Exemption No. 12092 

Regulatory Docket No. FAA–2015–0729

Mrs. Adele Scholl 

Mr. Jeffrey Scholl 

GravityShots.com, Inc. 

172 Lidstrom Road 

Whitefish, Montana 59937

c: 406-253-9048 

f: 866-333-4157 

adele@gravityshots.com

8/3/2015

Conditions set forth in Docket No. FAA-2015-0729 have not changed since Exemption No. 

12092 was granted 7/20/2015.

Purpose in this Addendum

A. Adding FreeFly Alta as an additional sUAV that GravityShots.com, Inc. operates, 

which qualifies for approval. Weighing under 55 pounds including payload, not 

exceeding 87 knots (100 miles per hour), N Number assignment and registration.

B. Submitting GravityShots.com, Inc. Motion Picture and Television Operations Manual 

(MPTOM) for the purpose of approval for closed-set motion picture and television 

filming.

A. FreeFly Alta – N998GS, Serial Number: ALTA627

( See Appendix 1 – Alta User Manual & Appendix 2 – Alta Starter Guide, Appendix 3 – 8050-1

Appendix 4 – 8050-2 Appendix 5 - 8050-88)

First Flight 7/10/2015 – Total Flight Time: 23 hours

Freefly Systems engaged the community of aerial cinematographers and logged thousands of 

flight hours to develop a completely new way to fly. From the Synapse Flight Controller to 

seamless MōVI integration, ALTA gives filmmakers the power to tell their stories from the sky.

Synapse - Intelligent Flight Controller

The Freefly Synapse flight control system represents a new level of control, precision and 

reliability for unmanned aerial systems. The system combines high quality sensors with 
proprietary control algorithms to allow users to execute complex flight patterns with ease. It 

features an integrated on screen display, high-bandwidth position control, live graphing, dual 

receivers, and has been tested for years by the industry's best pilots.

Data Logging

High speed data logging allows user analysis of critical flight data.

Motion Picture and Television Operations Manual (MPTOP)

A. Pilot/Operator Organization:

Mr. Jeffrey Brian Scholl (PIC)

172 Lidstrom Road, Whitefish, Montana 59937

406-253-9048 (Mrs. Adele Scholl, Visual Observer)

adele@gravityshots.com

B. Distribution and Revision.

MPTOP created 8/3/2015 can be updated in writing with a revision number, date and 

signature, added as an addendum.

C. Persons Authorized.

Section 91.119(c) is waived only with respect to those participating persons, vehicles, 

and structures directly involved in the performance of the actual filming. The operations 

manual will include procedures to ensure that no persons are allowed within 500 feet of 

the area except those consenting to be involved and necessary for the filming 

production. This provision may be reduced to no less than 200 feet if an equivalent level 

of safety can be achieved and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s (ASI) 

evaluation of the filming production area to note terrain features, obstructions, 

buildings, etc. Such barriers may protect nonparticipating persons (e.g., observers, the 

public, or news media) from debris in the event of an accident.

D. Area of Operations.

United States of America and Worldwide

E. Plan of Activities.

A plan of activities will be filed three (3) days in advance of filming, this will be 

submitted to the local Flight Standards District Offices (FSDO) having jurisdiction over the 

location of filming. The three (3) day notification may be waived if the PIC should contact the 

FSDO and explain why the notification is not applicable. 

Local FSDO is located 2725 Skyway Drive, Helena, Montana 59602 (406) 449-5270. 

1) Dates and times for all flights.

2) Name and phone number of person responsible for the filming production event.

3) Name and phone number of person responsible for the aircraft.
4) Make, model, and serial or N-number of aircraft to be used and type of airworthiness 

certificate, including CAT.

5) Name and certificate number of pilots involved in the filming production event, 

including any notation of external load endorsements or aerobatic competency, if 

required.

6) A statement that the waiver holder 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 from the waiver 

holder.

7) Signature of waiver holder or representative.

8) 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 minimum altitudes 

essential to accomplish the operation.

