July 31, 2015

Exemption No. 12270 Regulatory Docket No. FAA

– 20 15

– 2138

Mr. Nick Gruber President ReelSkies 5341 West Chanceler Court Lincoln, NE 68521
Dear Mr. Gruber : This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated April 21, 2015 , you petitio ned the Federal Aviation Administration (FAA) on behalf of ReelSkies ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and videography

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal R egister 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 Inspire 1

.2 The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in c onsideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the re quested relief from 14 CFR part 21 , C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s
. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requ ested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;
• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.
Our Dec ision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, ReelSkies 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

1 Aerial data collection 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 (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3 extent necessary to allow the petit ioner 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, ReelSkies is hereafter referred to as the operator. 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 Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.
3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as sp ecified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ; e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated be fore the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.
7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the4 Administrator upon reques t. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow th e procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcem ent official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FA A granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.
8. Any UAS that ha s undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. , replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other p eople. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.
10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. , inoperable components, items, or equipment. If the i nspection 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 exempt ion, 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

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, v essels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) a nd 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 t raining sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance w ith 14 CFR § 91.119.
15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
16. The U A may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published a eronautical 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 an y law enforcement official upon request.
17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre
- determined location within the pr ivate or controlled

- access property.
19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.
21. Air T raffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted 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 con ducted under the terms of the attached COA

.6

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 pa rt 45, Subpart C. Markings must be as large as practicable.
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 St ation of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear and give way to all manned aviation operations and activities at all t imes.
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 th at 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 p rotection 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 t o those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.
27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representa tive 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 FA A'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

.7 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 documente d in this grant of exemption.
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 a rea of propos ed 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 und er this grant of exemption; c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement th at 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 repres entative; 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 oper ations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8 This exemption terminates on August 31 , 2017 , unless sooner superseded or rescinded. Sincerely,
/ s/ John S. Duncan Director, Flight Standards Service

EnclosuresApril 21, 2015

U. S. Department of Transportation Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey

Ave., SE Washington, DC 20590 **Regarding:** Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 CFR Part 21; 61.113(a) and (b); 91.103; 91.109(c); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2 ); 91.417(a) and (b). Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act) and 14 CFR Part 11, ReelSkies which is an owner and operator of Small Unmanned Aircraft Sy stems (sUAS) equipped to conduct comme rcial aerial p hotography and videograph y for agricultural i nspection, real estate, and other commercial operations hereb y applies for an exemption from the listed Federal Aviation Regulations (FAR) to allow commercial operation of its sUAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established b y the FAA as required by Section 333. The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS may

operate safel y in the national airspace s ys tem (NAS) before completion of the FAA’s plan and rulemaking to integrate sUAS into the NAS. The Reform Act directs the Secretary to consider which ty

pes of sUAS as a result of their size, weight, speed, operational capability , pr oximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace or a threat to national securit y. If the Secretary determines that such vehicles may operate safel y in the NAS, the Secretary “shall establish requirements for the safe operation of such aircraft.” The granting of this exemption request will provide immediate benefit to both the agricultural and real estate industries by authorizing highl y controlled sUAS operations at or below 2 00 feet above ground level (AGL), in line of sight of an FAA Certificated Airline Transport Pilot during day light hours and above controlled privately owned and operated propert y. ReelSkies sUAS shall weigh less than 10 pounds including the pay load. They will operate at no more than 30 knots and have the capability to hover, and move verticall y and horizontally

simultaneously

. Operations would be conducted above privatel y owned and operated properties, with the consent of the owner/operator. Re elSkies operations will be performed b y a professionalpilot ; this will insure that the sUAS will not create a hazard to users of the national

airspace sy stem or the public. The grant of this exemption request is in the public interest, does not create a hazard to users of the NAS or the public, or pose a threat to national securit y. In the following pages ReelSkies addresses all areas of concern to include:

 Equivalent levels of safety

 Exemptions requested
The name and address of the applicant is:
**ReelSkies** ATTN : Nick Gruber Phone: ( 402 ) 318

- 8093 Email: nick.j.gruber@gmail.com Address: 5341 West Chanceler Court

Li ncoln, NE 68521
ReelSkies appreciates yo ur consideration in this matter. Best Regards, Nick Gruber President ReelSkies
In cluded in this Exemption L ett er :

 Operations

 Regulations for which exemptions are requested To follow this Exem ption L etter and/or on request:

 ReelSkies Operating Manual

 Inspection Program

 Aircraf

t Operating Manual (AOM)

### Table of Contents

Operations and How They Serve the Public Interest About ReelSkies ReelSkies sUAS Description Safety Maintenance Permissions and Permitting Operations Flight Time and Flight Durations Exemptions from which Regulations

### Operations **and How They Serve the Public Interest**

**Real Estate Photography by sUAS** 

 SUAS allow aerial video and photograph y of real estate property without the use of full size aircraft.

