### April 16, 2015 Exemption No. 11333 Regulatory Docket No. FAA-2015-0004
Ms. Melinda Sokoloski MSPhotography dba MSAerial 33 Sea Avenue Quincy, MA 02169 Dear Ms. Sokoloski: 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. The Basis for Our Decision By letter dated December 31, 2014, you petitioned the Federal Aviation Administration (FAA) on behalf of MSPhotography dba MSAerial (hereinafter petitioner or operator) for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct aerial photography for the media and advertising industries. 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 existsfor 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 S1000. 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

### 2 consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the S ecretary 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 proceduresfor 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 datacollection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pres ented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial (seeDocket No. FAA

−2014

− 0352), 11109 to Clayco, Inc. (seeDocket No. FAA

−2014

− 0507), 11112 to VDOS Global, LLC (see Docket No. FAA

−2014

− 0382), and 11213 to Aeryon Labs, Inc. (seeDocket 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 signi ficantly greater proporti ons, 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 re questing an exemption, I find that—

x They are similar in all material respects torelief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213; x The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and x A grant of exemption is in the public interest. Our Decision In consideration of the foregoing, I find that a grant of exemption is inthe public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, MSPhotography dba MSAerial 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, MSPhotography dba MSAerial is hereafter referred to as the operator.

### 3 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 S1000 when weighing less than 55 pounds including payl oad. 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 restricti on. 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 PI C 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 en sure 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 betweenthe conditions and limitations in this exemption and the pro cedures 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 revi se its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The

### 4 operator must also present updated and revise d 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 aff ect 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 functi onal 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 f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C 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, vehi cles and structures. PIC qualification flight hours and currency mustbe logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

### 5 (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 nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants 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 rule s (SVFR) are not authorized. 16. The UA may not operate within 5 nautical mile s 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 whenvisibility 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 f light 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 five 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.

### 6 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 tothe 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 es sential 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/contro ller 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.

### 7 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-s cene operation of the UAS; d. Make, model, and serial or N

−Number of UAS to be used; e. Name and certificate number of UAS PI Cs 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 April 30, 2017, unless sooner superseded or rescinded. Sincerely,

/s/ John S. Duncan Director, Flight Standards Service33 Sea A v e , Quincy , MA 

### Docket Management System U.S. Dept. of Tran s portation 1200 New J e rsey Ave ., SE Wa shington, D.C. 20590 

### J, , J,IIJ, ,, ,J,J , J,J,,JJ .. ,,J,,II Addr: 33 

### Sea Ave Quincy, MA, 02169-3135 Ph: + 1 -(857)-204-2448 

### Email: min d i@msaerial.com

VVeb: msaerial. co m



### MSPhoto g raphy, De ce mber 31,2014 Re: Exemption Request Pur s uant To Section 333 of the FAA Reform Act of2012

Dear Sir or Madam, Pursuant to §333 of the FAA Modernization and Reform Act of20 12 (the Reform Act) and 14 C.F.R. Part 11, MSPhotography DBA MSAerial, operator ofSmall U nmann ed Aircraft Systems (sUASs) equippe d to conduct ae ri al pho tography for the media and advertising indestries for pre - planned, cont rolled area, photographic and surveying ser vic es, h ereby applies for an exe mption from the listed Federal Aviation Regulation s (FARs) to allow com m ercia l operation of its sUASs, so lon g as such operations are co nducted within and und er th e co nditions outlined herein or as may be established by th e Fed e ral Aviation Administration (FAA) as requir e d b y §333. MSAerial's current operation of sUASs for co mm e rcial purposes has been halted to comply with rece ntl y e nacted federal aviation regu lations pertaining to sUASs. As des c ribed more fully below, the requested exemption would p ermit the operation of small, unmanned and r elatively in expen s ive multirotor aircraft under cont roll ed co ndition s in airspace that is 1) contained 2) predetermin ed 3) ha s on - s ite sa fety personnel controlling access, and 4) wou ld provide increased safety and e nh ance m ent s to cl ien ts' business operations.

Th e nam e and add ress o f the app licant is: MSPh otog raphy dba MSAerial Attn:Melinda Sokoloski Ph: + l

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- 2448 Email:mindi @ m sae rial.com Address: 33 Sea Ave, Quincy, MA 02169 MSAerial respectfully requests a grant of an exempt i on of the followi ng sec ti ons of Title 14 of the Code o f Federal Regulations:
• 14CPR21;
• 14CPR9l,etseq.;
• 14 CFR 45.23 (b);

### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

• 14 CPR 61.113 (a) & (b);
• 14 CPR 407 (a)(l);


### • 14 CPR 409 (a)(2);


### • 14CFR417(a)&(b). MSAerial also respectfully requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:
• 14 CFR 45.23(b); • 14 CPR Part 21; • 14 CPR 61.113 (a) & (b); 

### • 91.7 (a); 

### • 91.9 (b) (2); 

### • 91.103(b); • 91.109; • 91.119; • 91.12 1 ; • 9l.l5l(a); • 9l.203(a) & (b); • 91.405 (a); • 91.407 (a) (1); 

### • 91.409 (a) (2); • 91.417(a)&(b).
I. The Exten t of Re l ief MSAerial Seeks and the Reason I t Seeks Such Re li ef: 

### MSAerial submits this application in accordance with the R eform Act, 112 P.L. 95 §§331-334, seeking relief from any cu rrently applicable federa l aviation regulations PARs pertaining to UASs (unmanned aircraft systems) and operating to prevent MSAerial contemplated commercial photographic, mapping, and other flight operations within the U.S. national airspace system.

The Reform Act in §332 provides for such integration of civil UASs into our national airspace system as it 

### is in the public's interest to do so. MSAerial's lightweight UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in similar industri es, MSAerial's light duty UASs are ideal recipients of exemption by the intent of the Reform Act. Considerations for relief include a combination of sUAS physical characte ri stics, safety features, and safe practices identiied in §333:
• sUAS weight,
• sUAS overall size,
• sUAS speed over ground,
• sUAS flight zone characteristecs,

- Non

- operation near airports (civilian or military),

- Tightly contro ll ed operation in populated areas, 33 SEA 

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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of201 2

• Operat ion of the VAS by VLOS.

