May 21, 2015

Exemption No. 11651

Regulatory Docket No. FAA–2015–0664

Mr. Jon Budreski

Co-Founder

AirShark LLC

29 Pleasant Street

Montpelier, VT 05602

Dear Mr. Budreski:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 13, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of AirShark LLC (hereinafter petitioner or operator) for an exemption. The exemption 

would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct 

infrastructure inspection such as solar farms, wind turbines, and construction projects.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom Vision+.
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The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, AirShark LLC is granted an exemption from 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), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, AirShark LLC is hereafter referred to as the operator.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

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

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.

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 
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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 questions 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.

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

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

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 

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 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.

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 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

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.
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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; 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.

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.

If this exemption permits operations 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.
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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.

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.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
AirShark LLC Petition for Exemption – Section 333

Title 14 CFR 111.81 (FAA)

March 13 2015

US Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Electronically submitted via regulations.gov from:

AirShark

29 Pleasant Street, Montpelier VT 05602

jon@airshark.io 802 233 9330

www.airshark.io

AirShark is requesting a petition for exemption (Section 333) to fly small UAS for

the purpose of infrastructure inspection work such as solar farms, wind turbines

and construction projects. AirShark is focusing on supporting energy and

infrastructure since it’s a critical part of our nation’s economic success. Using UAS,

we can help contractors and managers inspect aging infrastructure, at reduced risk

while providing a new level of information not previously accessible. In addition,

noise and air pollution is less than alternatives. We are seeking exemption from

several CFR’s as noted below that remain burdensome to AirShark doing business

and growing. We believe and will provide supporting documentation that AirShark

can provide a level of safety greater than or equal to the rules we are seeking

exemption from. This request is in the public interest, our interest and our local

communities interest here in rural Vermont and New England. We have completed

due diligence and have noticed profound potential impacts from safety to economic

impacts to information quality.

Aircraft

AirShark is currently in the process of registering (2) DJI Phantom Vision+ UAS.

The Specific sections of Title 14 of the Code of Federal Regulations from which

AirShark requests exemption: 14 CFR : Part 21 Subpart H; 61.113(a)&(b); 91.121;

91.151; 91.405(a); 91.407(a) (1); 91.409(a)(1) and (2); 91.417(a)&(b)

For Each CFR – I have created a response addressing :

1) Rule is burdensome to AirShark...
2) AirShark can provide a level of safety greater than or equal to the rule we are

seeking exemption to. Explain...

3) This request is in the public interest (AirShark / Public / Community)

RE: Exemption Request Section 333 of FAA Reform Act of F.A.R.s. and 14 CFR

Part 11.

14 CFR 21 H – AirWorthiness Certificates sets forth requirements for procurement

of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size,

weight and operational area of my, UAS permits exemption from Part 21 because

my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations.

AirShark UAS meet or exceed each of the elements. Subpart H 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 AirShark, 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 USC

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 SUAS. In all cases, an analysis of these criteria

demonstrates that the SUAS 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 operating with an airworthiness certificate

without the restrictions and conditions proposed.

61.113 (a)(b) Private Pilot Privileges and Limits

These regulations limit private pilots to non‐commercial operations. Because the

SUAS will not carry a pilot or passengers; due to the SUAS’s size, weight, speed, and

operational capabilities; and since operations will occur in tightly controlled and

limited airspace, the proposed operations can achieve the equivalent level of safety

of current operations that currently require a commercial pilot’s license while still

benefiting the public good.

91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes

electronic global positioning systems with a barometric sensor. 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 SUAS

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 by confirming the altitude of the launch site shown on the GPS altitude

indicator before flight.

91.151(a) prescribes that no person may begin a flight in an airplane under visual

flight rules (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;

This regulation 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 SUAS provides

approximately 25 minutes of powered flight. That would make it impossible to meet

the 30 minute reserve requirement.

Given the limitations on the SUAS’s flight area and the location of its

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

daylight VFR conditions is reasonable. An equivalent level of safety can be achieved by

limiting flights to 25 minutes or 25% of battery power (whichever occurs first). This

restriction would be more than adequate to return the SUAS to its planned landing

zone from anywhere in its limited operating area.

Maintenance Inspections

91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have

that aircraft inspected as prescribed in subpart E of the same part and shall,

between required inspections, except as provided in paragraph (c) of the same

section, have discrepancies repaired as prescribed in part 43 of the chapter.

91.407 (a)(1); prohibits, in pertinent part, any person from operating an aircraft that

has undergone maintenance, preventive maintenance, rebuilding, or alteration

unless it has been approved for return to service by a person authorized under §

43.7 of the same chapter.

91.409 (a)(1) and (2); prescribes that no person may operate any aircraft unless,

within the preceding 12 calendar months, it has had an inspection for the issuance

of an airworthiness certificate in accordance with part 21 of this chapter.

91.417 (a)(b)
The above‐cited Regulations require, amongst other things, aircraft owners and

operators to “have [the] 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. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will

not, therefore, apply to out UAS. However, as a safety precaution AirShark shall

inspect all UAS before and after each flight. (see attachment for user manual).

