UASHOT AERIAL FILMWORKS, INC.

1

UASHOT Aerial Filmworks , Inc 1545 Euclid Avenue Apt 6C

 Miami Beach ,FL 33139 

 carlosespiga@hotmail.com

 Tel. (305)766-2604

 

 

United States Department of Transportation July 12, 2015

Docket Management System 

1200 New Jersey Ave

SE West Building Ground Floor Room W12-140

Washington, DC 20590

 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 

2012 and Part 11 of the Federal Aviation Regulations from 14 C.F.R 21(h ); 14 CFR §§ 61.23(a) 

and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c); 91.121; 91.151(a)(1); 14 

C.F.R. §91.203 (a) and (b), 91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b).

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 CFR Part 11, UASHOT Aerial Filmworks , Inc. applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

The petitioner requested to operate unmanned aircraft system (UAS) to conduct aerial image 

acquisition for, including but not limited to, the following industries: Closed set motion picture 

and television, Aerial data collection (real estate, short range inspection, mapping and survey, 

agriculture, search and rescue, inspection) , and training.

UASHOT is managed by :

Carlos Alejandro Espiga Calderon : A licensed FAA Private Pilot with a second class medical 

certificate who passed FAA commercial and instrument knowledge tests , in possession of an 

European JAA commercial and instructor licenses and he has over 4 years recreational and 

hobby experience in all aspects of aerial video, photography and small UAS.
UASHOT AERIAL FILMWORKS, INC.

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Rafael Maza: Filmmaker, for the past 8 years he has been working in the TV and film industry. 

Since then, he has been working on independent projects and has worked with some of the 

biggest television networks and advertising agencies including HBO, Sony, E!, MTV Latino, BVK 

Meka, and Bonzai 3 amongst many others

UASHOT Aerial Filmworks, Inc respectfully requests the grant of an exemption allowing it to 

operate lightweight, remote controlled UAS ́S. 

 DJI Inspire 1.

 DJI Matrice 100

 DJI Spreading Wings S900

The name and address of the applicant is: 

UASHOT Aerial Filmworks, Inc 

1545 Euclid Avenue Apt 6C

Miami Beach ,FL 33139

Phone: (305)766-2604

carlosespiga@hotmail.com

UASHOT Aerial Filmworks, Inc UAS has:

The UAS proposed by the petitioner, the Inspire 1 is an unmanned four-rotor, four-motor 

“quadcopter” manufactured by DJI. The UAS is under 45pounds, will be flown at all times 

under 300 feet AGL as measured by the UAS’ on-board GPS system, will be kept within line of

sight of the Pilot in Command (“PIC”), will have a separate safety Visual Observer (“VO”) at all 

times in communication with and within 5 feet of the PIC, will be flown at all times at speeds of 

40 miles per hour or less, will be flown at all times during daylight hours, always using Visual 

Flight Rules (“VFR”) and within visual line of sight (“VLOS”), and never using first person view 

by the PIC.

If the UAS loses communications or loses its GPS signal, the UAS must return to a 

predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual. The proposed UAS, the DJI Inspire 1, is designed to increase 

altitude 20 meters or 60 feet upon loss of signal between the ground controller held by the 

pilot and the aircraft itself. Upon reaching the higher altitude (a safety feature to avoid people, 

trees and buildings), the UAS will return to its original take-off point of origin and slowly land. 

It is critically important for the pilot to calibrate the aircraft prior to its flight. The calibration 

procedure sets the compass and lets the aircrafts onboard computer know where it is located 

on Earth. The UAS also has a Flytrex black box system installed which tracks every flight so if a 
UASHOT AERIAL FILMWORKS, INC.

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loss of link to the aircraft from the controller ever occurs, then the pilot can follow and retrieve 

the UAS when it lands. Additional details concerning lost-link failsafes can be found in the 

Operator’s Manual.

 DJI Inspire Model T600

Weight (Battery Included) 2935 g 103.5 Ounces 6.5 lbs.