• Coordination by a minimum of 4 persons, three staff members ofMSAerial and one safety official from

the client. Specific co n sideration is outline below.
14 C.F.R. Pa rt 2 1 , Sub part H: A irworthine ss Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural require

ments for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated sVASs, an exemption from Part 2 1 Subpart H meets the requirements of an equivalent leve l of safety under Part 11 and §333 of the Reform Acl. 1l1e Federal Aviation Act (49 V.S.C. §4470 1 (f)) and §333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certif icat e, upon consideration of the size, weight, speed, operational capabilit y, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the VAS operated without an airworthiness certificate, in th e restricted environment and under the conditions proposed will be at least as safe, or safer, than a conve ntional aircraft (fixed wing or rotorcraft) operati n g w ith an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated by MSAerial is less than llkg. with maximal payload consisting of remote sensing instrumentation, carries neither no persons, carries no explosive or flammable materials including combustibl e fuels, and operates exclusively within a secured area. Unlike other civil aircraft, ope rations under this exemption will be tightly controlled and monitored by both the pilot (P I C), 'spotter' role designated to act as both the remote sensing controller and secondary monitor for safety issues, and a technician, which assists in matters related to maintaining the sUAS and also monitors for safety concerns and liasons to the on - site safety officials. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same crite ria demonstrates that there is no intrinsic credible threat to national secu rity posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack of intrinsic exp losive mat erials or flammable liquid fuels, and inability to carry a substantial externa l load.
14 C.F.R. §45 .2 3 (b ). Marking of the Aircraft The regulation requires: When marks include only the Roman capital lette r "N" and the registration number is disp l ayed on limited, restricted or light-sport category aircraft or experime ntal or provisionally certificated aircraft, the operator must also display o n that aircraft near each e ntran ce to the cabin, cockpit, or pilo t 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 sVAS will have no airworthiness certificate, an exemption may be needed as the sVAS will have no entrance to lhe cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the sUA$, two-inch lettering will be impossible. The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a size suitable for the available space.

The equivalent level of safety will be provided by having the sVAS 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 UAS as "Experimental:' The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. Further markings include the use of flashing green LED illumination on the underside of the sUAS frame which stands at contrast against a blue or white sky.
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### Re: Exemption Request Pursuant To Section 333 of the FAA 

### Reform Act of2012

14 C.P. R
. § 61

. 11 3 (a) & 

### (b): Pr ivate Pilo t Pri vil eges an d Limi tation s: Pilot i n Co mm a nd

. §61.113 (a) & 

### (b) limil private pilots to non -commercial operations. Because the sUAS will not carr y a pilot or passe nge rs, th e proposed operations can ac h ieve the equivale n t level of safety of current o p e rations by requ i ring a g rou nd crew member to h ave a p r ivate pUot's license rather than a commercial pil ot's li cense to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance

. The risks associated with the operation of the sUAS are so diminished from Lhe level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).


### 14 C

. P .R. §91. 7( a ) : C ivil aircr aft air worthin ess . The regulati o n requires that no person may operate a civil aircraft unl ess it is in airwo r thy 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 Lhe requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a subset ofwhich are provided in enclosed Supplemental material , an equivalent l evel of safety will be provided.
14 C. P
. R. § 91.9 (b ) (2): C i v il Airc ra ft Fli g ht M a nu al in th e Airc ra ft. §91.9 (b) (2) p rovi des: No person may ope rate a U.S.

- registered civil aircraft

... (2) For which a n Airplane or Ro torcraft Fli ght Manual is not r equire d by §21.5 of th is chapter, u nl ess t he re is availab le in t he aircraft a current approved airp lane or Rotorcraft F li ght Manual, approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configuration has no ability to carry a physical flight manual 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
. § 91.10 3: Prefli g h t ac tion This regulation requires each PIC 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. The PIC will take all actions including reviewing weather , flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Further, we have proprietary manuals created with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered to.
14 C. F.R. § 91.109 : Fli g ht in s truction §91.103 p rovides th at no person may operate a civi l aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully funclioning 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 numb e r 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 33 SEA A VE, QU I NCY, MA02169-3135 M lN DI@MSAERIAL.COM 

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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 speed of the aircraft. Enhancing this safety is the technology inherent in the remote controls utiziling digital communications which is paired to the sUAS making it nearly impossible to unintentionally or intentionally have the control communications interrupted.
1 4 C

. F. R
. §9 1 .1 19: Minimum safe alt it ude s §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) aJiows 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 closely mimics the behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is closer. It will however be operated in a restricted area with securi ty officials tasked with ensuring publi c safety, and where buildings and people will not be exposed to operations without their pre -obtaine d consent and training.

The equiva l ent l evel of safety will be ach i eved given the size, weight, speed of the UAS as well as the location where it is operated. No flight operation will be taken without the permission of the property owner in the case of private property or local officials i the case of public property or private property with public interests. Because of the advance notice to the property owner and participants in the remote sensing activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum llkg ofMSAerial's sUASs proposed herein and the lack of flammable fuel, any risk associated with these operations is far Jess than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- al titud e operations of the sUAS will ensure separation between these small- UAS operations and the operations of conventional aircraft that must comply with §91.119.
14 C.P.R. §9 1.121 Altimeter Settings §91.121 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 equivalen t level of safety wil l be achieved by the operator, confirming the altitude of th e launch site shown on the GPS altitude indicator before flight. The PIC and Technician will also ensure effective pairing with multi ple GPS sources to guarantee accurate detection of height.
14 C.F.R. §9 1 .15 1 (a): Fuel Requir em ents for Flight in VFR Co ndition s §91.15 1 (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 sVAS provides approximately 15 minutes of powered flight in hover mode with out payload. MSAerial's sUAS will not be able to meet the 30 minute reserve requirement in 14 CFR §91.151. Operating the small UAS, in a tightly controlled area where only people and property owners or official rep resentatives who have signed waivers will be allowed, with less than 30 minutes of reserve power, does not engender the type of risks that Section 91.15l(a) was intended to alleviate given the size and speed of the small UAS. MSAerial believes that an equivalent level of safety can be achieved by limiting flights to» 10 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
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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012
10808.

1 4 C.P. R
. §9 1. 2 0 3 (a) & (b): Carryin g C i vil A irc r aft Ce rti fic at i on an d Reg i str a t ion The regula t ion 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 sUAS fully loaded weighs no more than llkg 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 wi ll 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, 9797 A, 9816A, and 10700.
1 4 C.P. R. §9 1. 405 (a); 407 (a) (1); 4 0 9 (a) (2); 417(a) & (b ): Mai nt enan ce Inspecti o n s 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 o r 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. 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. The operator will ensure that the UAS is in working order prior to in itiating 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.

