### September 17, 2015

Exemption No. 12910 Regulatory Docket No. FAA

–2015

–2118

Mr. Craig Peck Flying Media 837 Willow Road Lancaster, PA 17601
Dear Mr. Peck: 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 May 28, 2015, and September 3, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Flying Media (hereinafter petitioner or operator) for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial photography for the motion picture and television industry for scripted closed

set filming

. 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 exists for 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 are the AeroNavics Sky Jib and DJI Flame Wheel F550

. 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

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consideration 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 requested relief from 14 CFR part 21, Certification 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 collection1



### .. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos
. 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 Labs, 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 requested in Grant of Exemption Nos. 1 1062, 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 Decision 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, Flying Media 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.

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 (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

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Conditions and Limitations
In this grant of exemption, Flying Media 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 AeroNavics Sky Jib and DJI Flame Wheel F550 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 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 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; 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 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 the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,

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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 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 enforcement 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 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 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 people. 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 f or 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 perf ormed 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 flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

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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, 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 (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 nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants 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 rules (SVFR) are not authorized.
16. The UA 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 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 when visibility 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 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 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

.

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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.
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 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 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 essential 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/controller 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

.

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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.
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

-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 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.

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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded. Sincerely, /s/ John S. Duncan Director, Flight Standards Service

Enclosures**~~** --:::::;;;;P

# ~61 Flying Media

May28, 2015
U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.P.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) &(b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).
Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the ReformAct) and 14 C.P.R. Part 11, Flying Media, developer and operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography for the motion picture and television industryfor scripted closed set filming, hereby applies for an exemption from the listed Federal AviationRegulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conductedwithin and under the conditions outlined herein or as may be establishedby the FAA as required bySection 333.! As described more fully below, the requested exemption would permit the operation ofsmall, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) lirnited2) predetem1ined 3) controlled as to access and 4) would provide safety enhancements to the alreadysafe operations in the film and television industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (theFAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuchaircraft systems in the national airspace system." Section 333(c) ofthe ReformAct.
The name and address ofthe applicant is: Flying Media Attention: Craig Peck Phone: 717 475 2482 Email: cpeck@flyingmedia.net Address: 837 Willow Road, Lancaster PA 17601

1 The conditions proposed bythe applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of Waiver for Motion Picture and Television Filming.Regulations from which the exemption is requested:
14 CPR Part 21 14 C.P.R. 45.23(b) 14 CPR 61.113 (a) & (b) 14 C.P.R. 91.7 (a) 14 CPR 91.9 (b) (2) 14 C.P.R. 91.103 14 C.P.R. 91.109 14 C.F. R. 91.119 14 C.P.R. 91.121 14 CPR 91.151 (a) 14 CPR 91.203 (a) & (b) 14 CPR 91.405 (a) 14 CFR407 (a) (1) 14 CPR409 (a) (2) 14 CPR 417 (a) & (b)
This exemption application is expressly submitted to fulfill Congress' goal in passingSection 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system(NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In makingthis determination, the Secretary is required to determine which types ofUASs do not create a hazard tousers ofthe NAS or the public orpose a threat to national security in light ofthefollowing:

• The 

### VAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS within visua1line ofsight ofthe operator.
Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely inthe national airspace system, the Secretary shall establish requirements for the safe operation ofsuchaircraft in the national airspace system." 

### !d. §333(c) (emphasis added)2.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 oftheAct, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

2 Applicant interprets this provision to place the duty on the Administrator to not onlyprocess applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation oftheUAS, ifit should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.netThe Administrator may grant an exemption from a requirement ofa regulation prescribedunder subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(±) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). Flying Media's sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate,under normal conditions at a speed ofno more than 50 knots and have the capabilityto hover, and move inthe vertical and horizontal plane simultaneously. They will operate only in line ofsight and will operateonly within the sterile area described in the Aerial Camera Platforms OPERATIONS MANUAL, attached as Exhibit 1 (hereinafter "the Manual")3. Such operations will insure that the sUAS will "not create ahazard to users ofthe national airspace system or thepublic."4
Given the small size ofthe sUASs involved and the restricted sterile environment withinwhich they will operate, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety)in which Congress envisioned that the FAA must, by exemption, allow commercial operations ofUASsto commence immediately. Also due to the size ofthe UASs and the restricted areas in which therelevant sUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, includingreduced emissions associated with allowing UASs for movie and television operations, the grant oftherequested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAAgrant the requested exemption without delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The applicant proposes that the exemption requested herein apply to civil aircraft that havethe characteristics and that operate with the limitations listed herein. These limitations provide for at leastan equivalent or even higher level ofsafety to operations under the current regulatory structure becausethe proposed operations represent a safety enhancement to the already safe movie and televisionfilming operations conducted with conventional aircraft.

3 Applicant submits this manual as a Confidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary information that the applicant has not and will not share with others. The manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom oflnformation Act 5 USC 552 et.seq.
4 Reform Act Section 3 3 3 (b).

