight 

training will be required for the Phantom 2 Vision+ pilot as detailed on page 5 herein, “4. 

Qualifications for the Pilot in Command (PIC).” Compliance with these training requirements with 

logged hours, in combination with a private pilot’s license and current third-class medical certificate,

assure that the required competency for safely operating the Phantom 2 Vision+ will be maintained. 

On this basis an exemption from this rule is requested.

7. 14 CFR 91.119 (c), Minimum safe altitudes

14 CFR 91.119 (c) requires that no operation is permitted below 500 feet above the surface, except 

over open water and sparsely populated areas. The proposed use of the Phantom 2 Vision+ is 

specifically for altitudes that range from the surface to maximum 400 feet AGL. On the basis of the 

aforementioned safety procedures, we believe there will be no increased hazard to users of the 

National Airspace System (NAS) or the public will be created by the Phantom 2 Vision+ as detailed 

here. 

8. 14 CFR 91.121, Altimeter settings

14 CFR 91.121 provides specific rules for altimeter settings for cruising altitude and flight level of 

aircraft and speaks of altimeter stations along the route and the elevation of the departure airport. 

In lieu of these specific requirements, most suitable for manned airplanes, the Phantom 2 Vision+ 

has barometric altimeter and GPS derived altitude capabilities. All altitudes reported to Air Traffic 

Control (ATC) will be in feet above ground level (AGL). On this basis, an exemption from this rule is 

requested. 
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9. 14 CFR 91.151, Fuel requirements for flights in VFR conditions

14 CFR 91.151(a) requires that no person may begin a flight under Visual Flight Rule (VFR) conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing and, assuming normal cruising speed, (1) during the day, to fly after that 

for at least 30 minutes, or (2) at night, to fly after that for at least 45 minutes. 

The Phantom 2 Vision+ has a built-in Low Battery Level Warning Function: 

(1) If the smart battery is depleted to the point that may affect the safe return of the 

aircraft, the low battery level warning notifies the PIC to take action.

(2) The thresholds for these warnings are automatically determined based on the 

current aircraft altitude and its distance from the Home Point. 

(3) A color coded battery level indicator shows battery level, and an estimated 

remaining flight time in minutes is displayed.

(4) When the critical battery level warning activates, the aircraft will gradually 

descend and land automatically. 

As standard operating procedure, the PIC will immediately return the Phantom 2 Vision+ to the 

Home Point for a battery swap when the battery level reaches 25%.

On the basis of these specific safety features of battery power level monitoring, and operating 

procedures, an exemption from this rule is requested. 

10. 14 CFR 91.405 (a), Maintenance required

Please see exemption request explanation in item 15 below (14 CFR 91.417).

11. 14 CFR 91.407 (a) (1), Operation after maintenance

Please see exemption request explanation in item 15 below (14 CFR 91.417).

12. 14 CFR 91.409 (a) (2), Inspections

Please see exemption request explanation in item 15 below (14 CFR 91.417).

13. 14 CFR 91.417 (a) and (b), Maintenance records

Parts 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), and 91.417 (a) and (b), contain requirements for 

maintenance of larger aircraft. In lieu of adapting these rules for the Phantom 2 Vision+, Turner is 

requesting an exemption on the basis that it will inspect the Phantom 2 Vision+ and ensure that it is 

in a condition for safe flight prior to beginning any operation. We propose that adherence to the

operating documents describing the requirements for maintenance, inspection, and recordkeeping, 

are sufficient to ensure that safety is not adversely affected.
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PUBLIC BENEFIT

Granting this Section 333 Exemption would benefit the public in the following ways:

 Public Safety: Common practice for industrial facility construction projects and periodic sitewide industrial facility visual assessment involves utilization of manned aircraft. The potential 

risk to life and property is order of magnitudes less for use of a small unmanned aircraft system 

as compared to conventional aerial photography by manned fixed wing aircraft. 