 Use of sUAS in real estate, as well as other sectors, is more efficient, less costly , and environmentall y friendly

.  Utilizing sUAS for real esta te is safer than utilizing full

- sca le aircraft which pose a greater risk to people and propert y
 Operations will be conducted below 200 feet AGL, at slow speeds, and within line of sight of a certificated pilot

. **Agricultural Inspection by sUAS**

 SUAS inspection is of higher quality , more relia ble, and can be reviewed in real time. SUAS inspections allow for the collection, dissemination and permanent storage of photos and videos of agricultural inspections.

 SUAS inspection is more efficient and less costly

.  SUAS inspection is safer than traditional manned commercial aircraft. SUAS’s are less likel y to cause damage to propert y or life in the event of an accident. **Inspection of Construction Areas**

 SUAS use at construction sites will provide an aerial view of the area to interested parties such as financier of the project.

 Due to the small size of sUAS they pose less risk of damage to people or propert y when properly

used then full size aircraft.



### About **ReelSk**

**ies**
**President**

 Nick J. Gruber, a graduate of Embry

- Riddle Aeronautical Universit y, l eads ReelSkies as President. He graduated with a Bachelor ’s in Aeronautics minor in management

.  Nick Gruber holds an Airline Transport Pilot (ATP) Certificate along with Certified Flight Instructor (CFI), Instrument (CFII), and Multi

- engine (MEI) certificates. He also holds a Commercial Rotorcraft Helicopter with Instrument certificate. He currently

flies for a Part 121 airline.

 Nick has extensive experience in both commercial aviation and radio control airc raft operations including helicopters and multi

- copters.
 ReelSkies sUAS are outfitted for aerial photogra phy and videograph y for use in agricultural i nspecti on and real estate industries.**Experience**

As a professional pilot , Nick Gruber understands that safet y is paramount and will always hold **s afety**  ah ead of an y commercial endeavor.

 Individuals within ReelSkies have onl y operated sUAS as hobbyists. To date, ReelSkies members have not engaged in an y commercial activity to ensure it is in compliance with an y applicable FARs or local, state, and federal laws.

 ReelSkies has a detailed sUAS operating m anual and a ircra ft i nspecti on manual that it shall follow, sho uld this exemption be approved. 

### ReelSk **ies sUAS Description** 
ReelSkies intendeds to operate DJ I sUAS multi

- rotor aircraft for the purpose of obtaining photographs and v ideo for agricultural inspection, real estate, and other commercial endeavors

. These aircraft have fail

- safe features to include geo

- fencing and lost link return home capability . DJI

is the manufacturer of multi

- rotors weighing less than 25 pounds and has developed technology

that will enhance safe sUAS operations within the NAS.
**T6 00/**  **DJI Inspire 1** 

**Model** T600/ Inspire 1 **Weight (Battery Included)** 2935g 6.5 pounds
**Battery** 22.2V, 4500mAh **Hovering Accuracy Vertical:** 0.5m 1.7 f eet

**Horizontal:** 2.5m 8.2 feet

**Ma x Angular Velocity Yaw**  **/Pitch :**  150 °/s /300°/s

**Ma x Tilt Angle**  35° **Ma x Ascent Speed**  5 m/s 11.2 mph

**Ma x Descent Speed**  4 m/s 9 mph

**Ma x**  **Speed** 22 m/s 49.2 mph

**Ma x**  **Flight Time** 18 min **Operating Temperature Range**

- 10° to 40°C **Dimensions** 438x451 x301 mm 17x18 x12 inches Specifications and Design:A. All sUAS flown under this exemption shall be less than 10 pounds including aircraft and pay load. This exemption requests permission only with respect to the specific use of the DJ I In spire 1 Model T600 , which weighs less than 10 pounds including pay load.
B. The radio freq

uency spectrum used for operation and control of the sUAS shall comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. The DJ I Inspire uses spread spectrum technology operating in the 2.4 Ghz range and is compliant with all FCC regulations as demonstrated in the aircraft manual.
C. Max imum speed shall be less than 30 knots.
D. The sUAS shall be equipped with Inertial Navigation Sensor(s) and Gy roscopes (I RS/IRU/Accelerometer/MEMS Gy roscopes).
E. The sUAS shall be equipped with a Compass (Magnetometer/Heading Source).
F. The sUAS shall be equipped with a Global Positioning Sy stem (GPS) guidance sy stem. The sUAS shall be designed, should it lose communications or lose its GPS signal, t o return to a pre

