Leveridge Systems INC

John D Allen.

Ph: 417 414 4963

Email: john.allen@leveridgesystems.com

Address: 5954 South Mccann Ave, Springfield MO 65804

January 10th 2016.

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 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); 91.109;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).

Dear Sir or Madam:

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

Act) and 14 C.F.R. Part 11, Leveridge Systems INC a registered Missouri Corporation, and 

owned subsidiaries are a developer and operator of Small Unmanned Aircraft Systems	(“sUASs”)	

equipped	to	conduct	aerial electronic data collection, facilities inspections and aerial

Photography, hereby applies for an exemption from the listed Federal	Aviation	Regulations	

(“FARs”)	to	allow	commercial	operation	of	its	sUASs,	so	long	as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.

As described more fully below, the requested exemption would permit the operation of

small, unmanned and relatively inexpensive sUAS under very 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 of this exemption would thereby enhance safety

and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s) responsibilities	to

“...establish	requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national

airspace	system.”	Section 333(c) of the Reform Act.

c Aerial	Data	Collection”	which	includes	any	remote	sensing	and	measuring	by	an	instrument(s) aboard	the

UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments

aboard the UA
The name and address of the applicant is:

Leveridge Systems INC

Ph: 417 414 4963

Registered CEO/Owner is John D Allen.

Email: john.allen@leveridgesystems.com

Address: 5954 South Mccann Ave, Springfield MO 65804

Regulations from 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)

14 C.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 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in	passing	Section

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems may operate safely in the national

airspace system (NAS) before completion of the rulemaking required under Section 332 of the

Reform Act. In making this determination, the Secretary is required to determine which types of

UASs do not create a hazard to users of the NAS or the public or pose a threat to national

security in light of the following:

•	The	UAS’s	size,	weight,	speed,	and	operational	capability;

•	Operation of the UAS in close proximity to airports and populated

•	Operation	of	the	UAS	within	visual	line	of	sight	of	the	operator.

Reform	Act	§	333	(a).	Lastly,	if	the	Secretary	determines	that	such	vehicles	“may	operate

safely in the national airspace system, the Secretary shall establish requirements for the safe

operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	§333(c)	(emphasis	added)	A

_______________________________________________________________________

A Applicant interprets this provision to place the duty on the Administrator to not only process applications for

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it

should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority by its terms includes exempting civil aircraft, as the term is defined under

§40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the

Administrator finds 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).

Leveridge Systems INC’s	 sUASs	are	rotorcraft, weighting 55 or fewer 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. They will 

operate only in line of sight in accordance with the Manufacturer’s safe operations manual; Such

operations	will	insure	that	the sUAS	will	“not	create	a	hazard	to	users	of	the	national	

airspace	system”

Given the small size of the sUASs involved and the restricted sterile environment within which

they will operate, the applicant falls squarely within that zone of safety (an equivalent level of

safety) in which Congress envisioned that the FAA must, by exemption, allow commercial

operations of UASs to commence immediately. Also due to the size of the UASs and the

restricted areas in which the relevant sUASs will operate, approval of the application presents

no national security issue. 

Given the clear direction in Section 333 of the 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 UASs for 

commercial video operations, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the

requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that

have the characteristics and that operate with the limitations listed herein. These limitations

provide for at least an equivalent or even higher level of safety to operations under the current

regulatory structure because the proposed operations represent a safety enhancement to the

already safe commercial video filming operations conducted with conventional aircraft.

__________________________________________________________________________

B Reform Act Section 333 (b).
These limitations and conditions to which Leveridge Systems INC agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 200 feet AGL or, not more than 200

feet above an elevated platform from which operation is planned.

**As of March 23rd 2015 It is kindly accepted that Blanket COA be issued.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer.

6. sUAS pilot will be an FAA licensed airman with at least a sport or recreational certificate

and a valid	driver’s	license.	The	observer	will	also	hold	a	valid	driver’s	license.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS

Pilot, who possess the necessary PIC qualifications, is also present (i.e. the Aerial

Coordinator), that person can also be designated as PIC.