 Industrial Safety: In order to accomplish inspections of difficult to access areas at high 

elevations requires either erection of scaffolding or lifting personnel by crane in protective 

enclosures to view the subject of interest. Fall protection gear and compliance with OSHA rules 

governing such work is crucial for life safety. The ultimate protection, however, would be to not 

involve personnel in such activity and instead complete this work with an unmanned aircraft 

system.

 Energy Savings and Environmental Protection: Reduction of frequency of manned aircraft used 

to do aerial photography and surveys for construction sites and industrial facilities results in 

burning less fuel thereby saving energy and reducing emissions of combustion gases. 

REASONS SAFETY NOT ADVERSELY AFFECTED AND IS AT LEAST EQUIVALENT TO EXISTING RULE

The key features of the proposed Phantom 2 Vision+ unmanned aircraft system that assure that safety 

to the public and safety of the National Airspace System (NAS) is not adversely affected are the 

following:

 Credentials and training for the Pilot in Command (PIC), along with detailed operating 

procedures, assure that the level of competency required for successful and safe flight 

operations is achieved. 

 The built-in Flight Control System, which includes a Failsafe Function, assures proper flight 

control data feedback to the Pilot in Command (PIC), and immediate return to the Home Point 

and safe landing under failure scenarios, thereby preventing injury or damage.

 Visual Line-of-Sight (VLOS) operation provided by the PIC and the Visual Observer (VO), and 

their ability to communicate verbally at all times, assures full operational control.

 Detailed operations and maintenance procedures, including a Preflight Checklist, provide

assurance of mechanical integrity and full functioning of Phantom 2 Vision+ unmanned aircraft 

system prior to commencement of any operation.
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SUMMARY FOR PUBLICATION IN FEDERAL REGISTER

Petition for Exemption

Docket No.: FAA-2015-xxxx

Petitioner: Turner Industries Group, L.L.C.

Section of 14 CFR 14 CFR 21 Subpart H, 61.113(a) and (b), 91.7 (a), 91.103 (b) (2), 91.105, 

91.109, 91.119 (c), 91.121, 91.151, 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) and (b).

Description of Relief Sought: The petitioner is seeking an exemption to utilize an unmanned 

aircraft system (UAS) to accomplish aerial photography, surveys and assessments of industrial 

facilities and construction sites.

Respectfully Submitted,

William B. Bispeck

Independent Contractor/Consultant to

Turner Industries Group, L.L.C.

John H. Lindsey

General Manager – Integrated Solutions Group

Turner Industries Group, L.L.C.

Please direct correspondence to William Bispeck. Contact information is on page 2.
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Appendix A

UAS Operating Procedure
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Page intentionally left blank
Procedure UAS-001______ ____ Page 15

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Procedure for Unmanned Aircraft System Operations

Procedure Number UAS-001 Type Operation

Authored By Bill Bispeck Revision Number 0

Reviewed By John Lindsey Next Review Date 7-28-2015

Approved By John Lindsey Approved Date 1-28-2015

PURPOSE

The purpose of this procedure is to describe responsibilities and tasks required to safely and successfully 

operate a Phantom 2 Vision+ unmanned aircraft system to accomplish a mission to survey Turner or 

Turner Client construction sites or industrial facilities.

This is a Critical Procedure that requires sign off of the Preflight Checklist for safety and full compliance 

with all steps as required. 

To properly use this procedure, personnel must be aware of safety related information contained in the 

Health, Safety, Environmental Precautions section of this document.

RESPONSIBILITIES

1. PILOT IN COMMAND (PIC): 

a. The Pilot in Command of the aircraft is directly responsible for, and is the final authority for 

the operation and safety of the flight. 

b. In an in-flight emergency requiring immediate action, the PIC may deviate from any rule or 

procedure to the extent required to meet that emergency in order to protect life and 

property.

c. The PIC will assure that all Preflight Checks are completed and documented and execute full 

compliance with all manufacturer’s operation and maintenance documents.

d. The PIC will carry out the flight plan as agreed to and approved by site leadership.

e. The PIC is responsible for maintaining Visual Line-of-Sight (VLOS) with the aircraft during 

operations by direct view with human eyesight.

