UASHOT AERIAL FILMWORKS, INC.



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# UASHOT Aerial Filmworks **, Inc** 1545 Euclid Avenue Apt 6C Miami Beach ,FL 33139 carlosespiga@hotmail.com Tel. (305)766

- 2604

U nited States Department of Transportation July 12, 2015 Docket Ma nagement 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 establi shed 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, Aeria**  **l 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, photograp hy 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 inc luding 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 S 900

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 Fil mworks, 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 45pou nds, 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, w ill be flown at all times during dayl ight 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 t o 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 d esigned to increase altitude 20 meters or 60 feet upon loss of signal between the ground co ntroller held by the pilot and the aircraft itself. Upon reaching the higher altitude (a safety fea ture to avoid people, trees and buildings), the UAS will return to its original take

- off point o f 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 co mputer know where it is located on Earth. The UAS also has a Flytrex black box system installed which tracks every flight so if aUASHOT AERIAL FILMWORKS, INC.



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loss of link to the aircraft from the controller ever occurs, then th e pilot can follow and retrieve the UAS when it lands. Additional details concerning lost

- lin k 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 2 01 4.12 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 p ayload: 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 Propel ler 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) Charger DJI approved charger Dual Users Capability Master

- an d

- Slave control Battery 6000 mAh LiPo 2S Max Mobile Device Width 170mm Charger Model 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 2015/06/30UASHOT 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 °CUASHOT 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 struct ure 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 E12 00 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 recei ve 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, t he E1200 Pro’s integrated ESC, motor, and propeller are designed as a single unit that can be installe d quickly and easily on the arm of any compat ible 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 advanc ed ultra

- carbon

-fiber composite, provides the rigidity of a metal propeller with lower inertial momentum. The classic folding design prot ects the propellers while making transportation and use as simple and efficient as ever. A built

- in centrifugal fan pro vides 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 enha nces 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.



### 7 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 restricti ve because the handles bar ar e 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 we ight 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

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- 08 Ronin

- M User Manual (EN) v1.2 2015

-07

-01 E1200 Pro Propulsion Upgrade Kit for S900 User Manual v1.2 2015

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**All UAS will be landed with 20% of battery or 5minutes minimum whichever occur** **s before.**  **All remote controllers compl y**  **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 profe ssional 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 te levision 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 EQUI VALENT 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 th e 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 w eight 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 91.11 9, not allowed to fly less than 500 feet AGL. UAS on the other hand are best when flown bet ween 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 si x pounds would not be nearly as hazardous. Additionally, a regular helicopter is normally larger th an 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 manne d helicopter just based on size alone. In addition, the UAS can be operated for substantially l ess costs than a regular manned helicopter. The public is significantly served by reducing the cost of videography via UAS aircraft.

In reference to fil ming 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 surroundin g 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 aer ial 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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Additi onally, 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 script ed closed

- set environments and utility company’s high towers and electric wire in spections 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 m aterials 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 F light 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 40 0 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 verb ally 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 perfor m the duties required of the VO. The PIC is responsible:UASHOT AERIAL FILMWORKS, INC.



### 11 • 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 w ith 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 P IC to exercise effective control of the UA to prevent the UA from creating a collisio n 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 U AS 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 preceden ce 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 a nd 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 co nducting 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.



### 12 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 ope ration of the UAS, the aircraft will be prohibited from operat ing until the necessary mainten ance has been performed and the UAS is found to be in a condition for safe flight. The Ground Contro l Station, if utilized, will be included in the preflight inspection. All maintenance and alterati ons will be properly docume nted in the aircraft records. Any UAS that has undergone maintenance or alterations t hat affect the UAS operation or flight characteristics (e.g. replacement of a flight critical compo nent) will undergo a functional test flight in accordance with the opera tor’s manual. The PIC w ho 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 ins pection 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 th e 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 C olumbia, 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 n ot 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 d edicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flightUASHOT AERIAL FILMWORKS, INC.



### 13 operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in acc ordance 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 mod el 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 operat e 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 FAA

published 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 enforcemen t 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 hom e 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 (considerin g 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.



### 14 21. Air Traffic Organization (ATO) Certificate o f 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 CO A. 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 la rge 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 oper ated 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 5 00 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; Regarding distance from non

- participating persons, t he operator will ensure that no persons are allowed within 500 feet of the area ex cept 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 h as 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, buildin gs, safety barriers, etc. Such barriers may protect non

participating persons (e.g. observers, the public, news me dia) 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.



### 15 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 operat ion 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.g ov. F or 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 moti on 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 noti fication 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 exe mption; 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 t he 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 repres entative; 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 con ducted 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.



### 16 Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the U AS 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 Sub part 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 wit hout 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 restricti ons 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 ope ration 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 altitude s 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 e xemption 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 se t 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 th ese 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 consentin g 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 operati on 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. E quivalent 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 f lown closer than 500 feetUASHOT 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. Addition ally, prior to each operation, UASHOT flight crew will cond uct 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 p osts 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 depart ure.” 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, confir ming 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 co nditions 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 co nditions 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 sig ned waivers will be allowed. Applicant believesUASHOT 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 perti**  **nent 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 airworthin ess 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. i ncluding 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 exc eptions 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 ma intain 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 U AS can land immediately and will be operating from no higher than 400 feet AGL. The operatorUASHOT 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 p erform 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 metho ds, 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 Guid elines 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 S 900 User Manual v1.2 2014

- 12

- 18 A2 Qu ick 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 pu blic 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 (3 05 ) 766

- 260 4 or carlosespiga@hotmail.com

.

Thank you, Carlos A. Espiga Cald eron