An exemption granted to MSAerial would permit its operation of lightweight, unmanned, remotely controlled, sUASs in a tightly controlled environment with limited airspace. MSAerial utilizes local business' safety officers in specifically determined areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goals. Technical enhancements to current safety controls will allow MSAerial to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being implemented by the FAA and Department of Transportation. Further, MSAerial conducts its operations in compliance with protocols described here in or as otherwise established by the FAA.
II. Co m me rci a l a n d Pu b li c Benefit s We at MSAerial be l ieve that granting this exemption request furthers the public interest by providing safe (by way of an unmanned system) and efficient means to meet technical problems so lvable by elevated data collection instruments. MSAerial's client base are typically small to medium sized business' looking to increase their awareness of structures or landscape on their respective properties through data collection 33 SEA AVE, QUINCY, MA 02169-3135 MINDI@MSAERIAL

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### Re: Exemption R equest Pursuant To Section 333 of the FAA Reform Act of2012 by photographic, videographic or lidar ba sed s urveying. By moving these function s onto sUAS based aircraft, the potential for lo ss of life or property is dimini shed due to th e greater con trol in a small er and sa fer aircraft that hold s no pe rso ns. Second, there are no reactive or combus tibl e materials on board the s UAS an d thus th e potential for fire or explosions is great l y dimi n ished. Third, th e sma ll s i ze and extreme maneuverability of MSA er ials UASs allow the PIC to avo id hazards. Last l y

, due to th e natu re of the remote se nsing instrumentation onboard, the sUAS can maintain quite a safe distan ce between the airc raft and the objec t (s) undergoing scr utiny. A cco rdingly, MSAer ia l's U A

Ss have operated and will co ntinue to operat e at and above current safety leve ls. A

. The costs and ben e fit s of your proposed action t o s o ci ety i n general and s pe ci fi c gr o up s wi thin so ciety 

### As desc ribed above, MSAeri al's past customers have been small to medium bu s in ess seeki ng a remote sensing so lutio n to specific issues b ef ore a large r effort on their par t would com e und e rway. Examp les include constructio n efforts that so ught elevate d photographic image r y of s pecific landforms to minimize cost of e ffort s to develop, a regional park service that wante d to quantify the changing life cycl e of it's flora by way of m eas u r ing leaf health through gradual chlorophyll deplet ion, and a local cities' Dept. of Public Works that sough t to collect images and 3 D st ructural data by way of Lidar sensing en masse of it's bridges to serve as a supp le ment to it's routine repair and planning documentation.

The impact to society, financial an d othe r wise, would be extr emely minimal. Indeed, it's been demons tra ted th at sUASs have th e ability to dra s ti cially increa se th e inf o rmation availible t o policymakers at a frac t ion of the cos t of measurin g this data by terrestrial mean s. One such im pact would b e in convenience to directly proximal and non -esse ntial p ersonne l t h at wou ld be displaced from pub li c or busin ess owned pr operty if it is de emed to be un safe. In this case we relay our needs for a flight zo ne with the requirem ent that it be safe from cas ual in trusions and allow the business time to shift ope rat i ons in o rder to minimize poten tial safety is s ues. This is best performed with the aid of safety personn el that actively steer non -essen ti al pe rsons around th e Aight zone. 1. Th e effect of an e xe m p t ion for MSAerial on th e quali ty of the natu r al and soci al env ironments 

### Utilizing sUASs minimizes the re qu irement for conve ntion al aircraft. This eliminates th e need for an onboard pilot, time consuming adberance to regul ation s s urrounding bookeeping and s ubmis s ion of flight path s to local civi li ar or mil itary airports, and detrimental effects to the e nvi ronment cause d by operating a co mbustib le fuel bas ed, l ar

ge sca le aircraft, with restri ctio ns on the proximity to th e target for remote sensing.
Ill

. F light Capab ili tie s a nd Ch a racteri stics o f MSAeri a l' s UAS s 

### Persuant to 1 12 P.L. 95 §333 ( a), concerns for public safety a re mitigated by th e overall capabilities and characte ristics of the sUA$. 1 

### MSAerial UASs utilizes eight (8) counter-rotating propellers paired oppo s itely to each other for balan ce, co ntrol and stability. The total span of the sUAS is "" 1.2m all owing for s tabl e flight or land ing even with th e sudden o n set of d etrimental env iro nm enta l conditions. The sUAS's have a maximal unit+ payload mass of llkg, including cinematic/photographic or other s urveyi ng equipment. MSAerial's sUAS is desig ned to prim arily hover in pla ce to cap ture photographi c dat a and then operate at less than a 35 knot maximum speed to th e next point of interest. They are capable ofvertical an d horizontal operations but, in practice, is operated only withi n unaided VLOS of the PIC. In addition to the PIC, MSAerial e mplo ys a spotter ( VO S role) and a technician (seco ndary VOS and on-site personnelli aso n ) whi ch are within unaided verbal communication ran ge. These per so nn el a r e suppleme nted by safety offcials provided by the client who are instructed to cordon 'More charac teri stics have been outlined in the enclosed supp lemental materials. 33 

### SEA AvE , QuiN C Y, 

### MA 02169-3135 MIN DI@MSAERIA L.COM + 1- (8 57)- 204

- 2448Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

### off and otherwise minimiz

. e pedestrian access in the flight zone of the client's grounds. ln the event ofloss of visual of the UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r, a ,h) based controls which allows the PIC to utilize one controller axis to recall the VAS to the PIC's position without concern to the cu rr ent heading of the sVAS. In the event of loss of sight of the sUAS into an area co ntaining hazards or possible hazards, the spotter has a heads

- up-display containing 

### a live video feed which can be used to locate the UAS wh il e it maintains it's position in hover mode. The sVAS has demonstrated it's ability to maintain it's position by GPS coordinates in hover mode in "' 25kph wind gusts at rv25 feet representing an extreme environmental condition beyond the range of cond iti ons within the scope for sVAS operation. All ofMSAerial ' s sUASs utilize LiPo (lithium polymer) battery based power sources, decreasing safety r isks from more easily combustible, fuel based, power sources. Flight times generally last between eight (8) 

