Regional Construction,LLC Rock Brogan 504 Dillon St. St. Albans, WestVirginia 25177 rockbrogan@msn.com

December 10, 2015

U. S. DepartmentofTransportation Docket ManagementSystem 1200 NewJersey Ave., SE Washington, DC 20590 

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Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulationsfrom 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) 

### &(b); 91.7 (a);91.9 (b) (2);91.103(b); 91.1 09;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

DearSiror Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Regional Construction,LLC, developer and operator ofSmall Unmanned Aircraft Systems {"sUASs") equipped to conduct aerial electronic data collection c and aerial photographyforthe commercial video industry, herebyappliesfor an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established bythe FAA as required by Section 333.

As described more fully below, the requested exemption would permitthe operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the aerial filming and monitoring industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the SecretaryofTransportation's (the FAA Administrator's) responsibilities to

.. "

...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act.

cAerial Data Collectionn which includes any remote sensing and measuring by an instrument(s)aboard the UA. Examples include imagery (photography, video, infrared, etc.), electrqnic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), oranyother gathering ofdata by instruments aboard the UA



### 1The nameand address ofthe applicant is: Regional Construction,LLC Rock Brogan Ph: 304-722-2717 Email: rockbrogan@msn.com Address: 504 Dillon St., St. Albans; WestVirginia, 25177
Regulationsfrom which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR409 (a) (2) 14 CFR417 (a) 

### & (b)

This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This lawdirects the Secretary ofTransportation to considerwhether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users ofthe NAS orthe public or pose athreatto national security in light ofthefollowing:

• The sUAS's size, weight, speed, and operational capability;
• Operation ofthe sUAS in close proximityto airports and populated areas

.. Operation ofthe sUAS within visual line ofsight ofthe operator.

Reform Act§ 333 (a). Lastly, ifthe Secretary determinesthatsuch vehicles "may operate safely in the national airspace system, the Secretaryshall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." ld. §333(c) (emphasis added) A

AApplicant interprets this provision to placethe dutyon the Administratorto not only process applications for .exemptions undersection 333, butforthe Administratorto craftconditions forthe safe operation ofthe sUAS, ifit should be determined thatthe conditions setforth herein do notfulfill the statutory requirements forapproval.


### 2The Federal Aviation Act expressly grants the FAAthe authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, that includes sUASs, from the requirementthat all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed undersubsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administratorfinds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Regional Construction,LLC's sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. Theywill operate only in line ofsight and will operate only within the sterile area described in the Flight Safety Manual, attached as Exhibit 8 (hereinafter "the Manual"). Such operations will insure thatthe sUAS will "not create a hazard to users ofthe national airspace system orthe public." 8

Given the small size ofthe sUASs involved and the restricted sterile environment within which theywill operate, the applicantfalls squarely within that zone ofsafety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASsto commence immediately. Also due to the size ofthe sUASs and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents
no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing sUASsfor commercial video operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applieant respectfully requests that the FAA grantthe requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein applyto civil aircraftthat have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent oreven higher level of safety to operations underthe current regulatory structure because the proposed operations represent a safety enhancementto the already safe commercial video filming operations conducted with conventional aircraft.

8 Reform Act Section 333 (b).

3These limitations and conditions towhich Regional Construction,LLC agrees to be bound when conducting commercial operations under an F

### M issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/or observer. 3. Maximum total flight timefor each operational flight will be20 minutes. Flights will be terminated at 25% battery power reserve should that occur priorto the 20 minute limit. 4. Flights will be operated at an altitude ofno more than 400feet AGL or. not more than 200 feet above an elevated platformfrom which filming is planned.

5. Minimum crewfor each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Camera Operator.

6. sUAS pilotwill be an FAA licensed airman with at leasta sport or recreational certificate and a valid driver's license. The observerwill also hold a valid driver's license.

7. sUAS Pilot will be Pilot in Command (PIC). Ifa pilot certificate holderotherthan the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. theAerial Coordinator). that person can also bedesignated as PIC.

8. The sUAS will onlyoperate within a confined "SterileArea" as defined in the Manual. Section C ofthe Manual requires the establishment ofa "Safety Perimeter" fortheflight operations area.