- determined location within the area of operations and land or be recovered in accordance with Reel Skies sUAS operating m anual. 

### Safety
ReelSkies proposes that the exemption requested applies to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safet y to operations under the current regulatory structure because the proposed operations represent a safet y enhancement to the already safe operations conducted with conventional aircraft. **This Exemption Request is for Use of sUAS subject to Extensive Operational and Safety Requirements**  These limitations and conditions to which ReelSkies agrees to be bound when conducting commercial operations under an FAA issued exemption at a minimum include:
A. The sUAS Pilot in Command (PI C) shall possess at a minimum, a private pilot certificate and current third

- class medical certificate.

 The PI C shall also meet the flight review requirements specified in 14 CFR §61.56 in an aircraft in which the PI C is rated on their pilot certificate. The PI C shall be trained in the operation of the specific make and model of the sUAS being piloted and success fully completed all training required.

 The PI C shall have accumulated and logged, in a manner consistent with 14 CFR §61.51 (b), a minimum of 200 flight cy cles and 25 hours of total time as a sUAS pilot and at least five hours logged as a sUAS pilot with a similar sUAS ty

pe (multi

- rotor/ helicopter /airplane ). Prior documented flight experience that was obtained in compliance with applicable regulations may

satisfy this requirement.

 For currency

t he PIC shall have accumulated and logged, in a manner consi stent with 14 CFR §61.51 (b), a minimum of five hours as sUAS pilot operating the make and model of sUAS to be utilized for operations und er the exemption and three take offs and three lan dings in the preceding 90 day s. Flight time and number of takeoffs an d landings will be recorded in a logbook for purposes of demonstrating currency

.  Training, proficiency , and experience

- building flights can also be conducted under this grant of exemption to accomplish the required flight cy cles and flight time.
B. Dur ing training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered non

- participants, and the PIC must operate the sUAS with appropriate distance from non

- participants in accordance with 14 CFR §91.11 9. C. The PI C shall alway s be within visual line of sight (VLOS) of the sUAS while conducting operations.
D. A risk mitigation survey will be conducted prior to each flight to ensure VLOS can be maintained at all times, hazards are properly identified, and that all regulatory

perimeters can be met.


### Maintenance
A. SUAS shall be maintained in accordance with the manufacturer’s recommendations and ReelSkies sUAS o perati ng m anual

. B. ReelSkies will document and maintain a record of the sUAS maintenance, preventative maintenance, alterations, and status of replacement, overhaul component parts, and the total time in service of the sUAS. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations. See ReelSkies sUAS o perati ng m anual

.

C. ReelSkies shall comply with all manufacturer Safety / Service Bulletins or equivalent pertaining to the sUAS aircraft.D. The PI C s hall perform a preflight inspection of the sUAS, controller, and ground control station prior to each flight to ensure it is ope rational with no discrepancies. The preflight inspection checklist can be found on page 48 of the AOM. If the preflight inspection reveals discrepancies, repairs or maintenance shall be performed prior to flight and logged in the maintenance log . The sUAS will only be operated if all s ys tems are operating per manufacture’s specifications an d in a discrepancy free condition.
E. Maintenance or repairs that may affect the sUAS operation or flight characteristics shall undergo a functional test flight when required in accordance with manufactures recommendations and ReelSkies sUAS operating m anual. This functional test fl ight shall be recorded in the sUAS’s records. If the functional test flight is completed successfully , the sUAS can be returned to service b y the PI C.

F. ReelSkies shall follow the manufacturer’s sUAS maintenance, overhaul, replacement, inspection, and life limit requirements. When not provided by the manufacturer aircraft maintenance, component, overhaul, replacement, and inspection maintenance requirements shall be established and included in ReelSkies sUAS o perati ng m anual

.