### to ten (1 

### 0) minutes allowing the staff to work with small flight areas per phase. The maximum flight time without payload is 15 minutes, however practical safe operation l imits this to 10 to g iv e ample time to control the sUAS to a safe landing zone. MSAerial further re stricts fl ight time by not operating its sUASs with less than twenty five percent battery capacity. Further safety management systems in place include a GPS mode that allows MSAerial sVASs to hover in place if communication with the PIC is lost and optionally follow a set of waypoints at a set speed and height to a 'home base' predesignated safe landing zone. In the event of unforseen motor(s) failure, the system will enter into a controlled descent while allowing full use of all VAS flight controls by the PIC. All commands sent via remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's realtime 3 

### dimensional position and compensate rotors control the sUAS regardless of spin velocity. Landing gear is also programmed to deploy based on sensing of range to ground from non -GPS based sources. This assures that if one system is compensate d a safe and successfu l landing can still occur.
I V. Reasons Why an Exemp t ion to MSAeria l W ill Not Adversely Affect Safety Standa r ds 

### MSAerial's contend s that operalion of it's sUASs will not "create a hazard to u sers of the national airspace system or the public." as stated in 112 P.L. 

### 95 §333 

### (b). Given the diminuative size and weight of MSAerial's sUASs, combined with their operation in cordoned off and well-controlled areas, MSAerial's sUASs falls within Congress's contemplated safety zone. MSAerial sUASs have an established safety record bolstered by multi-point preflight checklist, awareness of their s urroundings and intimate knowlege of the behaviour of the sUAS platform in many weather conditions. TI1is safety record and impl emented operational practices demonstrate an awareness of public safety.

MSAerial operations routinely provide a level of safety at least equal to existing ru les , and in nearly every instance, exceeds existing rules. MSAe r ial has worked very closely with the regional vendors and support for thi s unit to create a tightly integrated and highly fault tolerant platform that has been tested throughly by a vendor with a proven record for safety and solid designs.

Though it does not mitigate safety it is of note thal as of Nov 2014 there are few companies that will insure sUAS operations and sUAS based companies. The sUAS of use at MSAerial is one of two models (by current awareness) that qualify for protection aga in st damages or injury. MSAerial attained the maximal level of insurance to rectify accidental damage or injury. MSAerial also co ntinu es to work close l y with this organ i zatio n to identify and mitigate sVAS platform risk due to their expertise in several industries closely related to the aviation and transportation.

MSAerial does not operate its UASs on or near airports and generally has only operated its fleet on private grounds with cordoned off areas or areas under the control of the property owner I 

### client with assistance by safety officials employed by the business. MSAerial determines the areas needed to fulfill the clients ' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS trade and hobby groups and recently codified by relevant FARs. 33 SEA AVE, QUINCY, 

### MA 02169-3135 M I NO I@MSAERIAL.COM +1

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### Re: Exemption Request Pursuanl1o Section 333 ofthe FAA Reform Act of2012
MSAerial sta nd ardized on the fo llowing practices to ensure safe operation of it's UASs:

• Work with on-site personnel to plan the flight goals,

• Work with on-site personnel to restrict access to non -esse ntial p ersons,
• Operation by unaided VLOS operation only,

• Operatio n in phases 10 minutes in length,

• Operation to minimal 25% battery power, • Operation of device to GPS aided readout to 300ft at m axi mum , • Num e rou s pre-p rogrammed fail

- safes that ensure specific b e havior per i ss u e,
• Three m a in roles s uppl e mented by on -s ite safety personnel,

• Empl oy con troll ed life cycle management of components to g uard against multiple failures,

• Preform a sile check day(s) before flight to iden tify potential issues,

• Subscribe to relevant local weather and safety alerts,



### • Expertly choose data collection in stru ment s and accessories lo minimize flight requirements or

expe rti se,

MSAerial has exper ience in sim ilar fields and ha s adapted this expe ri ence in it's use of UASs to increase safety. In co mbin a tion to the ever expanding knowlege repositories from hobbyists and experts alike, M SAeria l is consta ntly evo lvin g it's practice s when th e re is a clear benefit to ope ration s or increas e d safety ele m en t. A

. Summ ary Pursuant to 14 C.F.R. Part 11 , the following summary is provid e d for publication in the Federal Registe r, sho uld it be d eterm in ed that publication is needed:

MSAerial (appli can t) seeks an exe mption from the fo ll ow in g rul es: 1 4 C.F. R. §21, s ubpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03(b); 91.109; 91.119; 91.121; 91.15l(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1); 9 1. 409 (a) (2); 91.409 (a) {2) and 91.417 (a) & (b) to operate comme rcially a small unmanned vehicle {l lkg or less) in elevat ed photographk and rem ote sensing ope r ations. Approval of exemptions allowin g commercial operat i ons of sUASs in the the media industry wilJ e nhan ce safely by reducing r isk associate d with conventional a ircraft ope r at i ons and other means of elevated r e m ote sensing involving persons. The public benefit se r ved by approval of this petitio n i s increased awar e n ess of characteristics of difficult imaging targets. A sUAS weighing fewer than llkg and powered by sea l ed batteries eliminates virtually all ass ociate d risk inherent in operating c onv en tional airc raft in close proximity to buildin gs or persons or otherwise elevating persons to a position they would be able t o collect need ed data.

TI1e o p eratio n of s m all UASs, weighting less than SSlbs., conducted in the str ict conditions outlined above, will provide an eq uival e nt leve l of safety supporting the grant of th e exemptions requested herein , including exempting the app li ca nt from the requirements of Part 2 1 and allowing co mm ercial operations. 33 SEA AvE, QUIN CY , MA 02169

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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012
As id entified and described herein, Melinda Sokoloski, and her company MSPhotography DBA MSAerial, is an experie nced, recognized media services professional in the various photographic industries. Mrs. Sokoloski and her compa ni es have been producing and delivering media and technical so lutions for the media service industry for ten ( I0) years with a spotless safety record.

The FAA has been given the authority to issue the exemption to MSPhotography DBA MSAerial pursuant to the Federal Aviation Act, 85 

### P.L. 726 (1958), 

### and as such, we humbly seek your conside ration and approval of this petition.
PIC VLOS Best,

encl: Sup pl eme nt A: Physical characteristics of UAS encl: Supplement 

### B: F li g ht Operation and Procedures Manual (FOPM) related to operation encl: Supplement C: Flight maps in MSAerial regional base

33 SEA AVE, QUINCY, 

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### Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM)

• All regular and ir r egular operations are noted with timestamps, relevant UAS metrics and co r rective action procedures (CAP) that are performed.