Hovering Accuracy (Vertical) 0.5m 1.6 feet

 (Horizontal) 2.5m 8.2 feet

Max Angular Velocity (Yaw) 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s 16.4 feet/s

Max Decent Speed 4m/s 13.1 feet

Max Speed 22m/s 72.2 feet/s

Max Flight Time 18 minutes

Operating Temperature Range -10° to 40° C

Dimensions 438x451x301 mm 18x18x12 inches 

Attachments: 

1) Inspire 1 User manual Vl.O 2015.07

2) Inspire 1 (Quick Start Guide) Vl.O 2015.05.14

3) Inspire 1 Safety Guidelines Vl.O 2014.12

4) Intelligent Flight Battery Safety Guidelines v1.0 2014-12-31

5) Inspire 1 Maintenance Manual v1.0 2015-02-28

 DJI Matrice Model

Structure Diagonal Wheelbase 650 mm

 Weight (with TB47D battery) 2355 g

Weight (with TB48D battery) 2431 g

Max. Takeoff Weight 3400 g

Expansion Bay Weight 45 g

Battery Compartment Weight 160 g

Zenmuse X3 Gimbal with Camera Weight 247 g

Performance Hovering Accuracy (P-Mode With GPS) Vertical: 0.5 m, Horizontal: 2.5 m

Max. Speed of Ascent 5 m/s

Max. Speed of Descent 4 m/s

Max. Wind Resistance 10 m/s

Max. Speed 22 m/s (ATTI mode, no payload, no wind)

17 m/s (GPS mode, no payload, no wind)
UASHOT AERIAL FILMWORKS, INC.

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Hovering Time (with TB47D battery) No payload: 22 min; 500g payload: 17 min;1kg payload: 

13 min

Hovering Time (with TB48D battery) No payload: 28 min; 500g payload: 20 min;

1kg payload: 16 min

Hovering Time (with two TB47D batteries) No payload: 33 min

Hovering Time (with two TB48D battery) No payload: 40 min

Hovering Time (with TB47D battery and Zenmuse X3) No payload: 19 min

Hovering Time (with TB48D battery and Zenmuse X3) No payload: 23 min

Propulsion System Motor Model DJI 3510

Propeller Model DJI 1345s

ESC Model DJI E SERIES 620D

Flight Control System Model N1

Remote Controller Name C1

Operating Frequency 5.725~5.825 GHz

Transmission Distance 2 km (outdoors and unobstructed)

ChargerDJI approved charger

Dual Users Capability Master-and-Slave control

Battery 6000 mAh LiPo 2S

Max Mobile Device Width 170mm

ChargerModel A14-100P1A

Voltage Output 26.3 V

Power Rating 100 W

Battery (Standard) Name Intelligent Flight Battery

Model TB47D

Capacity 4500 mAh Voltage 22.2 V Type LiPo 6S

Energy 99.9 Wh

Net Weight 600 g

Max. Charging Power 180 W

Battery (Optional) Name Intelligent Flight Battery

Model TB48D

Capacity 5700 mAh Voltage 22.8 V Type LiPo 6S

Energy 129.96 Wh

Net Weight 676 g

Max. Charging Power 180 W

Attachements:

User Manual v1.0 2015/06/30
UASHOT AERIAL FILMWORKS, INC.

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 DJI Spreading wings S900

Frame

Diagonal Wheelbase 900mm

Frame Arm Length 358mm

Frame Arm Weight 

(Including Motor, ESC, 

Propeller )

316g

Center Frame Diameter 272mm

Center Frame Weight 

(with Landing Gear 

Mounting Base, Servos)

1185g

Landing Gear Size 460mm(Length)×450mm(Width)×360mm(Height)

Motor

Stator Size 41×14mm

KV 400rpm/V

Max Power 500W

Weight(with Cooling Fan) 158g

ESC

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight(with Radiators) 35g

Foldable Propeller 

(1552/1552R)

Material High strength performance engineered plastics

Size 15×5.2inch

Weight 13g

Flight Parameters

Takeoff Weight 4.7Kg ~ 8.2Kg

Total Weight 3.3Kg

Power Battery LiPo (6S,10000mAh~15000mAh,15C(Min))

Max Power Consumption 3000W

Hover Power 

Consumption 1000W (@6.8Kg Takeoff Weight)

Hover Time 18min (@12000mAh& 6.8Kg Takeoff Weight)

Working Environment 

Temperature -10 °C ~ +40 °C
UASHOT AERIAL FILMWORKS, INC.

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In order to increase the safety and the UAS capabilities the DJI S900 will be upgraded by a 

licensed ingeneer with the E1200 pro and a Ronim –M gimbal installed with an universal 

plate.

The E1200 is a fine-tuned propulsion system designed for multi-rotor copters weighing 7-15 kg. 

Extensive optimization provides efficiency, safety, and endurance under extreme conditions. 

This system can be used to upgrade platforms with 25mm-diameter arm tube, such as S900.

The Pro version adopts an integrated structure and a total solution for heat dissipation design.