2. VISUAL OBSERVER (VO): 

a. The Visual Observer is a trained person who assists the PIC with the duties associated with 

collision avoidance, including avoidance of traffic, clouds, obstructions and terrain. 
Procedure UAS-001______ ____ Page 16

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b. The VO will maintain Visual Line-of-Sight (VLOS) with the aircraft at all times during 

operation.

c. The VO will travel to required locations on the site, as specified in the flight plan, and be 

able to communicate verbally with the PIC at all times during the operation. 

HEALTH, SAFETY AND ENVIRONMENTAL PRECAUTIONS

3. Personnel Protective Equipment: The PIC and VO will at all times abide by local site safety rules 

regarding wearing of protective equipment. This typically consists of ANSI approved hard hats and 

safety glasses, but in many locations may also include fire resistant clothing (e.g. Nomex®) and 

safety shoes. 

4. Hazard Communication: Toxic substances used in the work area must be disclosed to personnel

under laws managed by OSHA. The UAS operation does not involve use of any hazardous materials. 

The site being surveyed may contain and process such materials. During the preflight planning 

meeting the PIC and VO should ask if there are any precautions required of them for personnel 

protection and comply with these. Material Safety Data Sheets (MSDS) should be available to aid in 

any awareness needed for specific substances. 

5. Permits: In compliance with local site safety procedures all required permits must be obtained and 

approved. All safety and environmental requirements by those permits and referenced site 

procedures must be followed at all times.

6. Equipment Safety Inspection: Prior to each flight, the PIC will inspect the Phantom 2 Vision+, 

including the ground control station, in accordance with the Preflight Checklist to assure that the 

system is airworthy as determined by the PIC on the basis of these checks and manufacturer’s 

documentation. If the Preflight Check indicates any unsafe conditions or a non-functioning safetycritical part, the flight will not commence until the needed maintenance is performed and a 

satisfactory Preflight Check can be completed. 

7. Site Approval: No operations will start without review and approval of site leadership and 

communication of the site plan and schedule with site personnel. 

8. Conditions: All operations must be in daylight hours and under visual meteorological conditions 

(VMC). No operations will be conducted less than 500 feet below or less than 2,000 feet 

horizontally from a cloud when visibility is less than 3 statute miles from the PIC.

9. Safe Power Levels: As standard operating procedure, the PIC will immediately return the Phantom 2 

Vision+ to the Home Point for a battery swap when the battery level reaches 25%.

10. Collision Avoidance: Altitude and distance limits will be entered into the Flight Control System prior 

to commencement of flight. This will restrict the operation to the Turner or Turner Client property. 

The Failsafe Function integral with the Flight Control System will assure the aircraft stays within the 

area deemed safe for operation, as well as assure altitudes do not exceed 300 feet AGL. By the 

Visual Line-of-Sight (VLOS) method the PIC with assistance of the VO will assure the aircraft avoids 

any other possible traffic, with clouds, obstructions and terrain. 
Procedure UAS-001______ ____ Page 17

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11. Proximity of Airports: Operations will be restricted to Class G airspace. No operations will occur 

within 5 miles of a non-towered airport reference point as denoted on a current FAA-published 

aeronautical chart, unless a letter agreement with the airport’s management is obtained, and the 

operation is conducted in accordance with a Notice to Airman (NOTAM) as required by the 

Certificate of Waiver or Operation (COA). 

12. Emergencies: Operations will be aborted immediately if the PIC encounters unpredicted obstacles 

or emergencies. Safe descent and landing procedures will be followed in accordance with operating 

documents. 

13. Incident Reporting: 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. Site leadership will be notified immediately as specified by local procedures.

14. Qualifications and Training: The PIC will have logged hours and certifications as described in the 

Qualifications for the PIC section of this procedure. The VO will be trained by the PIC regarding duty 

stations for the VLOS method as required by the flight plan and the procedures for verbal 

communication.

PREREQUISITES

15. Operation of the UAS cannot proceed without full compliance with

a. Health, Safety and Environmental Precautions

b. Qualifications for the Pilot in Command (PIC)

c. Preflight Planning 

d. Preflight Checklist

These are covered in the so-named sections of this document.