 At a minimum the foll owing will be meet:
1. Actuators / Servos
2. Powerplant(s) (motors)
3. Propellers
4. Electronic speed controller(s)
5. Batteries
6. Remote controllers and Ground control station 

### Permissions and Permitting
A. All required permissions and permits shall be obtained from territorial, state, county or city jurisdictions, including local law enforcement, or other appropriate governmental agencies.
B. At least three day s before a scheduled operational flight, ReelSkies shall submit a written plan of activities to the local flight standards district office (FSDO) with jurisdiction over the area of the proposed flight. The 3

- day notification may

be waived with the concurrence of the FSDO. The plan of activities shall in clude at least the following:

1. Dates and times for all requested flights
2. Name and phone number of ReelSkies sUAS Flight Operations
3. Name, certificate, phone number of the PIC responsible
4. Make, model, and serial number of sUAS to be used
5. Statement from ReelSkies that it will be operating on approved privatel y owned and operated propert y; the list of those who gave permission shall be made available to the inspector upon request.
6. Description of the flight activity , including maps or diagr ams of any area over which flights will be conducted, the relationship of that area to an y nearb y city , town, etc., and the altitudes essential to accomplish the operation
7. Signature of exemption

- holder or representative
C. Documents required per 14 CFR §91.9 and §91.203 shall be readil y available to the PI C an y time the aircraft is in operation. These documents shall be made available to the Administrator or an y l aw enforcement official upon request.
D. ReelSkies shall obtain an Air Traffic Organizatio n (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under this grant of exemption.
E. ReelSkies shall obtain the consent of all persons involved in the operation and ensure that onl y consenting persons be allowed within 500 feet of the Operations Area. 

### Operations
A. The sUAS shall not operate within 5 nautical miles of the geographic center of any airport as denoted on the current FAA

- published aeronautical chart unless a letter of agreement with that airp ort’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. This letter of agreement with the airport management shall be made available to the Administrator upon request.
B. The sUAS will only operate within the lateral boundaries of approved privately owned and operated property . An Operations Area within those boundaries will be established for each flight. These areas will be free of unnecessary hazards or risks and non

- participating personne l. The sUAS shall only operate within a pre

- defined area of operations that shall be thoroughl y inspected b y the PI C for buildings, overhangs, obstacles, wires, pole s, people, vehicles, shadows, glare, reflective surfaces, clouds, smoke, and terrain among other potential hazards.
C. Flights shall be conducted under day visual meteorological conditions (VMC) only

.

 In addition, the sUAS shall not be operated less than 500 feet below or l ess than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C.

 SUAS operations shall **not** be conducted at night, as defined in 14 CFR §1.1.

 Flights shall **not** be conducted under special visual fli ght rules (SVFR).
D. Flights shall be operate d at an altitude at or below 200 feet AGL, as indicated by t he procedures specified in ReelSkies sUAS operating m anual.
E. Ground speeds will not exceed 30 knots as indicated b y the aircraft GPS.
F. The PI C shall be prohibited from operating the sUAS from any moving device or vehicle.
G. The sUAS shall be operated within VL OS of the PI C.

 The PI C shall maintain VLOS without the aid of telesco pes, cameras or other devices.

 T he PI C will maintain VLOS with their own vision, which includes the use of ey eglasses or corrective lenses as specified on the PI C’s medical certificate.
H. The sUAS shall remain clear and yi eld the right of way to manned operations and activities at all times including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.
I. ReelSkies will require the PIC to have successfully completed a qualification process which will include ground and flight tr aining, as outlined in the ReelSkies sUAS Operating Manual.
J. The PI C’s primary responsibility

while in flight is the safe operation of the sUAS.


### Flight Time and Flight DurationsThe PI C will commence the landing sequence when 25% battery life remains. The aircraft will a utomatically return to base when it triggers a low battery warning. 