- Note: All irregu l ar behavior have root cause analysis performed before UAS operation is resumed.
VI. Emergen cy Pr oce du re s

• Loss of Remote Signal

- The flight package features an optional e n hanced fail-safe which returns the UAS to the home base waypo int via the same path taken to point of lost signal.

- The UAS will then preform a hover over this waypoint and then a contro ll ed landing.
• Loss of GPS signal

- The system will operate in GPS assisted mode with three (3) satell i tes.

- At loss of th ree (3) GPS satell ites, manual mode can be activated or the flight package can be programmed to preform a controlled landing to the home base waypoint.

- Ground based height ranging is prefo r med by a seperate system and so loss of GPS wi ll not impact controlled landing in a safe manner. • Loss of Engine Power

- In t he event of one (1) (or to two oppositely positioned) rotor or motor failure the system wHl enter into contr olled spin where all controls are trans l ated based on current orientation and will behave as normal operation to the PIC to ensure a safe l anding,

- In the event of multiple rotor or motor failures the flight package can be configured to preform a safe l and ing or attempt operation to home base waypoint.

- Note : Behavior of the landing location is highly dependant on the position and number of rotors/motors that are affected.
• Loss of Ground Contro l Software

- This w ill not affect operation of the flight. The unit will be piloted to a safe l anding area 

### and then l anded so that examination of the link can be made.

Best, Norfolk , SS

. Commonwealth of Massachusetts December**3~ ,**  2014

# ML~~ I On this 31st day of December , 2014, before me, the undersigned Notary Public , personally appeared Melinda Sokoloski , provide to me through satisfactory evidence of identification, wM.ch was her Mass
. Driver's License , to**~-- --------** **-4 ~~e**  person whose name is signed on the preceding document, and acknm..rledged to me that she signed it voluntarily as her free act and deed and for its stated purpose .

# Car~**~ ?Ur~P~**  33 SEA AVE, QUINCY, MA 02169-3135 MINDI@MSAERI AL.COM + 1- (8 57)- 204-2448

### CERTIFICATE OF LIABILITY INSURANCE 

# I OATE (MM I DDIVYYY ) 1120 / 2014 THIS CERTIFICATE IS ISSUED AS A MATTER OF INFOR MATI ON ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND , EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER , AND THE CERTIFICATE HOLDER. IMPORTANT : If the certificate holder Is an ADDITIONAL INSURED , the pollcy(les) must be endorsed

. If SUBROGATION IS WAIVED , subject to the terms and conditions of the policy , certain policies may requ i re an endorsement. A statement on this certificate does not confer rights to the certificate holder In lieu of such endorsement(s)

. PRODUCER CONTACT Lockto n Affin i ty , LLC NAME. : P

. O

. Box 410679 PHONE 

# I 888-202
- 1526 fAX Kansas City , MO 64141-0679 (A/C No
. Exlt: (A/C , No) :: E· M

AIL A ODRESS : INSURER(S ) Af

FOR D ING COVERAGE NAI C INSURER · A : C

e rtai n Underwr»o rs a t lloyd 's, Lo ndon INSURED INSURER · B: MS Photography I NSURER · C : 33 Sea Ave IN S URER · D: Quincy MA 02169 I N S URER·E : IN S URER·F : COVERAGES CERTIFICA'I'E NIIURI'R · REVISION**NUMBER ~**  THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSU E D TO TH E INSURED NAMED ABOVE FOR THE POLICY PERlOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WTTH RESP ECT TO WHICH THIS CERTIF1CATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POUCIES DESCRIBED HEREIN IS SUBJECT TO All THE TERMS, EXCLUSION S AND CONDITIONS OF SUCH POUCIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. INSI\ TYPE OF INSIJRANCI: AOOl $UBR POLICY HUMBER POLICY EFF POLICY EX!' liMITS lTit IHSII Wl/0 (MI>\'00/YY) (MWDD/YY) A GENERAL liABi liTY PP4003590 112112014 l/21/2015 EACtl OCCURRENCE $1,000,000 X COM M ERCIAl. GENERAL UAB I LTTY DAMAGE TO RENTED PREMISES $100,000 !xloccuR (Ea occurr ence) CLAIMS MADE MED EXP (Any one person) $5,000 PERSONAL & ADV INJURY $1 ,000,000 GENERAL AGGREGATE $2,000,000 GEHl AGGREGATE LIMIT APPLIES PER: PROOUCTS • COMP/OP AGG $2,000,000

X POLICY 

# n PRO.JE<T 

# n LOC $ AVTOMOellE l!ABIUTY COKSlNE'O SINGLE UMTT s (EI acddent) ANY 1\IJfO BODILY INJURY (Per person) s 

## - All OWNED AUTOS SCHEDUlED AUTOS BODILY INJURY (Per aaldent) $



## - PROPERTY DAMA GE $ HIRED AUTOS "O" · OWNED AUTOS (Per occident ) 

# -
UMB R E LLA LIAS OCCUR EACH OCCURRENCE $



## - EXCESS LIAS CLAIMS MADE AGGREGATE $ OED I I RETEHTlON s WOIUC£RS COMPENSAllON**~** nAN 

# t l OnM AND EMI'I.OYBtS' liABiliTY TOIItYUMITS /11ft PROPRIETOR/PARTNEIIJE)CECUTlVE Y/N OFFlCER/MEMBER EXCLUDE07 E
. L EAOiACCIDENT $ (MAND

... TORY IN N H} E.L
. DISEASE · EA EMPLOYEE $ II yes, describe under DESCRIPTION OF OPERATIONS belOw E.l

. DISEASE · POLICY LIMIT s H i r ed & Non
-owned Auto li abil i ty Is In c lud ed CERTIF I CATE HOLD E R CAN CELLATIO N Proof of Coverage SHOULD ANY OF THE ASOVE DESCIU8ED POUOES BE CANCELLED BEFORE THE EXI'IRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WlTI1 TNE POLICY PROVISIONS AUTHORIZED REPRESENTATIVE 