The 17-inch carbon propeller, together with 4216 motor and sine-wave drive ESCs with real 

time diagnostics, unlock vastly greater possibilities for professional aerial photographers.

When using the E1200 Pro to upgrade your S900 using a standard 6S battery, flight endurance 

can be extended by nearly 30% *, assuming a consistent takeoff weight. With greater thrust, 

the maximum take-off weight can be increased by 1.8kg*. 

SAFETY : Each smart ESC can receive real-time diagnostic data from the motor and visually 

communicate its status via high-visibility LEDs. This provides the user with a timely warning in 

the event of abnormal motor function.

Spark-proof circuitry offers enhanced safety and protection when plugging in or unplugging 

the power source.

Moreover, the E1200 Pro is capable of working in environmental temperature up to 60 ̊C

For ultimate convenience, the E1200 Pro’s integrated ESC, motor, and propeller are designed 

as a single unit that can be installed quickly and easily on the arm of any compatible platform. 

It also enables a total solution for heat dissipation.

As one of the largest members of the Z-blade series, the 17-inch propeller boosts both 

efficiency and thrust. The application of advanced ultra-carbon-fiber composite, provides the 

rigidity of a metal propeller with lower inertial momentum. The classic folding design protects 

the propellers while making transportation and use as simple and efficient as ever.

A built-in centrifugal fan provides active cooling for both the ESC and the motor. Grid-shaped 

structure in the top allows for adequate ventilation while keeping dust and other debris out. 

The dissipation area of the integrated base plate has been enlarged by 200-300%, effectively 

enhances passive cooling of the system.

The sine-wave drive ESC increases power efficiency by capturing energy that is produced 

during deceleration. Active braking provides better dynamic response.

The E1200 features a duplex communication port, which allows you to easily and 

independently upgrade the ESC firmware.
UASHOT AERIAL FILMWORKS, INC.

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Specifications Before Upgrading After Upgrading

Take off weight 4.7 ~ 8.2 kg 4.7 ~ 10 kg

Total Weight 3.3 kg 3.7 kg

Flight Max.power consumption 3000 W 4000W

Parameters Hovering power consumption 1000 W 

(@ 6.8 kg Takeoff 

Weight)

770 W

(@ 6.8 kg Takeoff 

Weight)

Hovering Time 18 min

(@ 12000 mAh with a 

6.8 kg Takeoff Weight)

23 min

(@ 12000 mAh with a 

6.8 kg Takeoff Weight)

Working temperature -10 ~ 40 ̊C -10 ~ 60 ̊C

Foldable Size 15×5.2 inch 17×6.0 inch

Propeller Weight 13 g 23 g

Stator Size 41×14 mm 42×16 mm

Motor KV 400 rpm/V 310 rpm/V

Max Power 500 W 700 W

Weight (With Cooling Fan) 158 g 205 g

Diagonal Wheelbase 900 mm 920 mm

Frame Frame Arm Length 358 mm 368 mm

Frame Arm Weight(With 

Motor, ESC, Propeller )

316 g 385 g

Ronin-M

Capture anything you can imagine with a second operator controlling the camera’s movements 

as the first operator moves around set. Achieve perfect framing and complete more complex 

camera movements by working together and making your camera’s motions completely 

independent of the person holding it.

Calculations

DJI S900 with E1200 kit Upgrade : Weight 3.7 kg (8,15 lb) 

Take off weight 4,7 – 10 kg (10.37- 22 lb)

RONIN-M : Weight 2.3kg (5.07lb) fully loaded with handlebar(we will not use the handlebar 

once mounted in the S900)

The maximum load weight of the Ronin-M is 3.6kg (8lbs).

Total DJI S900 E1200 upgrade + Ronim-M gimbal = 11,75 pounds (more restrictive because the 

handles bar are taken into account)

The Cameras that we will use with full batteries and components will never weight more than 

8 pounds., Usually around 2,7 lb like a C100 or less.

Total Weight DJI S900 + Ronim-M + C100 camera = 14,45 lb. (6.55 kg)
UASHOT AERIAL FILMWORKS, INC.

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Maximum Take off weight 22 lb. Hovering Time: 23 min (@ 12000 mAh with a 6.8 kg Takeoff 

Weight)

To be more restrictive and taking into account that we will not be in a hover position all the 

time ,12 minutes flight time is more realistic.

Attachements: S900 User Manual v1.2 2014-12-18

 A2 Quick Start Guide v1.22 2015-05-08 

 Ronin-M User Manual (EN) v1.2 2015-07-01

 E1200 Pro Propulsion Upgrade Kit for S900 User Manual v1.2 2015-08-06

All UAS will be landed with 20% of battery or 5minutes minimum whichever occurs before.