8.	The	UAS	will	only	operate	within	a	confined	“Sterile	Area”	 that	of	a	“Security	Perimeter”	

for	the	flight	operations area to ensure very safe operations.

9.	A	briefing	will	be	conducted	in	regard	to	the	planned	sUAS	operations	prior	to	each	day’s

commercial activities. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the

requested exemption, with the appropriate Flight Standards District Office. FSDO.

11. The operator will obtain the consent of all persons involved in the filming and ensure that

only consenting persons will be allowed within 100 feet of the flight operation, and this radius

may be reduced to 30 feet based upon an equivalent level of safety determination, as required

by Section F of the Manual. With the advanced permission of the relevant FSDO, operations at

closer range can be approved. (See Section B in the Manual Appendix B)

12. The operator will submit a written Plan of Activities to the FSDO three days before the

proposed commercial activities.

13. Pilot and observer will have been trained in operation of UAS generally and received uptodate information on the particular UAS to be operated as required.

14. Observer and pilot will at all times be able to communicate by voice.

15. Written and/or oral 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 law enforcement, fire, or other appropriate governmental agencies.

17. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to

return to a pre-determined location within the Security Perimeter and land.

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

emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

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

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

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement

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

capability, and proximity to airports and populated areas of the particular UAS. In all cases, an

analysis of these criteria demonstrates that the UAS operated without an airworthiness

certificate, in the restricted environment and under the conditions proposed will be at least as

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The sUAS 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 area as set out in the Manual. Unlike other civil aircraft, operations under this

exemption will be tightly controlled and monitored by both the operator, pursuant to the

Manual’s	requirements,	and	under	the	requirements	and	in	compliance	with	local	public	

safety requirements, to provide security for the area.

The FAA will have advance notice of all operations. These safety enhancements, which

already apply to civil aircraft operated in connection with aerial photography or production 

operations and will provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part

21, Subpart H. 

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

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

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

substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the 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 more than 6 inches high, the words "limited,"

"restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the

word	“Experimental”	can	be	placed.	Given	the	size	of	the	sUAV,	two-inch lettering will be

impossible.	The	word	“Experimental”	will	be	placed	on	the	fuselage	in	compliance	with	

§45.29(f).
The equivalent level of safety 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	of	the	UAS	as	“Experimental.”	The	FAA	has	issued	the	following

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

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 UAS

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of

safety of current operations by requiring the	PIC	operating	the	aircraft	to	have	a	private	pilot’s

license	rather	than	a	commercial	pilot’s	license	to	operate	this	small	UAS.	Unlike	a

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with

no living thing on board. The area of operation is controlled and restricted, and all flights are

planned and coordinated in advance as set forth in the Manual. The level of safety 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 of the sUAS are so diminished from the level of risk associated with commercial

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as

requested with a private pilot as the PIC exceeds the present level of safety achieved by 14

C.F.R. §61.113 (a) & (b). 14 C.F.R. §91.7(a): Civil aircraft airworthiness.

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

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

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the Manual for maintenance

and use of safety check lists prior to each flight, as set forth in Sections C & D, an equivalent

level of safety 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 may operate a U.S.-registered	civil	aircraft	...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this

chapter, unless there is available in the aircraft a current approved airplane or

Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof.

The 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 of safety will 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: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure

the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the

aircraft an exemption will be needed. An equivalent level of safety 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 for flight instruction unless that aircraft has fully functioning dual

controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls.