9. A briefing will be conducted in regard to the planned sUAS operations priorto each day's production activities. It will be mandatorythat all personnel whowill be performing duties within the boundaries ofthe safety perimeter be presentforthis briefing.

10. The operatorwill file a F

### M Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office.

11. The operatorwill obtain the consent ofall persons involved in the filming and ensurethat only consenting personswill be allowed within 100 feet oftheflight operation, and this .radius may be reduced to 30 feet based upon an equivalent level ofsafetydetermination, as required by Section F ofthe Manual. With the advanced permission ofthe relevant FSDO, operations at closer range can be approved. (See Section B in the Manual Appendix B)

12. The operatorwill submit a written Plan ofActivities to the local FSDOwith jurisdiction over the area ofproposed filming. The three-day notification may bewaived with the concurrence of the FSDO.

13. Pilot and observerwill have been trained in operation ofsUAS generally and received upto-date information on the particular sUAS to be operated as required.

14. Observerand pilotwill atall times be able to communicate byvoice. 15. Written and/ororal permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local lawenforcement, fire, orother appropriate governmental agencies.

17. Ifthe sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a pre-determined location within the Security Perimeterand land.

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

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



### 4Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

### (f)) and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraftfrom the requirement foran airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular sUAS. In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityfor the area ofoperation as is nowdonewith conventional filming. The FAAwill have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed ofoperation, location of operation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. 

### § 45.23 (b). Marking ofthe Aircraft

The regulation requires:

When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAV, two-inch lettering will be

5impossible. The word "Experimental" will be placed on the fuselage in compliance with 

### §45.29 (f). The equivalent level ofsafety will be provided by having the sUAV marked on its fuselage as required by 

### §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe sUAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 

### A.

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations by requiring the PIC operating the aircraftto have a private pilot's license ratherthan a commercial pilot's licenseto operatethis small sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with
no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as setforth in the Manual. The level ofsafety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot asthe PIC exceedsthe present level ofsafety achieved by 

### 14 C.F.R. §61.113 (a) & (b).

14C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person mayoperate a civil aircraft unless it is in airworthy

. condition. As there will be no airworthiness certificate issued forthe aircraft, should this

exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofsafety check lists priorto each flight, as setforth in Sections C & D, an equivalent level ofsafety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 

### 91.9 (b) (2) provides: No person mayoperate a U.S.-registered civil aircraft

... {2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unlessthere is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof.

6The sUAS, given its size and configuration has no ability or place to carry such a flight manual
on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level ofsafetywill be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A,9565,9565B, 10167, 10167A, 10602,32827,and 10700.

14 C.F.R. § 91.103(b): Preflight action

This regulation requires each pilot in command to take certain actions beforeflight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafety will be provided as set forth in the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fullyfunctioning dual controls.

sUASs and remotely piloted aircraft, bytheir design do not have fullyfunctional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions forflight training without fully functional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided bythe fact that neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. Safe simulation and practice flight will be carried out in controlled environments. All simulations will be carried out on a computer using the drone controls. Any practice flying will take place in a safe environment, with no risk to human life below.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicoptercomplies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes upto 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 setforth herein the sUAS will never operate at higherthan 400 AGL. It will however be operated in a



### 7restricted area with safety perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safetywill be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in thefilming activity, all affected individuals will be aware ofthe planned flight operations as setforth in the Manual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the lowaltitude operations ofthe sUAS will ensure separation between these smaii-UAS operations and the operations of conventional aircraft that must complywith Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport oran 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 bythe operator, pursuant to the Manual and Safety Checklist, confirming the altitude ofthe 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 "aflight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel tofly to the first point of intended landing, and, assuming normal cruising speed- (1) Du_ring the day, to fly afterthatfor at least 30 minutes; or (2) At night, tofly afterthat for at least 45 minutes."

The battery powering the sUAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertimeframe for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS, in a tightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small sUAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility forwhich the exemption will be granted.



### 8Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 20 minutes or25% of battery power whichever happensfirst. This restriction would be morethan adequate to return the sUAS to its planned landing zone from anywhere in its limited operating
area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

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 thefollowing:
(1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the sUAS.