All remote controllers comply with part 15 of the FCC Rules.

Please refer to the documents attached to this petition for further information about the UAS.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

would operate in the following manner: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering. Closed-set motion picture and television filming 

and production.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.
UASHOT AERIAL FILMWORKS, INC.

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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional 

aircraft. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured and designated area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements. The FAA will have 

advance notice of all operations. These safety enhancements provide a greater degree of 

safety to the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.

Use of the sUAS will increase ground safety by eliminating the need to have multiple 

individuals in a helicopter while filming. Manned helicopters pose a risk to the pilots and 

onboard crew. Comparatively, when flying a sUAS, the pilot and crew are safely on the ground, 

rather than several hundred feet in the air, as the FAA has previously determined. The limited 

weight significantly reduces the potential for harm to participating and nonparticipating 

individuals or property in the event of an incident or accident. Additionally, UASs can fly at 

lower altitudes than manned aircraft and requires less room for takeoff and landing, allowing 

for flights to take place over smaller areas.

Regular helicopters are, except as provided in Section 91.119, not allowed to fly less than 500 

feet AGL. UAS on the other hand are best when flown between 50 and 300 feet AGL and in fact

the best video quality is 50 to 100 feet. A large manned helicopter could also cause very 

serious damage to persons or property on the ground and even to pilots and passengers inside 

a manned helicopter. A UAS weighing in at approximately six pounds would not be nearly as 

hazardous. Additionally, a regular helicopter is normally larger than a standard automobile 

whereas the UAS is smaller than a basketball. It is substantially safer for the public to have a 

UAS accomplish the job of aerial photography than a manned helicopter just based on size 

alone. In addition, the UAS can be operated for substantially less costs than a regular manned 

helicopter. The public is significantly served by reducing the cost of videography via UAS 

aircraft.

In reference to filming and videography current operations require a helicopter involving two 

to four or five persons flying at very low altitude trying to achieve an aerial visual effect for a 

scripted scene which is extremely dangerous for all involved including surrounding structures 

and high power electrical lines with the risk of property damage or worst death. In addition, 

motor vehicles with mounted film cranes which extent 25 to 30 feet over and past the motor 

vehicle’s center of gravity requirements to achieve an aerial visual scripted scene effect are 

currently used which is also very dangerous for all involved because of the high risk of the 

motor vehicle crashing into people, other motor vehicles, and buildings causing property 

damage, human injury or death.
UASHOT AERIAL FILMWORKS, INC.

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Additionally, a UAS can complete all these tasks in less than 20 to 30 minutes, a drastic 

reduction in the time it takes the workers, who may otherwise spend three or more hours at a 

time in these conditions. Scenic aerial photographic and cinematographic scripted closed-set 

environments and utility company’s high towers and electric wire inspections made possible 

by the UASs will reveal dangerous conditions, including possible being electrocuted, crashing 

vehicles into people and buildings, causing great harm, injury, or death to all involved in the 

process.

Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the UAS, due to its size, speed of operation, location of operation, 

lack of explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load. 

These limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under the FAA issued exemption as set forth in the Flight Operations 

Manual (FOM) include:

1. - The UAS weighs less than 55 lbs including payload .

2. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). 

3. The exemption holder may use either groundspeed or calibrated airspeed to

determine compliance with the 87 knot speed restriction. In no case will the UA be 

operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground 

level (AGL). Altitude must be reported in feet AGL. 

The sUAS will never enter any MOA or Restricted Airspace, nor shall it violate any TFR 

as outlined by the FAA.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The 

VO and PIC must be able to communicate verbally at all times; electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the VO can perform the duties required of the VO.

The PIC is responsible:
UASHOT AERIAL FILMWORKS, INC.

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• To remain clear and give way to all manned aviation operations and activities at all 

times, 

• For the safety of persons or property on the surface with respect to the UAS, and

• For compliance with CFR Parts 91.111, 91.113 and 91.115 b. UAS pilots will ensure 

there is a safe operating distance between aviation activities and unmanned aircraft 

(UA) at all times.

The PIC is responsible to ensure visual observer(s) are: 

• Able to see the UA and the surrounding airspace throughout the entire flight, and 

• Able to provide the PIC with the UA’s flight path, and proximity to all aviation 

activities and other hazards (e.g., terrain, weather, structures) sufficiently for the PIC 

to exercise effective control of the UA to prevent the UA from creating a collision 

hazard.