# I B

## ~~ ACORD 25 (2010/05) The ACORD name and logo are registered marks of ACORD33 Sea Ave, Quincy, MA
Docket Management System U.S. Dept. of Tran sportation 1200 New Jersey Ave., SE Wa shington, D.C. 20590 1 •• 1.111 ••• I 

### II 1.1.1 .. 11 .... 1 .. 11

S u ppl e m e nt A : Ph ysical C h arac t e ri s t ics of MSAe ri a l's UAS

Dear Sir or Madam, Addr: 33 Sea Ave Qui ncy, MA, 02169-3135 Ph: + 1

- (85 7)- 204- 2448 Email: m i nd i@ msaer i al.com VVeb: msaer1al

. com

MSPhotography, December 31, 2014

Pl ease find in this do c ument specifica tions relat ed to th e UAS subject to co n s id erat ion for Exemption. All specificat ions given by the manufacturer. It is of not e that these s pecification s in so m e in stance s constitute the maximal values discovered by the manuf acturer a nd average d ove r seve r al test units. MSAerial utili zes these metrics when f orming safe and sustain abl e flight operations and in no way do the spec ificati on ext r ema co nt ai ned herein constitute normal MSAerial flight parameters.
I. Ge n era l Ma n ufactur e r D e tails

Specification Manufacturer Model Website Co nt act (P h ) Co nt ac t (Em ) Value D JI $1000 (Spreadi n g Wings ) www.dji.com us.support@dji.com

+1 (818) 235 -0789

### Supplement A : Physical Characteristics of MSAerial's UAS
II
. Physica l Characteris t ics Frame Specification Value Diagonal Wheelbase Frame Arm Length Frame Arm Weight(with Motor, ESC, Propeller) Center F ram e D1ameter Cen t er Frame Weight La ndin g Gear Size 1045mm 386mm 325g 337.5mm 1330g 460mm(L) x Sllmm(W) x 305mm(H)

Specification Motor Spec ification Stator Size KV 

### Max Power Weight Value 41 xl4mm 400rpm/V SOOW

158g

Electronic Speed Controller Specification Value StatorSize 4lxl4mm Working Current 40A Working Voltage 6$ LiPo Signal Frequency 30Hz 450Hz Drive PWM Fr equency 

### 8KHz Weight (with Radiators) 35g

Specification Material Size Weight Propeller Va lue Performance engineered plastic 15 x 5.2inch 13g

Flight Parameters Value TakeoffWeight (with payload) Total Weight (system only) Power 6.0Kg "' ll.OKg 4.2Kg Battery LiPo (6S,10Ab 20Ah,l5C(Min)) 4000W 1500W (@9.5Kg total load) 15min (@15Ah @9.5Kg total load)

- 10 "' +40 

# o c Max Insl. Power Hovering Power Hovering Time Working Temp

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Docket Management System U.S. Dept. ofTransportation 1200 New Je rsey Ave., SE Washington, D.C. 20590 1 •• 1.111 •••• 1.1.1.1 •• 11 .... 1 •• 11 Addr: 33 Sea Ave Quincy, MA, 02169-3135 Ph: + 1 -( 857)-204-2448 Email: mindi@msaeri al.co m



### Vfeb: msaerial.com

MSPhotography , December 31, 20 14 S u pp lement B : S u mmary Sections of Flig h t O peratio n s an d Procedure Ma n ua l ( FOPM )

Dear Sir or Madam, I. Intr o ducti o n This manual describes the notable roles , tasks, and operations perform ed by MS photography/MS Aeria l. The aim i s to d ocument everythi n g that is needed to be done during a mi ssion, so it can act as a reference point for team members.
II. R o les and Respon sibili t i es As much as is possib le, MSAerial staff attempt to have redundancy in expe rli se and s kill se ts related to operat io n s of the VAS

.
P il ot in Co mma n d ( PIC)

• Piloti ng the UAV. TI1is will include:

- Takeoff,

- Normal Flight,

- Flight during eme rge n cy procedur es,

- Landing,
• Assembling the UAV • Performs pre-flight checks of the firmware ,

### Supplement B :Summary Sections of Flight Operations and Procedure Manual (FOPM)

• Performs pre-flight checks of the hardware, • Preforms pre-flight checks of the software. Spotter

• Relays notable flight parameters such as flight times, battery strength, metrics from the UAS. • Primary communication link between pilot and on-site safety personnel, • Will hold physical documents related to current flight, • Preforms pre - flight checks of the data collection equipment, • Monitors ground and greater above

- ground env ironment for safety concerns Techn icia n

• Assembling the UAV, • Preforms pre-flight checks of the hardware, • Performs pre-flight checks of the software, • Secondary comm unication link between pilot and on-site safety personnel, • Relays to the Spotter and records notable flight parameters metrics from the UAS, • Monitors ground and greater above-ground environment for safety concerns Ill

. P re- Fl igh t Ch ec k l is t A

. Bef o r e P owe r App l ie d


### • Check for physical damage and any missing hardware, • Check all electronics present and connected/ check coord connections are tight. • Confirm all batteries charged, • Check all rotors and moving parts for debris that would prevent proper operation. • Check weather patterns the night beforehand. SlOOO 

### should be raised above the ground when testing

landing gear or recalibrating servo travel. • Check data collection equipment for proper operation. • Check data collection equ ipme n t fo r iss ues that wou ld impact safe operat ion of flight package.
B. Afte r Power S o u r c e App l i e d


### • Confirm proper power reading of battery, • Run hardw are based systems check, • Run software based systems check, • Check flight LED array, • Confirm proper radio link to flight controller, • Confirm proper radio link to data collection device co ntr o ll er, • Confi rm secondary controller connection to UAS onboa rd flight controller, • Confirm waypoints and geofences are accurate to current flight, • Confirm desired behavior of emergency i(ifailsafes, • Check with on-site safety personnel for any changes in goals I 

### Oightpath.

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### Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM)
IV. Flight -time Checklist

• Check with on-site safety personnel for a safe flight area for first flight, • Record relevant metrics in flight log, • Check for ground hazards at home-base and rectify, • Confirm 

### > 8 satellite GPS lock, • Confirm initial state of controllers, • Initialize rotors and check for proper operation, • Perform controlled flight to hover mode approximately Sm above ground, • Check landing gear flight mode (up) operation, • Perform controlled mu lti-axis roll procedure to check for proper orchestrated rotor operation, • Perform controlled multi-axis (if applicable) control procedure of data collection package, • Switch controller mode to radial based, check proper operati on to maximum 5m distance to PIC and

return to initial position, • Return UAS to norma l orientation, • Perform controlled flight to hover mode approximately 1m above ground, • Check landing gear landing mode (down) operation, • Land the UAS and check for proper de