F. Permission to Operate.

All flight operations will receive permission to operate the registered UAVs at less than 

500 feet from persons, private land owners, vessels, vehicles and structures. (See Appendix 6 -

Permission to Operate Form)

This includes but is not limited to:

(1) Property owners

(2) Law enforcement officials (if required at location)

(3) Fire department officials (if required at location)

(4) Local, State and Federal government (if required at location)

(5) Air traffic control (if required at location)

G. Security.

Security will be set in place on location, by the PIC and VO, and carried throughout the 

entire crew on location. If the security set in place is breached by an unauthorized personal, 

the PIC will land the UAV and re-secure the location.

H. Briefing of Pilot/Production Personnel.

Before flight operations occur, the PIC and VO will conduct a briefing of all parties on 

location. The briefing will cover the following topics:

1) Authorization for motion picture and television certificate of waiver and the attached 

special provisions,

2) Operations manual,

3) Plan of activities,

4) Aircraft parking and starting,

5) Taxi procedures,

6) Radio communications,
7) Takeoff procedures,

8) Aviation activities to be conducted during the filming production event,

9) Approach and landing procedures,

10) Recall procedures,

11) Emergency procedures,

12) Risks to participating personnel, and

13) How to control nonparticipating persons.

I. Certification/Airworthiness.

As granted in Exemption No. 12092, The FAA granted relief from 14 CFR, part 21, 

certification procedures for products and parts, Subpart H- Airworthiness Certificates. The 

UAVs granted the relief in this exemption will be the only aircrafts that will be used in filming.

J. Pilot Personnel—Minimum Requirements.

GravityShots.com, Inc. PIC, Jeffrey B. Scholl meets these requirements listed below:

1) A current U.S. Commercial pilot certificate with ratings appropriate to the CAT, class, 

and type (if applicable) of aircraft to be used under the terms of the waiver.

2) At least 500 hours logged as the PIC and at least 20 hours logged as the PIC in the 

aircraft type.

3) A minimum of 100 hours in the CAT and class of aircraft to be used.

4) A minimum of 5 hours in the make and model aircraft to be used under the waiver.

5) In the event that the 1,500-foot minimum standard contained in § 91.303(e) is to be 

waived, the pilot performing aerobatic maneuvers must hold FAA Form 8710-7,

Statement of Acrobatic Competency, to perform the operations.

6) In the event the operation to be conducted contains elements of an external-load 

operation, whether fixed-wing or rotary-wing operations, pilots used in the operation 

shall be qualified. This qualification may be obtained through a knowledge test (which 

may be oral or written) or skill. The inspector or another company pilot approved by the 

geographically responsible FSDO who is qualified to carry loads externally will give the 

test(s) which are similar to part 133 requirements and cover the following subjects:

a) Steps to be taken before starting operations, including a survey of the flight area.

b) Proper method of loading, rigging, or attaching the external-load.

c) Aircraft performance capabilities under motion picture operating procedures and 

the Aircraft Flight Manual (AFM).

d) Proper instructions for flight and ground crew personnel.

e) AFM, pilot’s operating handbook (POH), or a Rotorcraft-Load Combination Flight 

Manual (RLCFM) and limitations, if appropriate.

K. Communications.
GravityShots.com, Inc. PIC and VO will create and provide all crew members with a flight 

plan. Either verbally or via radio communications will keep all crew abreast of the procedures.

L. Accident Notification.

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

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

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

National Transportation Safety Board (NTSB) per instructions contained on the NTSB web site: 

www.ntsb.gov.

M. Recall/Stop Procedures.

The PIC and VO via oral, visual or radio communications will keep all crew members 

abreast of any safety and/or stop procedures as they arise.

N. Aerobatic Competency.

If Aerobatics Competency Form FAA Form 8710-7, is necessary for filming purposes in 

the product. The appropriate forms will be filed.

Appendix Table of Contents: 

1. Alta User Manual – Attachment1-FFAUM.pdf

2. Alta Starter Guide – Attachment2-FFASG.pdf

3. Alta FAA Aircraft Registration Documentation: AC Form 8050-1 - Attachment3-8050-1-

Alta.png

4. Alta FAA Aircraft Bill of Sale: AC Form 8050-2 - Attachment4-8050-2.png

5. Alta Affidavit of Ownership For Amateur-Built Aircraft: AC Form 8050-22 - Attachment4-

8050-22-Alta.png

6. Permission to Operate Form - Attachment6-Permission.pdf