DeGrazia Music LLC

Request For Exemptions

ADDITIONAL INFORMATION, VIEWS AND ARGUMENTS

Below please find supplemental information in the form of a quick reference list of information 

related to the UASs and operations thereof.

Domingo DeGrazia

DeGrazia Music LLC

120 S. Houghton Rd, Suite 138-113

Tucson, AZ 85748

Tel: 520-370-1150
Supplemental Information Table of Contents

1. General Information Regarding the Unmanned Aircraft System.....................................................2

2. Procedures for Pre-flight, Flight, Emergencies and Maintenance ...................................................3

3. Radio Frequencies Used .................................................................................................................3

4. Pilot Qualifications...........................................................................................................................3

5. Medical Requirements for Pilots......................................................................................................4

6. Flight Operational Limitations.........................................................................................................4

7. Maximum Aircraft Operations.........................................................................................................4

8. Characteristics of Intended Operations............................................................................................4

9. Operational Proximity to Airports....................................................................................................4

10. Methods to Ensure Visual Line of Sight.........................................................................................5

11. Risk Assessment – Pre-flight Safety...............................................................................................5

12. Contact with FSDOs.......................................................................................................................5
1. General Information Regarding the Unmanned Aircraft System

How Operations Will be Conducted to Minimize Risk

All UAS operations will be conducted in accordance with the Motion Picture and Television 

Operations Manual and Company Operations Manual (MPTOH COH), Aircraft Operational 

Handbook (AOH) and FARs with the safety of the public and protection of private property as a

paramount concern. 

Protection of the general public will be accomplished by securing each flight area and only 

operating the aircraft when sufficient satellites are available to provide Fail Safe Return to 

Home functions. Ground crews will ensure restricted access to the flight area during flight 

operations. All persons remaining in the flight area will be briefed on potential hazards of flight

and will acknowledges such risks through waiver. Any property which may be at risk will be 

removed and / or flight plans altered to reduce the possibility of damage to property. 

Design and Operational Characteristics

AIRCRAFT

The UASs proposed are light-weight, (less than 7 lbs) quad-copter configuration, remotely 

controlled aircraft. The four blades are fixed pitch and operate in pairs with two rotating clockwise and two rotating counter clock-wise. Lift is achieved by increasing the speed of rotation 

of the blades. Directional control is achieved by altering the speed of various blades, thereby 

increasing lift to one or more rotor disks. 

SOFTWARE and SENSORS

The UASs here are equipped with flight control software for greater safety and control of the 

aircraft in all flight envelopes. The aircraft are programmed with both Phantom and Naza flight

modes in GPS and non-GPS flight. The Phantom flight mode, when coupled with GPS, 

provides the Fail Safe Return to Home function and provides hover accuracy of 0.8 meters 

vertically and 2.5 meters horizontally. The Naza-M-V2 Flight Control Software developed by 

DJI also provides Go Home and automatically land functions. In both cases the software is 

coupled with a 3-axis gyroscope and barometer to provide inertial sensing and act as a 

barometric altimeter. The software also couples GPS signals and a geomagnetic compass for 

stability and accuracy of flight. 

Aircraft performance – Please see page 3 of the Aircraft Operational Handbook

Operational limits - Please see page 5 of the Aircraft Operational Handbook

Operating procedures - Please see page 6 of the Aircraft Operational Handbook

Aircraft Loading

The UASs to be operated are unable to carry persons. Cargo is limited to small cameras 

weighing up to three (3) lbs. No other cargo can be carried.

UAS development and operational history

While manned versions of the quad-copter have been in development for decades, current 

micro-processor /sensor packages allow for hover stability, accurate directional stability, battery

monitoring, and Fail Safe Return to Home functions as described below. 
Failure Modes

Failure modes of aircraft systems and redundant safety measures are as follows: 

Mechanical Failure of the Aircraft

The proposed UASs have few mechanical parts. The electric motors driving the rotor blades 

are the only mechanical parts related to flight. While the UASs do carry camera gimbals with 

mechanical components, those components are separate from the flight motors and failure of the

gimbals does not compromise flight safety.

Pre-flight checks and routine maintenance provide the best possible protection against 

mechanical failure. However, should mechanical failure occur, site security and briefing of 

personnel provides redundant protection for persons or property on the ground.

Pilot Incapacitation

Should the pilot experience issues related to ability to pilot the UAS, the AOH directs the pilot 

to initiate the Fail Safe return to Home procedure. If the pilot is unable to execute the Fail Safe 

mode, the aircraft is programmed to hover in the place where the last command was received 

and land automatically if no further commands are received. As the flight area will be secure, 

the aircraft can land safely. 

Battery Failure

Should issues arise with the aircraft battery, on-board programming automatically alerts the 

pilot via audible alerts and a visible warnings on the remote control. The flight software 

continuously calculates the time required to safely return to the Home-Point and land based on 

distance from the Home-Point and the aircraft's altitude. If the aircraft battery power gets to a 

critical level during flight, the aircraft will automatically begin a safe landing sequence. 