Visual observer(s) must be able to communicate clearly to the pilot any instructions 

required to remain clear of conflicting traffic.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS−80) may be contacted if quesons arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations under this 

exemption. Functional test flights may only be conducted by a PIC with a VO and must 

remain at least 500 feet from other people. The functional test flight must be 

conducted in such a manner so as to not pose an undue hazard to persons and 

property.
UASHOT AERIAL FILMWORKS, INC.

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Prior to each flight the PIC will 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 aircraft will be prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station, if utilized, will be included in the preflight inspection. All maintenance 

and alterations will be properly documented in the aircraft records.

Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics (e.g. replacement of a flight critical component) will undergo a 

functional test flight in accordance with the operator’s manual. The PIC who conducts 

the functional test flight will make an entry in the UAS aircraft records of the flight.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it 

is in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and 

the UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, 

the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 14 CFR 

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

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 14 

CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for flight 
UASHOT AERIAL FILMWORKS, INC.

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operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 

14 CFR 61.51(b), 25 hours of total time as UAS pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS to be used for 

operations under the exemption).

In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings 

in the preceding 90 days (for currency purposes).

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property. 

If the UAS and its radio controller disconnects during flight, the system’s failsafe 

protection will come to the rescue and the multirotor will return to home and land 

automatically, rather than flying off uncontrollably or landing at an unknown location.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the 

reserve power recommended by the manufacturer if greater. 

A briefing will be conducted in regard to the planned sUAS operations prior to each 

day’s activities. It will be mandatory that all personnel who will be performing duties in 

connection with the operations be present for this briefing .

Prior to each day’s activity, the flight crew will visit the location for filming to 

determine if it is safe for filming. The flight crew will also brief their clients on the 

limitations of the sUAS and their own internal safety limitations.
UASHOT AERIAL FILMWORKS, INC.

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21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the 

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately in a manner ensuring the safety of 

nonparticipating persons; 

Regarding distance from non-participating persons, the operator will ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved 

and necessary for the filming production. This provision may be reduced to no less 

than 200 feet if it would not adversely affect safety and the Administrator has 

approved it. For example, an equivalent level of safety may be determined by an 

aviation safety inspector’s evaluation of the filming production area to note terrain 

features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (e.g. observers, the public, news media) from debris in the event 

of an accident

and b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does 

not present an undue hazard. The PIC, VO, operator trainees or essential persons are 

not considered nonparticipating persons under this exemption. 
UASHOT AERIAL FILMWORKS, INC.

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27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

For the purpose of closed-set motion picture and television filming and production, the 

following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual 

(MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards District 

Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming 

conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene 

operation of the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 
UASHOT AERIAL FILMWORKS, INC.

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Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the 

UAS operations must comply with all applicable parts of 14 CFR including, but not 

limited to, parts 45, 47, 61, and 91.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In 

all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed.

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: 

Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot 

certificate may act as a pilot in command of an aircraft that is carrying passengers or property 

for compensation or hire. We may achieve an equivalent level of safety as achieved by current 

regulations because the applicant’s UAS do not carry any pilots or passengers nor property. 

The risks attendant to the operation of UAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR 61. The PIC of the UAS will have the proper 

certifications.
UASHOT AERIAL FILMWORKS, INC.

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14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority 

to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from 

which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, the UAS will never operate at higher than 400 AGL.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighting far more than 

the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure 

separation between these UAS operations and the operations of conventional aircraft that 

must comply with Section 91.119. 

Regarding distance from non-participating persons, the operator will ensure that no persons 

are allowed within 500 feet of the area except those consenting to be involved and necessary 

for the filming production. This provision may be reduced to no less than 200 feet if it would 

not adversely affect safety and the Administrator has approved it. For example, an equivalent 

level of safety may be determined by an aviation safety inspector’s evaluation of the filming 

production area to note terrain features, obstructions, buildings, safety barriers, etc. Such 

barriers may protect non-participating persons (e.g. observers, the public, news media) from 

debris in the event of an accident

UASHOT requests an exemption to allow it to conduct flight operations closer than 500 feet to 

vessels, vehicles and structures when the owner/controller of any such vessels, vehicles or 

structures grants permission for the operation and the PIC makes a safety assessment of the 

risk of operating closer to those objects and determines that it does not present an undue 

hazard. 

UASHOT also requests an exemption allowing it to fly closer than 500 feet to participating 

individuals. 