- initialization of rotors, • Perform controlled flight to hover mod e approximately 5m above ground, • Check landing gear flight mode (up) operation, • Operate UAS to each waypoint 

### I position until maximum flight time is achieved, • Return UAS to normal orientation, • Perform controlled flight to hover mode approximate l y 1m above ground, • Check landing gear landing mode (down) operation, • Land the UAS and check for proper de-initialization of rotors, • Remove power to the flight package, • Remove power to the data collection package, • Remove power to controllers, • Complete flight log.
V. Standing Procedures

• The Pilot, Spotter, and Technician will be the only MSAerial staff members in the forward flight area. On-site personnel will be with in verbal range and behind MSAerial staff. • The maximum power used to control the device is soft limited to 75% in order to maintain power in

reserve for unforeseen conditions, • Flight time is limited to 15 minutes and goal s will be planned in phases to be accomplished during this

time. • Flight time is limited to reserving 25% battery power, • Flight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 300ft,

whichever is less. • Flight time is limited to operation in safe environmental conditions, • Flight staff will maintain proximity so as to be in clear and unaided verbal range, • The PIC will announce all movements to MSAerial and on-site staff so that non- PIC staff members can

identify possible safety concerns before operation of the UAS to the next waypoint or position,
33 SEA AvE, QuiNCY , MA 02169-3135 MIND I @MS AERIAL. C 0 M 

### + 1

- (8 57)

- 204-2448MS Photography / MS Aeria l

Operations Area (Attached VFR Chart with Coordinates) 

## 41° 59 ' 13" N 

# I 70° 57' 54" 

# wACORD 0 

## CERTIFICATE OF AIRCRAFT INSURANCE 

# I DATE (MM/00/YYYYI**~** 10/ 6/201 4 THIS CERTIF I CATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO R I GHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFF I RMAT I VELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW

. THIS CERT I FICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSU IN G INSURER ( $) , AUTHORIZED REPRESENTATIVE OR PRODUCER , AND THE CERTIFICATE HOLDER. IMPORTANT : If the certificate holder is an ADDITIONA L INSURED , the po l icy(ies) must be endorsed. If SUBROGATION IS WAIVED , subject to the terms and conditions of the policy , certa i n policies may require an endorsement. A s t atement on this certificate does not c onfer rights to the certif i cate holder i n lieu of such endorsement (s)

. PR ODUCER CONTACT Trans p ort Ris k NAME :**Tran ~ort**  Ri sk 12 42**B~** T i mber Driv e, S u ite 5 I :::Jg N Jo. Extl : 720

. 2 08

. 08 44 

### I**r..e~** Nol: 720 208.0845 Co nife r , 0 8043 3**~~t~~SS:** I**~~~~~~~~** I D 

### *' INS U R ER (S I AFFORD I NG COV ERAGE % NA IC. I NS U RED I N SU R E R A : St arN e t I ns u ra n ce Company 100 4004 5 MS Aeri a l an d MS P h ot o g raph y I N SU RER B : 33 Se a Avenue Quincy MA 0 2169 I NS U RERC: I NSUR E R D : INSUR E R E : INSU R E R F : THIS IS T O CERT I FY T HAT THE POLICIES OF I NSURANCE LISTED B E LOW HAVE BEEN I SSUED TO THE INSURED NAMED ABOVE FOR TH E POLICY PERIOD I NDICATED. NOTWITHSTANDING ANY REQU I REMEN T , T E RM OR CONDIT I ON OF ANY CON T RAC T OR OTHER DOCUM E NT WITH R E SPECT TO WH I CH T HIS CERTIFICATE MAY B E I SSU E D OR MAY PERTAIN, THE INSURANCE AFFORDED BY T HE POLIC IE S DESCRIBED HEREIN I S SUBJECT TO AL L THE TERMS , E X

C L US I ONS AND CONDITIONS OF SUCH POL I C I ES

. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PA I D CLAIMS

. POLICY INFORMATI ON CERTIFICATE NUMBER : 219106 14

PLEASUR E & BUS I COMMERCIAL AIRPLA NE HELICO PTER HU L L & liABILITY

Y E A R ! MAK E 2014 DJ I TER R ITORY : AIRCRAFT COVERAGES I liABiliTY ONLY 

## I M O DEL ls 1 ooo 

# I S E R I AL N U M BER TRM76 7 REVISION NUMBER :
QUOTA SHAR E 

# I RE GI STRA T ION NUMBER N /A

I N S URER LETTER 

# I POl i CY N U MB E R A BA
- 14
- 05
- 00 2 10 

# I E FF EC TIVE DAT E 

# IEXPIRATION DATE 5/2 1 /201 4 5/21/20 1 5 ADD I TIONAL INS U RED? (YIN) 

# I S U BROGATION WAIVED? (YIN) y N COVERAGE OPTIONS LIM IT APP L IE S T O LI M IT AP P L I ES TO $ $ AIRCRAFT HULL t-- t-- $**~** $ 1 ,000.000 EAOCC $ EAPER AIRCRAFT LIABILITY f- $ E XC LU D E D EAPASS $ AGGR I NCLUDING CREW MEDICAL PAYME N TS t-- $ 5 , 000 EA PER I EXCLUDING CREW CO VE RA GE C O DE D E SCRIPT I ON OP T I O N S LIM I T A P P L I ES TO LIM IT APP LI ES TO $ $



### - - $ $ $ $ I-- 

### r- $ $ 1- f- $ $ $ $ DESCRIPTION OF OPERATIONS I REMARKS (Attach ACORD 101 Additional Remarks Schedule i f more space is re quired) It is agreed t hat t h e Certificate Holder is inc l uded as an Additiona l Insured u n der t h e Aircraft Liabilit y Coverages , but only to th e e xt ent of l i a b il ity v i ca ri o u sl y impose d up o n th e Certificate Ho l d e r solely as the res u lt of an act or om i ssion of t he Named Insured or i ts emp l oyees in con n ection w i th th e Named I nsu red's A i rcraft o p eration s , s u bject to all pol i cy t e r ms , c on d i ti on s and exclus i ons. Th e Compa n y has made t he provis i on to give t he Certificate Hol d e r prompt not i ce of ca n cellatio n o f an y po l ic y above