Lost Communications Between Remote and Aircraft 

Should the aircraft experience loss of communication during flight, the aircraft automatically 

enters Fail Safe mode. Loss of communication can be caused by signal interference, blocked 

signals, or loss of power to the remote control. In any of these situations, the aircraft enters Fail

Safe mode and automatically returns to the Home-Point and lands automatically. 

Lost Satellites

If less than six satellites are detected for more than twenty seconds, the aircraft will enter Fail 

Safe mode and return to land automatically.

2. Procedures for Pre-flight, Flight, Emergencies and Maintenance 

Pre-flight inspections - Please see page 6 of the Aircraft Operational Handbook

Emergency Procedures - Please see page 9 of the Aircraft Operational Handbook

Maintenance - Please see page 12 of the Aircraft Operational Handbook

3. Radio Frequencies Used 

Radio Frequency 5.728 – 5.8 Ghz

FCC compliance Factory set at 100mW

Camera Control The on-board camera is controlled via cellphone on the 2.4 GHz band.
4. Pilot Qualifications

Minimum Pilot Licensure - Private Pilot license.

PIC will have logged hours and demonstrate experience meeting or exceeding the following:

1. A minimum of 300 hours logged in conventional aircraft.

2. A minimum 2 years experience in remote controlled aircraft, 

3. Have logged flight time consistent with 14 CFR § 61.51 (b):

1. A minimum of 200 flight cycles as PIC,

2. A minimum of 25 hours as PIC of UAS rotor craft,

3. At least 10 hours as a UAS as PIC with a similar UAS type (single blade or 

multirotor),

4. A minimum of 5 hours as UAS PIC operating the make and model of UAS to be 

utilized for the current operation,

5. Three take-offs and three landings in the preceding 90 days.

5. Medical Requirements for Pilots

Pilot will hold a minimum current Class 3 medical.

6. Flight Operational Limitations

Please see page 5 of the Aircraft Operations Handbook.

7. Maximum Aircraft Operations

Maximum Operating Speed 33mph Phantom, (22mph Inspire)

Maximum Operating Altitude - 400 feet AGL

Minimum Visibility 1⁄4 mile

Distance from Clouds 500 feet below, 2,000 horizontal

Hazards and Mitigation Please see page 4 of the Company Operations 

Handbook

8. Characteristics of Intended Operations

Intended Area of Operations- The areas of intended operations are the United States. All 

specific locations will be in accordance with the MPTOH COH and AOH with notice to the 

local FSDO.

Hazards Mitigation- Hazard mitigation is described below and is comprised developing a plan

that meets regulatory and safety requirements for both ground hazard mitigation and flight 

hazard mitigation. In both cases the goal is to operate while protecting the public as much as 

possible while conducting flight operations. 

Ground hazard mitigation consists of ensuring there is no danger to persons on the ground 

through securing the flight area, removing non-participating public, properly securing property 

in the flight path to the extent possible, and ensuring that all crew in the flight area know and 

waive the risks involved. Potential hazard to property on the ground will not preclude flight.

Flight hazard mitigation begins with contacting the regional FSDO, researching the area 

through sectional charts, site visits, and continuous weather planning. The UAS will be 

operated at an altitude that allows landing in an emergency without hazard to persons or 

property on the surface, and includes consideration of maximum lateral wind-drift in a manner 

similar to “cone of safety” operations. 
Proximity to populated areas- Flights may be conducted within populated areas when the 

flight area is secure and maximum wind drift is calculated to ensure the aircraft cannot drift 

over the public or public property if communication with the remote control is lost. Should 

wind conditions exceed this limit the flight will not be conducted.

9. Operational Proximity to Airports

The UASs will not operate in Class B, C, or D airspace without written approval from the FAA. 

The UASs will not operate within 5 nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management will be made available to the Administrator upon request.

10. Methods to Ensure Visual Line of Sight

The Pilot in Command will operate the UAS only with VLOS. Support persons other than 

Visual Observers are not authorized to supplement the VLOS of the PIC. The PIC has the final 

responsibility to ensure the UAS is operated within VLOS. Each flight must be executed in a 

manner that ensures there will be no hazard to the NAS and the public. 

11. Risk Assessment – Pre-flight Safety

Please refer to page 6 of the Aircraft Operational Handbook.

12. Contact with FSDOs

At least three (3) days prior to any scheduled filming a written plan of activities will be 

submitted to the local FSDO having jurisdiction over that area. The written plan will include:

(1) Dates and times for all flights.

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

(3) Name and phone number of person responsible for aircraft.

(4) Make, model, and serial of aircraft to be used. 

(5) The name and certificate number of pilots involved in the filming production.

(6) A statement that the waiver holder has obtained permission from property owners and/or 

local officials to conduct the filming production event. The list of those who gave permission 

must be made available to the inspector upon request from the waiver holder.

(7) Signature of waiver holder or representative.

(8) A description of the flight activity including maps or diagrams of any area, city, town, 

county, and/or State over which filming will be conducted and the minimum altitudes essential

to accomplish the operations.

Maintenance Log Book

Please see page 13 of the Aircraft Operations Handbook