Flight control is accomplished through the use of a control box that communicates with the

aircraft via radio communications. The FAA has approved exemptions for flight training without

fully functional dual controls for a number of aircraft and for flight instruction in experimental

aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the

fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed

of the 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 of civil aircraft. Section 91.119 (d)

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

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

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

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

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

herein the UAS will never operate at higher than 400 AGL. It will however be operated in a

restricted area with security perimeter, where buildings and people will not be exposed to

operations without their pre-obtained consent.
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 as set forth in the Manual. 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 the movie industry. In addition, the 

lowaltitude operations of the sUAS will ensure separation between these small-UAS operations

and the operations of conventional aircraft that must comply with 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	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, pursuant to the Manual and Safety Checklist,

confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

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

Section	91.151	(a)	prohibits	an	individual	from	beginning	“a	flight	in	an	airplane	under	VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day,

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the 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	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 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 UAS, in a tightly controlled area where

only people and property owners or official representatives who have signed waivers will be

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS.

Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the

exemption will be granted.
Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20

minutes or 25% of battery power whichever happens first. This restriction would be more than

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 the following:

(1) An appropriate and current airworthiness certificate. . . .

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

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

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

to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs 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 sUAS.

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

control point where the pilot flying 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 of other exceptions includes Exemption Nos. 9565, 9665, 9789,

9789A, 9797, 9797A, 9816A, and 10700.

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

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

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

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

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

43.

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

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

operator pursuant to the flight manual and operating handbook as referenced in the

Manual.(See Sections B, D and G) An equivalent level of safety will be achieved because

these small UASs are very limited in size and will carry a small payload and operate only in

restricted areas for limited periods of time. If mechanical issues arise the UAS can land

immediately and will be operating from no higher than 400 feet AGL. 
As provided in the Manual, the operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

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.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(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 (55lbs or less) in motion picture operations.

Approval of exemptions allowing commercial operations of sUASs in the Video and Inspections

industry will enhance safety by reducing risk. Conventional film or observations operations, using 

jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being 

filmed and in extreme proximity to people and structures; and present the risks associated with 

vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel 

(140 gallons for jet helicopters shown below). Such aircraft must fly to and from the location.

In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all

of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is

carried to the location and not flown. The sUAS will carry no passengers or crew and, therefore,

will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions

requested herein, including exempting the applicant from the requirements of Part 21 and

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the

ground, and in a sterile environment and, as a result, are far safer than conventional operations

conducted with turbine helicopters operating in close proximity to the ground and people.

UASs Details: 

Safety Features:

● Emergency	“Return-To-Home”

○ At the beginning of each flight a home point is set. This home

point is set in accordance with the manual to allow for a safe takeoff

and	return.	Should	the	pilot’s	control	lose	signal	with	the	UAS

or manually request a return, the UAS will return to the starting

point.
Privacy

All	flights	will	occur	over	private	or	controlled	access	property	with	the	property	owner’s	

prior consent and knowledge. 

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 for the grant

of the requested exemptions allowing commercial operation of applicant’s	UAS	in	the

commercial video production and service industry.

Sincerely

John D Allen. CEO/President. Leveridge Systems INC.

January	10th 2016.
Appendix A: No-Fly Zones

Leveridge Systems INC’s	Pilots	will	not	be operating within 5 nautical miles of any airport.

As a safety precaution, Leveridge Systems INC’s	pilots	will	not	be operating within 5 nautical 

miles of ANY airport similar to the permission granted in Exemption No. 11153 - Regulatory 

Docket No.

FAA20140519, page 25, "20. The UA may not operate within 5 nautical miles of an airport

reference point as denoted on a current FAA-published aeronautical chart unless a letter of

agreement with that airports management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operators COA. The letter of agreement with the

airport management must be made available to the Administrator upon request."

As well as in Exemption No. 11195 - Regulatory Docket No. FAA20140884, page 12, "19. The

UA may not operate within 5 nautical miles of an airport reference point as denoted on a

current FAA-published aeronautical chart unless a letter of agreement with that airports

management is obtained, and the operation is conducted in accordance with a Notice to

Airmen (NOTAM), as required by the operators Certificate of Waiver or Authorization (COA).

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

Administrator upon request."

Leveridge Systems INC requests the same flexibility as exemptions 11153 and 11195 for 

acquiring agreement with the airports' management should operations fall within 5 nautical miles 

of an airport.
Appendix B: Safety Manual

A. Maintenance

a. The UAS must be inspected by a factory trained technician every 10 flight hours.