### Exemptions from which Regulations Unless otherwise requesting an exe mption, ReelSkies , the PI C, and the sUAS shall comply with all applicable parts of 14 CFR including, but not limite d to, Parts 45, 47, 61, and 91. ReelSkies is requesting exemptions from the following Federal Aviation Regulations to the extent necessary

to enable the requested sUAS operations for the reasons detailed below.
**Relief sought from 14 CFR ReelSkies**  **Statement**
21 Stated Below 61.113(a) and (b) Stated Below
91.103 Stated Below 91.119(c) Stated Below 91.121 Stated Below 91.151(a)(1) Stated Below 91.405(a) Stated Below 91.407(a)(1) Stated Below 91.409(a)(1) and (2) Stated Below 91.417(a) and (b) Stated Below

**14 CFR 21**

**– Requirements to Secure Airworthiness Certificates**  1. Certificate exemptions should be given because size, weight, and operation areas of the sUAS meet the level of safet y necessary for exemption under Section 333 of the Reform Act.
2. FAA has the authorit y to exempt aircraft from airworthiness certificate requirements under the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act.**14 CFR 61.113 (a) and (b)**

**– Private Pilot Privileges and Limitations; P**  **ilot in**

**Command** 1. Due to the fact that there are no standards for private or commercial sUAS operations, ReelSkies requests to utilize at least private pilots with a third class medical in support of its own operations.
2. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), along with the ability

to phy sicall y manipulate the controls of the sUAS are the critical aspects of the requested operation. ReelSkies feels this can be accomplished b y a private pilot that has specific traini ng on the sUAS aircraft and operates in accordance with the ReelSkies sUAS Operating Manual, Federal Aviation Regulations, local, state and federal laws.
3. The risks associated with the operation of a sUAS are so diminished from the level of risk associate d with commercial aviation operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PI C exceeds the present level of safet y achieved b y 14 C.F.R. §61.113 (a) & (b).
4. Equivalent or better safety levels will be achieved as there will be no human bei ngs on board the sUAS aircraft. In addition, people will not be allowed in the area of operation.
5. FAA has authority

to waive pilot requirements for commercial operations under 49 U.S.C §44701(f).

**14 CFR 91.103**

**– Preflight Action**  1. The PI C shall perform a preflight inspection in accordance with the manufacturer’s recommendations and the ReelSkies sUAS Operating Manual of the controller, ground control station and associat ed equipment prior to each flight to ensure it is free of all discrepancies.
2. Equivalent safet y levels will be met through preparation and compliance according to ReelSkies ’s sUAS Operating Manual; including but not limited to, weather reports, forecasts, wind, temperature, battery requirements and other information, relating to aircraft performance, gross weight, shall be considered. **14 CFR 91.119(c)**

**– Requirements for Minimum Safe Altitudes for Civil Aircraft**  **Operation** 1. The sUA S will be operated at or below 2 00 feet AGL

.2. ReelSkies shall obtain the consent of all persons involved in the operation and ensure that only consenting persons be allowed within 500 feet of the Operations Area.
3. The sUAS will only

operate within the lateral boundaries of appro ved privately owned and operated property . An Operations Area within those boundaries will be established for each flight. These areas will be free of unnecessary hazards or risks and non

- participating personnel.
4. Given the size, weight, speed, material, and operation of the sUAS aircraft, equivalent levels of safety

will be achieved.
**14 CFR 91.121**

**– Altimeter Settings**  1. SUAS will not have a barometric altimeter, and may use a GPS altitude read out indication instead, so an exemption may be needed.
2. Th e operator will achieve an equivalent level of safet y as the sUAS uses AGL height from its initialization/takeoff point. **14 CFR 91.151 (a) (1)**

**– Fuel Requirements for Flights in VFR Conditions**  1. The FAA has previously issued exemptions for fuel requirements in VFR conditions including Exemptions 2689F, 5745, 10673, and 10808.
2. ReelSkies feels an equivalent level of safet y can be obtained b y terminating the flight prior to the following. **Aircraft Fuel (Battery) Requirements**
DJI I nspire

- 18 m inutes which allows for 5 minutes reserve.
1. The DJ I Inspire has a second level of safety that is achieved through the use of an aircraft battery

monitoring s ys tem. The aircraft s ystem will alert the operator of low battery

voltage and return the aircraft to its take off location before battery capacity is depleted.
2. ReelSkies will not operate sUAS at night in accordance with 14 CFR 1.1
3. An equivalent level of safety will be achieved because these sUAS are limited in size, operational purposes of the sUAS, and shall only fly above approved privately owned and operate d property at or below 2 00 feet AGL, it does not bear the same risks associated with this section’s requirements. **14 CFR 91.405 (a)**

**– Maintenance Required**  This section and Part 43 apply onl y to aircraft with an airworthiness certificate; therefore these sections will not apply