An equivalent level ofsafetywill be achieved by keeping these documents at the ground control pointwhere the pilotflying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother 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 ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis 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 tothe flight manual and operating handbook as referenced in the Manuai.(See Sections B, D and G) An equivalent level ofsafety will be achieved because these small sUASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the sUAS can land



### 9immediately and will be operating from no higherthan 400feetAGL. As provided in the Manual, the operatorwill ensure that the sUAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in
an airworthy condition to providethe equivalent level ofsafety.

Pursuantto 14 C.F.R. Part 11, thefollowing summary is provided for publication in the Federal Register, should it be determined that publication is needed:
Applicant seeks an exemption from thefollowing rules: 14 C.F.R. §21, subpart H; 14 C.F.R45.23(b);14 C.F.R. §§ 61.113( a) 

### &(b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) 

### &(b) to operate commercially a small unmanned vehicle (551bs or less) in motion picture and television operations.
Approval ofexemptions allowing commercial operations ofsUASs in thefilm industry will enhance safety by reducing risk. Conventional film operations, usingjetor piston power aircraft, operate at extremely low altitudesjustfeet from the subject being filmed and in extreme proximity to people and structures; and presentthe risks associated with vehicles that weigh in the neighborhood of4,0001bs., carrying large amounts ofjetA orotherfuel. Such aircraft mustfly to and from thefilm location. In contrast, a sUAS weighing fewerthan 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack of combustiblefuel carried on board. The sUAS is carried tothe film set and notflown. The sUAS will carry no passengers orcrew and, therefore, will not expose them tothe risks associated with manned aircraftflights.

The operation ofsmall sUASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicantfrom the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close tothe ground, and in a sterile environment and, as a result, are farsaferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.



### sUASs Details: See Appendix C

Safety Features:
• Emergency "Return*To*Home"

o At the beginning ofeach flight a home point is set. This home point is set in accordance with the manual to allowfor a safetakeoffand return. Should the pilot's control lose signal with the sUAS

10Privacy or manually request a return, the sUAS will return to the starting point.

All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place.

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

- provides more than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant's sUAS in the commercial video production industry pursuant to the Manual appended hereto.

Sincerely

Regional Construction,LLC Rock Brogan

11

# Appendix A: No-Fly Zones

Regional Construction,LLC's Pilots will not be operating within 5 nautical miles ofany airport.

As a safety precaution, Regional Construction,LLC's pilots will not be operating within 5 nautical miles ofany airport similarto the permission granted in Exemption No. 11153

- Regulatory Docket No. FAA20140519, page 25, "20. The UA maynotoperate within 5 nautical miles ofan airportreference pointas denotedon

### a currentFAA-publishedaeronauticalchart unless 

## a letterofagreement with thatairports managementis obtained, andthe operation is conductedin accordance with 

## a NOTAMas requiredbythe operators GOA. The letterof agreement with the airportmanagementmustbe made available to the Administratorupon request."

As well as in Exemption No. 11195- Regulatory Docket No. FAA20140884, page 12, "19. The UA may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letterofagreementwith that airports management is obtained, and the operation is conducted in accordance with a Notice to Airmen (NOT AM), as required by the operators Certificate ofWaiver orAuthorization (COA). The letterofagreementwith the airport management mustbe made available to the Administrator upon request."

Regional Construction,LLC requests the sameflexibility as exemptions 11153 and 11195for acquiring agreementwith the airports' management should operationsfall within 5 nautical miles ofan airport.