QUALIFICATIONS FOR THE PILOT IN COMMAND (PIC)

16. Certifications: Operations will be conducted by a Pilot in Command (PIC) possessing at least a 

private pilot certificate and at least a current third-class medical certificate. 
Procedure UAS-001______ ____ Page 18

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17. Logged Hours: Prior to operations the PIC will have accumulated and logged a minimum of 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS. Training, proficiency, and experience-building flights in dedicated training sessions will 

be included in the accumulated and logged hours. 

18. Currency: Prior to operations, the PIC will have accumulated and logged a minimum of 5 hours as 

UAS pilot specifically operating the Phantom 2 Vision+. The PIC will have accomplished, during 

dedicated training sessions, 3 take-offs and landings in the preceding 90 days (for currency 

purposes). 

19. Emergency and Evasive Maneuvers: The PIC will have demonstrated the ability to safely operate the 

Phantom 2 Vision+ in a manner consistent with how it will be operated in surveying Turner and 

Turner Client properties, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. The logged hours reference above will 

document this. 

PREFLIGHT PLANNING

20. Plan: A meeting with site leadership will be conducted to establish the purpose and objectives of 

the operation. Following that meeting, a path of flight over the Turner or Turner Client property to

achieve the operation’s objectives will be displayed on a site plot plan drawing showing 

a. Starting and ending points

b. Required intermediate waypoints for hovering or change of direction 

c. Approximate altitudes along the flight path 

d. Areas of special interest to be surveyed 

e. Clearly marked obstructions or areas to avoid

f. Station points for the PIC and VO at various stages of the operation 

g. Camera on and off points, angle of view, as well as still and video requirements along the 

flight path. 

21. Walk Around: The PIC, the VO, and site leadership will walk the site in accordance with the above 

plan with the aim to observe any additional details that should be taken into account in the flight 

plan. The flight plan will then be adjusted accordingly.

22. Approval: This flight plan will be thoroughly reviewed with site leadership and signed off by both 

the PIC and site leadership.
Procedure UAS-001______ ____ Page 19

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PREFLIGHT CHECKLIST

23. Preflight Checks: As a minimum, the following items will be checked prior to initiating any 

operation. (A form to check off and document completion of these checks is included at the end of 

this procedure document.)

a. Operations must be in daylight hours and under visual meteorological conditions (VMC).

b. Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for 

each leg of the flight clearly marked.

c. Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and 

structures unless protective barriers or structures are present, or permission is granted, or 

such operations present no hazard to the Pilot in Command, the Visual Observer, trainees, 

and other essential persons. 

d. Flight plan and schedule has been reviewed with site leadership and communicated to all 

Turner and Client personnel in the area.

e. Remote control, smart battery, range extender, and smart phone are fully charged.

f. Propellers are mounted correctly.

g. Gimbal clamp has been removed.

h. Damping absorbers are in good condition, not broken or worn.

i. Anti-drop kits have been mounted correctly.

j. Camera lens cap has been removed.

k. Micro-SD card has been inserted.

l. Gimbal is functioning as normal.

m. DJI Vision app can connect to the camera.

n. Compass has been calibrated.

o. Flight radius and altitude limits have been set with the Phantom 2 Vision+ Assistant 

software, not to exceed 400 ft. AGL altitude, and radius limited to the property boundaries 

of Turner or Turner Client site. 

p. The Visual Observer (VO) is stationed at the required initial observation point according to 

the flight plan and in view of the Pilot in Command (PIC) and has means for continual verbal 

communication. 
Procedure UAS-001______ ____ Page 20

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q. There are no inoperable components.

r. All site required safety permits are approved in in possession of the PIC.

s. A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and 

not less than 48 hours prior to the operation.

t. Flight Indicator Lights on the aircraft verify that the Home Point is set to current location.

CAUTION

Flight of the UAS must not proceed unless the Home Point is set in the Flight Control System 

utilizing the manufacturer’s procedures prior to flight. This will assure that the Fail Safe 

Function returns the aircraft to the PIC in case any of the failure scenarios are encountered. 

u. Motors can start and function as normal.

v. Record the Preflight Check, date and sign, and file it in the Equipment Inspection and 

Maintenance Record Book. 