Equivalent level of safety: UASHOT will not operate the sUAS any higher than 400 feet AGL, 

and the majority of flights will be closer to 100 feet AGL. Furthermore, while UASHOT will not 

be operating over any congested areas, the sUAS will necessarily be flown closer than 500 feet 
UASHOT AERIAL FILMWORKS, INC.

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to the natural areas and structures it will be filming. When planning operations, UASHOT will 

work with local FSDO to determine the proper location for filming. Additionally, prior to each 

operation, UASHOT flight crew will conduct a safety assessment and will not operate its sUASs 

without determining that there are no undue safety hazards. UASHOT will also have a buffer 

zone to prevent unauthorized individuals from entering into the flight area. UASHOT VOs will 

serve as fence posts on the outer edges of the flight operational area in order to actively 

monitor the space for unauthorized and nonparticipating individuals. Should one appear, PIC 

will safely land the sUAS in a manner meant to avoid the unauthorized/nonparticipating 

individual. This will provide an equivalent level of safety to 14 C.F.R. 91.119(b) and (c) because 

the PIC and flight crew will make a safety assessment of the risk of operating, and determine 

that it does not present an undue hazard.

14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the safety check list 

and live flight data monitoring, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 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 battery powering the UAS provides approximately 18 minutes(INSPIRE 1) , 40 MIN 

(MATRICE 100) and 12 min (octocopter) of powered flight. To meet the 30 minute reserve 

requirement in 14 CFR §91.151, UAS flights would be limited to approximately -12 and -18

minutes in length. Given the limitations on the UAS’s proposed flight area and the location of 

its proposed operations within a predetermined area, a longer time frame for flight in daylight 

or twilight VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed. Applicant believes 
UASHOT AERIAL FILMWORKS, INC.

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that an equivalent level of safety can be achieved by limiting flights to where (considering wind 

and forecast weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. This restriction would be more than 

adequate to return the UAS to its planned landing zone from anywhere in its limited operating 

area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The 

regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: (1) An appropriate and current airworthiness 

certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued under 

§91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers 

or crew. 

The UAS fully loaded weighs no more than 55 lbs. including payload and is operated without 

an onboard Pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the UAS will have immediate access to them, to the extent 

they are applicable to the UAS, and should they be issued.

FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 

of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook. An equivalent level of safety 

will be achieved because the UAS is very limited in size and will carry a small payload and 

operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS 

can land immediately and will be operating from no higher than 400 feet AGL. The operator 
UASHOT AERIAL FILMWORKS, INC.

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will ensure that the UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, 

the operator will ensure that the UAS is in working order prior to initiating flight and perform 

required maintenance needed. 

Likewise, the exemption sought will not adversely affect safety because UASHOT Aerial 

Filmworks ,Inc. will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents.

To ensure that the UAS continues to offer optimal performance and to ensure flight safety, it is 

recommended that comprehensive maintenance be performed as specified in the 

Maintenance Manual after every 100 flights or 25 flight hours.

In conclusion, satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 

(size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security) provide more than adequate 

justification to grant the requested exemptions. 

Attachments: 

Inspire 1 User manual Vl.O 2015.07

Inspire 1 (Quick Start Guide) Vl.O 2015.05.14

Inspire 1 Safety Guidelines Vl.O 2014.12

Intelligent Flight Battery Safety Guidelines v1.0 2014-12-31

Inspire 1 Maintenance Manual v1.0 2015-02-28

Matrice 100 User Manual v1.0 2015/06/30

DJI S900 User Manual v1.2 2014-12-18

 A2 Quick Start Guide v1.22 2015-05-08 

 Ronin-M User Manual (EN) v1.2 2015-07-01

 E1200 Pro Propulsion Upgrade Kit for S900 User Manual v1.2 2015-08-06

Flight Operations ,Maintenance and Aircraft Manual

Motion Picture and Television Flight Manual

Applicant submits the manual ́s (Flight Operations, Maintenance and Aircraft, Motion Picture 

and Television Flight Manual) as a Confidential document under 14 C.F.R. § 11.35(b) as the 

entire manual contains proprietary information that the applicant has not and will not share 

with others. The manual contains operating conditions and procedures that are not available 

to the public and are protected from release under the Freedom of Information Act 5 U.S.C. § 

552 et. seq.
UASHOT AERIAL FILMWORKS, INC.

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If you have any questions or need additional information, please contact me at (305) 766-2604

or carlosespiga@hotmail.com. 

Thank you, 

Carlos A. Espiga Calderon