.In the absence of regulatory provisions dealing with sUAS operation for maintenance required. See ReelSkies sUAS Operating Manual, Inspection Program and Manufactures Ma intenance Recommendations for maintenance required. 1. Maintenance shall be accomplished by ReelSkies , pursuant to the manufacturer’s recommendations and ReelSkies sUAS Operating Manual and Inspection Program.
2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully accomplished b y train ed personnel onl y
. 3. The ReelSkies sUAS Operating Manual and Inspection Program details how to enter worked preformed in the maintenance log for scheduled, unscheduled maintenance or func tional test flights that are performed.
4. ReelSkies shall only

operate its sUAS with all sy stems functioning per manufactures specification in a discrepancy free condition.
5. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations.
ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. This maintenance process allows for an equivalent level of safet y to be achieved due to the limited size, scope and area of operations. **14 CFR 91.407 (a) (1)**

**– Operation after Maintenance, Preventive Maintenance,**  **Rebuilding or Alteration** This section and Part 43 apply onl y to aircraft wit h an airworthiness certificate; therefore these sections will not apply

. In the absence of regulatory provisions dealing with sUAS operation after maintenance, preventive maintenance, rebuilding, alteration or functional test flights, ReelSkies has develo ped requirements to address these topics. See ReelSkies sUAS Operating Manual, Inspection Program and Manufactures User Guides.
1. Maintenance will be accomplished by ReelSkies pursuant to the manu facturer’s recommendations and ReelSkies sUAS Operating Manual and Inspection Program.
2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully accomplished b y trained personnel onl y.
3. Functional test flights will be performed b y the PIC when required, the sUAS sha ll only be returned to service when this functional test flight is successfull y completed. If a mechanical issue arises the sUAS can land safel y or be recoveredwithin the Operations Area.

4. The ReelSkies sUAS Operating Manual details how to enter in the m aintenance log scheduled and unscheduled maintenance or functional test flights that are performed.
5. ReelSkies shall only

operate its sUAS with all sy stems functioning per manufactures specification in a discrepancy free condition.
6. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations. ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition. These maintenance procedures allow for an equivalent level of safet y to be achieved due to the limited size, scope and area of operations. **14 CFR 91.409 (a) (1) and (2)**

**– Inspections**  This section and Part 43 apply onl y to aircr aft with an airworthiness certificate; therefore these sections will not apply

. In the absence of regulatory provisions dealing with sUAS inspections, ReelSkies has developed requirements to address this topic. See ReelSkies sUAS Operating Manual, Inspect ion Program and the Manufactures User Guides.
1. Maintenance will be accomplished by ReelSkies pursuant to the manufacturer’s recommendations and ReelSkies sUAS Operating Manual and Inspection Program.
2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully accomplished b y trained personnel onl y.
3. The ReelSkies sUAS Operating Manual details how to enter into the maintenance log all inspections that are performed.
4. Functional test flight will be performed b y the PIC when requi red after inspections, the sUAS shall be returned to service when the flight is successfull y completed. If a mechanical issue arises the sUAS can land safel y or be recovered within the Operations Area.
5. ReelSkies shall only

operate its sUAS with all sy ste ms functioning per manufactures specification in a discrepancy free condition.
6. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations.
ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft andbest suited to maintain the aircraft in an airworth y condition. These maintenance

inspections allow for an equivalent level of safet y to be achieved due to the limited size, scope and area of o perations. **14 CFR 91.417(a) and (b)**

**– Maintenance Records**  This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these sections will not apply

. In the absence of regulatory provisions dealing with sUAS maintenance re cords, ReelSkies has developed requirements to address this topic. See ReelSkies sUAS Operating Manual and Inspection Program.
1. Maintenance will be accomplished by ReelSkies pursuant to the manufacturer’s recommendations and ReelSkies sUAS Operating Manual.
2. Maintenance, preventive maintenance, rebuilding, and alteration maintenance recording keeping will be performed b y trained personnel and entered in the respective aircraft maintenance log at completion of each event. The ReelSkies sUAS Operating Manual details how entries are to be made in the aircraft maintenance log for scheduled and unscheduled maintenance or functional test flights that are performed.
3. These records will be maintained at the principle base for operation for the life of the ai rcraft or as required b y Federal Aviation Regulations.
ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. These maintenance records allow for an equiva lent level of safet y to be achieved due to the limited size, scope and area of operations.