TASKS AND STEPS

24. All operations will be conducted in accordance with the manufacturer’s required procedures for safe 

flight. These requirements are specified in the following documents which will have been used to 

guide flight instruction for the PIC.

a. Phantom 2 Vision+ Quick Start Guide

b. Phantom 2 Vision+ User Manual V1.6

c. Phantom 2 Vision+ Pilot Training Guide V1.1

EQUIPMENT INSPECTION AND MAINTENANCE

25. Preflight Inspection: In accordance with the Preflight Check procedure above, the PIC will complete 

a visual inspection and assessment of the aircraft and determine airworthiness. The Preflight 

Checklist Form will record each item listed to verify that it has been checked. 

26. Record Keeping: Preflight Checklists will be signed and dated by the PIC and filed in an Equipment 

Inspection and Maintenance Record Book.

27. Acceptance: If the Preflight Check indicates any unsafe conditions or a non-functioning safetycritical part, the flight will not commence until the needed maintenance is performed and a 

satisfactory Preflight Check can be completed and the aircraft is accepted as airworthy by the PIC.
Procedure UAS-001______ ____ Page 21

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28. Repairs and Alterations: 

a. All maintenance, repairs, and alterations performed will be documented in detail with 

description of work, parts, names of repair persons, date, and will be filed in the Equipment 

Inspection and Maintenance Record Book.

b. All repairs and alterations will be done in accordance with the manufacturer’s published 

recommendations. 

REFERENCES

 Phantom 2 Vision+ Specifications 

 Phantom 2 Vision+ Quick Start Guide

 Phantom 2 Vision+ User Manual V1.6 

 Phantom 2 Vision+ Pilot Training Guide 
Procedure UAS-001______ ____ Page 22

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Preflight Checklist Form

Checklist Number UAS-001-01 Type Operation

Authored By Bill Bispeck Revision Number 0

Reviewed By Next Review Date

Approved By Approved Date

Check each item as verified complete:

 Operations must be in daylight hours and under visual meteorological conditions (VMC).

 Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for each leg of 

the flight clearly marked.

 Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and structures 

unless protective barriers or structures are present, or permission is granted, or such operations 

present no hazard to the PIC, the VO, trainees, and other essential persons. 

 Flight plan and schedule has been reviewed with site leadership and communicated to all Turner 

and Client personnel in the area.

 Remote control, smart battery, range extender, and smart phone are fully charged.

 Propellers are mounted correctly.

 Gimbal clamp has been removed.

 Damping absorbers are in good condition, not broken or worn.

 Anti-drop kits have been mounted correctly.

 Camera lens cap has been removed.

 Micro-SD card has been inserted.

 Gimbal is functioning as normal.

 DJI Vision app can connect to the camera.

 Compass has been calibrated.

 Flight radius and altitude limits have been set with the Phantom 2 Vision+ Assistant software, not to 

exceed 400 ft. AGL altitude, and radius limited to the property boundaries of Turner or Turner Client 

site. 

 The Visual Observer (VO) is stationed at the required initial observation point according to the flight 

plan and in view of the Pilot in Command (PIC) and has means for continual verbal communication. 

 There are no inoperable components.

 All site required safety permits are approved in in possession of the PIC.

 A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and not less 

than 48 hours prior to the operation.

 Motors can start and function as normal.

 Flight Indicator Lights on the aircraft verify that the Home Point is set to current location.

 Record the Preflight Check, date, sign, file it in Equipment Inspection and Maintenance Record Book. 

__________________________________ ____________________________________ _______

PIC Printed Name PIC Signature Date
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Appendix B

Phantom 2 Vision+ Specifications

1 page follows

(Source: http://www.dji.com/product/phantom-2-vision-plus/spec)
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Appendix C

Phantom 2 Vision+ Quick Start Guide

2 pages follow

(Source: http://www.dji.com/product/phantom-2-vision-plus/spec)
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