. But, the c ompany assumes no responsibili ty f or fa i l u re to provide such notice. Th i s Certificate does not change in any way the actual cove r<!9._ej:1_rovided Qy_**he _ll_** **ol ~**  CERTIFICATE HOLDER CANCELLATION SHOU L D ANY OF THE A BOV E DE SCR I BED POL I CIES BE C AN C EL L ED BEFORE**Br d~ewater**  Stat e U n ive rs i ty THE EXP I RA TION DAT E THEREO F, NOTICE WILL BE DELI VERE D I N 1 3 1 u mmer St reet ACCORDANCE WITH TH E P OLICY P ROV I SIONS

. B ri dgewate r MA 0 2325 AUT H OR I ZED REPR E S E NTATIVE

Diane Beane 

# (b

. w
© 2009 ACORD CORPORATION. All nghts re served

. ACORD 21 ( 2009/12) Th e ACORD name and log o are registered marks of ACORD C ERT NO .: 219106 14 Diane Beane 10/6/2014 3: 20:59 P M (PDT) Page l of leLiInvoice:#H599494Tuesday,29Aprial2014SOLDTO:M5PhotographyMelindaSogoloski33SeaAveQuincy,02169Massachusetts,UnitedStatesOrder#:H599494ProductsOJIS1000PREMIUM,A2ANDZENMUSE50MKIIICOMBOSN#0200020888FUTABA10JH2.4GHeliR3008SBS/FHSSMode2SN#840313003PLU15-160006PULSELIPO16000mAh6S1P22.2V15CInvoiceHeliOirect730EasternAve.,Umt096EastBoston,MA02148USA877-HOX-HELI781-443-6185j_jDELIVERTO:--------1____+-fMsPhotographyI!MelindaSogoloskiIf33SeaAveIIQuincy,02169I_t.f--jt---1---,Massachusetts,UnitedStatesI·-t----'IIDateofOrder:04/29/2014SKUQtyShipDJI-S1000PA51FUTK92011PLU15-1600061Paymentmethod:CreditcardQtyPrice(EX)80$6,560.00$349.98$0.00SubTotal:ShippingCost:Total:TotalPaid:TotalRefunded:Total(Inc)$6,560.00$349.98$0.00$0.00$6,_?09.98$7,519.96$609.98I

# FAA UAS Civil COA Request Any information that is provided is bound by the Freedom of Information Act (FOIA) and may be releasable

. This requ i res compliance to FOIA and consent to the release of your information. If you do not consent to the release of your informati on , you must contact us for further guidance

. For more information , please visit http ://www

. foia

. gov/

. 

### Date I 

# J}X

. :ifl= Jo t/ 333 Exemption # or Federal Register Docket# 

## Proponent Information Contact Name !Melinda Sokoloski Company Name I MS Photography DBA MS Aerial Street Address 1 133 Sea Ave Street Address 2 City lauincy State IMA Zip Code ._ 1 0_21_6_9

_____ __, Phone Number IB57
- 204-2448 E-mail Address lmindi@msaerial.com


## Aircraft System Aircraft Type I UAV Aircraft Registration lsN # o2aoo2oaaa 

### Performance Characterist i cs Climb Rate (Feet/Minute) 1350 feet per m i nute Descent Rate (Feet/Minute) 1250 / 350 per minute

### Turn Rate 

# la o introversive and a 3 °

### ~ Approach Speed !maximum thrust of

### 2.~ (Degrees/Second) Cruise Max 130
-45 mph Min !Hover Speed Gross Takeoff Weight 111 kg Max Launch/Recovery ! A utomated Return to

### ~ 

## Operational Information Location

Alt i tude Description of Operation Bridgewater State University ( 131 Summer Street , Bridgewater, MA 02324) Possib l y other privately owned locations within the New Eng l and**L~'"''"'** ll 

### 1200 Feet Distance from nearest Town/City Melinda Sokoloski along with a pilot and an observer have been asked to film a few moments of B roll in a tightly controlled enviroment. On the Campus of Br i dgewater State university. There wi ll be a few days of film i ng . Projected film i ng for other companies would take place in similar condit i ons , meaning saftey and education would be on the forefront. This includes knowijng regulations and weather conditions

. Operations Area (Attach VFR Chart with Coordinates) Class of Airspace 

# D A D Under Mode C Veil 

# D D llJ G Flight Conditions llJ VFR 

# D IFR


## Air Traffic Communication

O VHF Transmitter 

## 0 Yes 

## 0 No 

# D B (Requires FAA HQ approval) 

# o c D E D G 

### (With an operational ATC Tower)

Receiver 

# 0 Yes 

## 0 No Guard (Emergency Frequency) 

## 0 Yes 

# 0 No

### [ZJ UHF



## Procedures Transmitter @ Yes 0N o

Lost Link Procedures 1. How long to activate LL procedure Receiver @ Yes 

## 0 No

lmmed i tely after line of sight may be compromised

. There are 2 spotters at all**times~** 

### 3. Lost Link Route f I tell it to or the signal is dropped it will fly back to where it is told

. I preprogram the altitude it iiJ 5. Flight Termination Point Never beyond line of s i ght and below 450 '

Lost Communication Procedures 1. Between Pilot and Air Traffic Control Guard (Emergency Frequency) @ Yes 

## 0 No

2. LL A lt itude 

# 1450 feet

4. Lost Link Point Beyond line of sight. We do not fly beyond l i ne of sight.

The MSPhotography/MS Aerial team would never be within in the range of airfields or restricted airspace

. The coordinates are : 41 ° 59' 25" N 

### I 70 ° 58' 32" W

2. Between Pilot and Observer Procedurally we would not allow an observer to be any farther than speaking d i stance

. It can be said that fundamentall y , the primary role of the observer is to maintain communication w ith the pilot as a first dire c tive

..

## Observer Line of Sight of Observer 

### [lJ Yes 

# D Other Observer Location Time of Day Transponder !Close enough to be w i thin speaking

### distance**~** @ Day @ Yes 

# 0 No 

# 0 N/A 

## 0 Night 

## 0 Both Mode C 

# D

Pl ease return comp l eted form to 9wAJVw 1 15wUASOrganizat i on@faa .gov.

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