Page 1 of 30

January 2 8 , 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 accordanc e 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 Gene ration, 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 indust rial 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, Louisian a. 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.Page 2 of 30

Contact Information:
William B. Bispeck Independent Contractor/Consultant for
Turner Industries

– Integrated Solutions Group Houston Office
3850 Pasadena Blvd.
Pasadena TX 77053
Mo bile : 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 Pet itions 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)Page 3 of 30

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 Visio n+ 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 captur ing 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 integr al
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
land s 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. 1 1138 granted on January 5, 2015 to Douglas Trudeau, Realtor®.Page 4 of 30

2. P rocedures f or Ensuring UAS Is In a Condition Safe f or Fli ght

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

. (See Appendix A in this document for detailed procedures, Turner Procedure UAS

- 001.)

 Operat ions must be in daylight hours and under visual meteorol ogical 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 co ndition, 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 v erify 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.Page 5 of 30

3. Radio Frequency (RF) Spectrum For Control

The Remote Control ground station operating f requency 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 multi

rotor 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 accomplish ed , during dedicated training sessions, 3 take

- offs and landings in the preceding 90 days (for currency purposes).

Emergenc y 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, v essels, 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 (PI C) ”

, 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 managementPage 6 of 30

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 immed iate 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, ladd ers, 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 aircr aft 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 Turn er 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 b e 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 st rictly 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 propert y 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 wil l 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 acco rdance with operating documents.Page 7 of 30

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 Ai rports

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
i s 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 w ill 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 two

w ay 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 o r a non

- functioning safety

- critical part, the flight will not commence until the needed maintenance is performed and a satisfactory
Pr eflight 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.Page 8 of 30

Specific Regu lations 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 a ssociated 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 ai rcraft 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+ operati on, 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 there fore 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 Vi sion+ 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 aircr aft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.Page 9 of 30

Since the Phantom 2 V ision+ 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 require d 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 medic al 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 opera tion 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
afor ementioned 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 airplane s, 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.Page 10 of 30

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

p oint of intended landing and, assuming normal cruising speed, (1) during the day, to fly aft er 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 Functi on :

(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 powe r 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 maintenanc e

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 inspe ct 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.Page 11 of 30

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 site

wide indust rial 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 ai rcraft.

 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 protectio n 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 Co mmand (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 C ommand ( PIC )

, and immediate return to the Home Point
and safe landing under failure scenarios, thereby preventing injury or damage

.

 Visu al 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, p rovide

assurance of mechanical integrity and full functioning of Phantom 2 Vision+ unmanned aircraft system prior to commencement of any operation.Page 12 of 30

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: T he petitioner is seeking an exemption to utilize an unmanne d 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.Page 13 of 30 

# Appendix A
UAS Operating ProcedurePage 14 of 30

Page intentionally left blankProcedure UAS

- 001______

____ Page 15

Page 15 of 30 

## 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 fligh t 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

Page 16 of 30 b. The VO will maintain Visual Line

- of

- Sight (VLOS) with the aircraft at all ti mes 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 Pr otective 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 procedur es 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 accordanc e 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 safety

critical part, the flight will not commence until the needed maintenance is performed a nd 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 dayli ght 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 standa rd 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: A ltitude and distance limits will be entered into the Flight Control System prior

t o 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 th e aircraft stays within the area deemed safe for operation , as well as assure a ltitudes 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

Page 17 of 30 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

oper ation 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 Transpo rtation 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 l ogged 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
communicati on.

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 secti ons 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

Page 18 of 30 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 multi

rotor UAS. Training, proficiency, and experience

- build ing 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 accomplish ed, 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 Vis ion+ 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, v essels, vehicles and structures. The logged hours refe rence 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 ac cordingly.

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

Page 19 of 30 PREFLIGHT CHECKLIST

23. Preflight Checks: As a minimum, the following items will be checked pr ior 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 pla n 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 th e 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 vie w of the Pilot in Command (PIC) and has means for continual verbal
communication.Procedure UAS

- 001______

____ Page 20

Page 20 of 30 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 7 2 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 s cenarios 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 airwor thiness. 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 safety

critical 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

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____ Page 21

Page 21 of 30 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 R ecord 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 GuideProcedure UAS

- 001______

____ Page 22

Page 22 of 30 

## 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 protectiv e 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 th e 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 fli ght 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 reques ted 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, dat e, sign, file it in Equipment Inspection and Maintenance Record Book.

__________________________________ ____________________________________ _______

PIC Printed Name PIC Signature DatePage 23 of 30 

# Appendix B
Phantom 2 Vision+ Specifications

1 page follows

(Source: http://www.dji.com/product/phantom

- 2

- vis ion

- plus/spec )Page 24 of 30

Page intentionally left blankPage 25 of 30Page 26 of 30

Page intentionally left blankPage 27 of 30 

# Appendix C

Phantom 2 Vision + Quick Start Guide

2 pages follow

(Source: http://www.dji.com/product/phantom

- 2

- vision

- plus/spec )Page 28 of 30

Page intentionally left blankPage 29 of 30Page 30 of 30