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 sections and Part

43 apply only to aircraft with an airworthiness certificate, these sections will not

apply. Maintenance will be accomplished by the operator pursuant to the Phantom

user manual and guide. An equivalent level of safety will be achieved because these

small SUASs are very limited in size, will carry a small payload, and operate only in

restricted areas for limited periods of time. If mechanical issues arise, the SUAS can

land immediately and will be operating from no higher than 400 feet AGL. Further,

the operator will ensure that the SUAS is in working order prior to initiating flight

and perform maintenance as required. Moreover, the operator is the person most

familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety.

UAS Equipment

AirShark plans to utilize a DJI Phantom2 Vision+. AirShark PIC will operate the UAS

in a safe manner fully aware of the NAS minimizing risk on both the ground and air.

With full VLOS and redundant systems on board as well as GPS the UAS will be

carefully guided to inspect infrastructure and energy installations. AirShark shall

officially register the UAS with the FAA before any flights commence. See the

attached documents for design and operation characteristics. Checklists will be

amended as need to create an even higher level of safety. For instance, battery data

will be aggregated with each flight log using in house software.

UAS are less than 50lbs and fly less than 30 MPH and under 400ft. Flights will be

ceased and UAS will return to home at 25% battery power. A Return to Home

feature is available and can be used should connectivity or power issues arise.

Procedures

Preflight checklists will be followed (see attached user guide). Maintenance and

repairs will be logged and batteries will be logged as well. (attached user manual).

Radio Frequencies
2.4 and 5.8 Radio Spectrum Frequencies will be used to communicate and provide

video feeds from the UAS to a ground station. All frequencies and usage will comply

with existing FCC bands. In addition, ground spotters (Visual Observers) will be

equipped with a 462 MHz radios complying with part 15 FCC and be in

communication at all times with PIC.

Pilot in Command (PIC) and Visual Observer Rules/Goals

AirShark’s (PIC) shall hold a valid FAA issued Private Pilot’s license (SEL) and valid

class II or III medical at the time of flights. Jon Budreski currently holds

approximately 140 hours of flight time S.E.L. and has 25 hrs. of UAS time. PIC will

have had at least 3 takeoffs and 3 landings in the preceding 90 days.

­ Pilot will be “re‐certified” via flight review before May 2015 (S.E.L.) with

(3

rd Class Medical)

o Total Hrs. 140

o Total UAS Hrs. 25

o License / Certificate #_FF‐1687500

A Visual Observer will understand basic UAS operational characteristics, safety

protocols and have site understanding to help in successful missions. The visual

observer will primarily be for keeping an extra set of eyes on the sky while noting

proximity to ground hazards including people and property. Prompt notification via

radio will be key for quick communication.

Operation of UAS / Privacy / Public Safety

AirShark is aiming to work with customers in the construction, energy and

infrastructure space in primarily Northern New England to start. AirShark will

inspect solar panels, wind turbines, construction sites and bridges (for example).

Our nation's infrastructure requires tremendous amounts of maintenance and

check‐ups and is aging. We feel that using UAS will complement existing

technologies and equipment that is being used today but also provide a greater level

of safety than alternatives.

AirShark shall conduct operations in VFR VMC weather during daylight hours

outside of Class B airspace and outside of 5 mile area of Class D/C airport unless

approved in the COA. In addition, flight altitudes will be no higher than 400FT AGL.

All operations will be conducted line of sight (LOS). We are aware a clearance in the

form of a COA will be needed to conduct any operations outside of Class G airspace

from the local controlling authority (Tower or FSDO). In addition any needed

NOTAMs will be completed 48 hrs before flights.

Potential hazards will be outlined in initial safety briefings and clearly avoided.

Hazards could include power lines, tall structures and mechanized moving

equipment. “See and Avoid” rules using VLOS will be followed to minimize NAS
impacts. Further, permissions must be granted or approved over private or public

lands where UAS is operating.

COA will be secured before flights as required by latest FAA guidance. TFRs,

NOTAMS, weather etc will all be recognized / utilized as applicable.

Further:

• All operations will avoid congested or populated areas.

• Notifications will be made in advance to nearby or legal entities such as local police,

fire.

• The operator will file a NOTAM for each flight as required by FAA / FSDO Office.

• A pre­job brief will be developed and conducted and must verify control of the flight

area, including the absence of members of the public in the flight area.

Checklists will guide operators during pre‐flight, flight, and post flight operations

and reduce risk. Safety risk assessment checklists will be developed and updated

yearly.

Since the areas being photographed or filmed will be on primarily private property,

accessed only after given written and/or oral consent by the property owner(s), and

clear of all people, except for the PIC and the PIC's helper(s), approval of this

application presents no risk to the public privacy.

Reference to similar Petitions:

Astreus Aerial, petition – Petition No. 0352, Grant No. 11062.

Alan Purwin, petition ‐p#0786

Singer’s Creations, petition ‐ p#0915

Supporting Documents Etc.

o Phantom User Manual

o Phantom Users Manual (1‐3)

o Phantom Guide

o Phantom Training Guide

o AMA Safety Code
We are prepared to modify or amend any part of this request to satisfy the need for

an equivalent level of safety. We look forward to working with your office. Please

contact me at any time if you require additional information or clarification.

Respectfully,

Jon Budreski, Co Founder – AirShark LLC

29 Pleasant St

Montpelier VT 05602