12

### Appendix 8: Safety Manual

A. Maintenance
a. The sUAS must be inspected by a factory trained technician every 10 flight hours. All maintenance records will be maintained for inspectjon as setforth ln Section B. b. Ifany maintenance is undergone, the sUAS must pass a flighttestwith both a pilot and a manufacturertrained technician beforeflight. B. Record Keeping
a. A digital record will be keptfor all flights, flighttimes, and maintenance records. C. Securing Flight Site
a. FSDO Submissions 

### i. The sUAS operatorwill file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office. b. Safety Parameter 

### i. Beforefilming occurs, a 100 yard perimeterfrom the planned flight path will be identified in orderto set a "sterile" environmentforthe operation. 1. Regional Construction,LLC must obtain written ororal permission from all landowners in sterile environment. 2. 48 hours beforefilming, all residents or businesses within 100 yards ofthe filming will be notified with printed flyers.
a. Flyers will contain date offlight, time offlight, and contact information. 3. Streets and sidewalks that cross into the sterile environment will be marked with 'Warning Lowflying Aircraft

- Stay Back 150ft" signs towarn the public. 4. At all times Regional Construction,LLC will carry $1mm in general liability insurance in case ofany damage to property or persons within the safety parameter c. Identify potential obstacles i. Before each flight, an inventorywill be taken for all potential obstacles that must be avoided while in flight. Including: 1. Powerlines 2. Cell Phone Towers 3. Trees 4. Flocks ofbirds that maytake flight 5. Heavilytraveled roadways 6. Utility wires 7. Elevated structures 8. At least 5 nautical milesfrom the nearest airport or helipad.



### 13

### D. Pre*FiightChecklist
a. Take Off Location/"Home" i. The sUAS will mark its take off location as a safe area to return to should the sUAS lose signal with the control or ifthe pilot signals the craft to return to its "home" location. 1. Take off location will be in an area with a 25ft radius with no obstructions, maintaining said radius vertically 200ft. 2. The sUAS will take off and land in the same location. 3. GPS Altimeterwill be marked as 0' elevation b. FlightCanceling Events i. All flights will be cancelled for a minimum of2 hours ifanyofthe below
occur: 1. Police activity in the area 2. Lowflying aircraft in the area 3. Medical/News Helicopters active in the area 4. Wind exceeding 10 mph 5. Any emergency requiring emergency services occurs within the sterile environment 6. PIC is unable to complete flight without losing visual ofthe sUAS 7. Any precipitation 8. Heavy bird presence in the area that could cause a mid-air collision. 9. Any defects ordamage found during preflight exam c. Physical Inspection i. Before each flight the sUAS will be checked to ensure that it is safe for flight. 1. Batteryvoltage will be checked to ensure it is >75% 2. Blades will be inspected to ensurethey are tightened and free of damage 3. Camera mount and gimbal will be inspected to ensure it is fully attached and operating. 4. sUAS will be checked for any damagethat may have taken place in transit. 5. The sUAS will be tested at a low altitude to ensure all controls are responding correctly. 6. Battery checked fordamagethat could affect its charge ii. Ifany party ofthe inspecting shows a damaged part orparts, the sUAS is deemed non-usable and must be inspected by a factory trained technician./ d. Post Flight Inspections/Checklist i. After each flight, the the sUAS will be thoroughly inspected for any damage that occurred in flight. 1. Body inspected forany damage 2. Blades visually checked foranydamage atall



### 14

### 3. Battery checked for damage 

### E. Mid-AirSafety Protocol
a. Max Speed 

### i. Ascent 1. 10m/s ii. Descent 

### 1. 4m/s iii. Flight Speed 1. The sUAS is neverto exceed 1Om/s 

### b. Altitude 

### i. The sUAS is neverto exceed 400ft


### c. Emergency 

### i. If it appears thatthe sUAS, any property or humans are at risk, the sUAS will be grounded immediatelyto a safe location. 

### d. Sight 

### i. The pilot must keep the sUAS within eyesight at all times unassisted by anytechnology. 

### F. Participation by non-pilot staff
a. All staff involved in the production orfilming using the sUAS will consent to maintain a safe distance ofat least 30 

### ft during the filming. 

### G. Pilot/SpotterTraining
a. Before flying, both the Pilot and spotterwill receive updated information on the sUAS and its 

### firmware. 

### i. The controller allows for a simulatortraining, both the pilot and spotterare allowed to run through the simulatortraining

15

### Appendix C UAS#1: DJI

See AppendixD forusermanual Model: Inspire 1

UAS#2: DJI


# ii \\\\\\



### ,,....



# - - 

# - SeeAppendixE forusermanual Model: Phantom 3 Professional



### 16