All maintenance records will be maintained for inspection as set forth in Section

B.

b. If any maintenance is undergone, the UAS must pass a flight test with both a pilot

and a manufacturer trained technician before flight.

B. Record Keeping

a. A digital record will be kept for all flights, flight times, and maintenance records.

C. Securing Flight Site

a. FSDO Submissions

i. The UAS operator will file a FAA Form 7711-1, or its equivalent, as

modified in light of the requested exemption, with the appropriate Flight

Standards District Office.

b. Safety Parameter

i. Before filming occurs, a 100 yard perimeter from the planned flight path

will	be	identified	in	order	to	set	a	“sterile”	environment	for	the operation.

1. Leveridge Systems INC must obtain written or oral permission from all

landowners in sterile environment.

2. 48 hours before filming, all residents or businesses within 100

yards of the operations will be notified with printed flyers.

a. Flyers will contain date of flight, time of flight, and contact

information.

3. Streets and sidewalks that cross into the sterile environment will

be	marked	with	“Warning	Low	flying	Aircraft	- Stay	Back	150ft”

signs to warn the public.

4. At all times Leveridge Systems INC will carry $1mm in general liability

insurance in case of any damage to property or persons within the

safety parameter

c. Identify potential obstacles

i. Before each flight, an inventory will be taken for all potential obstacles

that must be avoided while in flight. Including:

1. Powerlines

2. Cell Phone Towers

3. Trees

4. Flocks of birds that may take flight

5. Heavily traveled roadways

6. Utility wires

7. Elevated structures

8. At least 5 nautical miles from the nearest airport or helipad.

D. Pre-Flight Checklist

a. Take	Off	Location/	“Home”
i. The UAS will mark its take off location as a safe area to return to should

the UAS lose signal with the control or if the 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 UAS will take off and land in the same location.

3. GPS	Altimeter	will	be	marked	as	0’	elevation

b. Flight Canceling Events

i. All flights will be cancelled for a minimum of 2 hours if any of the below

occur:

1. Police activity in the area

2. Low flying 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 of the UAS

7. Any precipitation

8. Heavy bird presence in the area that could cause a mid-air

collision.

9. Any defects or damage found during preflight exam

c. Physical Inspection

i. Before each flight the UAS will be checked to ensure that it is safe for

flight.

1. Battery voltage will be checked to ensure it is >75%

2. Blades will be inspected to ensure they are tightened and free of

damage

3. Camera mount and gimbal will be inspected to ensure it is fully

attached and operating.

4. UAS will be checked for any damage that may have taken place in

transit.

5. The UAS will be tested at a low altitude to ensure all controls are

responding correctly.

6. Battery checked for damage that could affect its charge

ii. If any party of the inspecting shows a damaged part or parts, the UAS is

deemed non-usable and must be inspected by a factory trained

technician./

d. Post Flight Inspections/Checklist

i. After each flight, the the UAS will be thoroughly inspected for any damage

that occurred in flight.

1. Body inspected for any damage

2. Blades visually checked for any damage at all

3. Battery checked for damage

E. Mid-Air Safety Protocol
a. Max Speed

i. Accent

1. 10m/s

ii. Decent

1. 4m/s

iii. Flight Speed

1. The UAS is never to exceed 10m/s

b. Altitude

i. The UAS is never to exceed 400ft

c. Emergency

i. If it appears that the UAS, any property or humans are at risk, the UAS

will be grounded immediately to a safe location.

d. Sight

i. The pilot must keep the UAS within eyesight at all times unassisted by

any technology.

F. Participation by non-pilot staff

a. All staff involved in the production or filming using the UAS will consent to

maintain a safe distance of at least 30 ft during the filming.

G. Pilot/Spotter Training

a. Before flying, both the Pilot and spotter will receive updated information on the

UAS and its firmware.

i. The controller allows for a simulator training, both the pilot and spotter are

allowed to run through the simulator training
Appendix C

UAS #1: DJI

Model: Phantom III Professional