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.netThese limitations and conditions to which Flying Media agrees to be boundwhen conducting commercial operations under an FAA issued exemptioninclude:
1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/or observer. 3. Maximumtotal flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feet AGL or, not more than200 feet above an elevated platform from which filming isplanned. 5. Minimum crew for each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Camera Operator. 6. sUAS pilot will be an FAA licensed airman with at least a private pilot's certificate and/or third class medical, or US Driver's License. The observer will hold at least a third class medical. 7. sUAS Pilot will be Pilot in Command (PIC). Ifa pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC. 8. The UAS will only operate within a confined "Sterile Area" as defined in theManual. The Manual requires the establishment ofa "Security Perimeter" for the flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations prior to eachday's production activities. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeter be present for this briefing. 10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office. 11. The operator will obtain the consent ofall persons involved in the filming and ensurethat only consenting persons will be allowed within 100 feet ofthe flight operation, andthis radius maybe reduced to 30 feet based upon an equivalent level ofsafety determination, as required by the Manual. With the advanced permission ofthe relevantFSDO, operations at closer range can be approved. 12. The operator will submit a written Plan ofActivities to the FSDO three days before the proposed shoot as required by the Exemption. 13. Pilot and observer will have been trained in operation ofUAS generally and receivedupto- date information on the particular UAS to be operated as requiredthe Manual. 14. Observer and pilot will at all times be able to communicate verbally. 15. Written and/or oral permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 17. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre-determined location within the Security Perimeter andland. 18. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies.

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net

### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a)(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required byFAR §91.203 (a) 

### (1). Given the size andlimited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

### (f)) and Section 333 ofthe Reform Actboth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate,upon consideration ofthe size, weight, speed, operational capability, and proximity to airports andpopulated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposedwill be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating withan airworthiness certificate without the restrictions and conditionsproposed.
The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilotnor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively withina secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption willbe tightly controlled and monitored byboth the operator, pursuant to the Manual's requirements, andunder the requirements and in compliance with local public safety requirements, to provide security for thearea ofoperation as is now done with conventional filming. The FAA will have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connectionwith motion picture and television production, provide a greater degree ofsafety to the public andproperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no crediblethreat to national securityposed by the UAS, due to its size, speed ofoperation, location ofoperation, lackof explosive materials or flammable liquid fuels, and inability to carry a substantial externalload.


### 14 C.F

### .R. § 45.23 {b). Marking ofthe Aircraft
The regulation requires:
When marks include only the Roman capital letter "N" and the registration numberis displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft neareach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches normore than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.
Even though the UAS will have no airworthiness certificate, an exemption maybe needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAV, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 

### (f).
The equivalent level ofsafety will be provided byhaving the sUA V marked on its fuselage as required by §45.29 

### (f) where the pilot, observer and others working with the sUAV will seethe identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net

### 14 C.F.R. § 61.113 (a) & 

### (b): Private Pilot Privileges and Limitations: Pilot in Command.
Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafetyof current operations byrequiring the PIC operating the aircraft to have a private pilot's license rather thana commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries thepilot and passengers, the sUAS is remotely controlled with no living thing on board. The area ofoperationis controlled and restricted, and all flights are planned and coordinated in advance as set forth in theManual. The level ofsafety provided bythe requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated withcommercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requestedwith a private pilot as the PIC exceeds the present level ofsafety achieved by 14 C.P.R. §61.113 (a) &(b).


### 14 C.F.R. §91.7(a): Civil aircraft airworthiness.
The regulation requires that no person may operate a civil aircraft unless it is inairworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemptionbe granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofsafety check listsprior to each flight, as set forth in Sections I and 

### J, an equivalent level ofsafety will beprovided.


### 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft.
Section 91.9 (b) (2) provides:
No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or anycombination thereof.
The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not onlybecause there is no pilot on board, but because there is no room or capacityto carry such an item on the aircraft.
The equivalent level ofsafety will be maintained bykeeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issuedthe following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net

### 14 C.F.R. § 91.103: Preflight action
This regulation requires each pilot in command to take certain actions before flight to insurethe safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level ofsafety will be provided as set forth in the Manual. The PIC will take all actions including reviewing weather, flight batteryrequirements, landing and takeoff distances and aircraft performance data before initiation offlight.


### 14 C.F.R. §91.109: Flight instruction:
Section 91.103 provides that no person may operate a civil aircraft (except a mannedfree balloon) that is being used for flight instruction unless that aircraft has fully functioning dualcontrols.


### sVASs and remotely piloted aircraft, by their design do not have fully functional dualcontrols. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight training without fullyfunctional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. SeeExemption Nos.5778K 

### & 9862A. The equivalent level ofsafety provided by the fact that neither a pilotnor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.


### 14 C.F.R. §91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a 

### sVAS that is a helicopter and the exemption requests authority to operate at altitudes up to400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemptionmay be needed to allow such operations. As set forth herein, except for the limited conditions stated inthe Manual, the 

### VAS will never operate at higher than 400 AGL. It will however be operated in arestricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent.
The equivalent level ofsafety will be achieved given the size, weight, speed ofthe 

### VAS as well as the location where it is operated. No flight will be taken without the permission ofthe propertyowner or local officials. Because ofthe advance notice to the property owner and participants in thefilming activity, all affected individuals will be aware ofthe planned flight operations as set forth in Section Hof the Manual. Compared to flight operations with aircraft orrotorcraft weighting far more thanthe maximum 55lbs. proposed herein and the lack offlammable fuel, any risk associated withthese operations is far less than those presently presented with conventional aircraft operating at or below500 AGL in the movie industry. In addition, the low-altitude operations ofthe 

### sVAS will ensure separation between these small-VAS operations and the operations ofconventional aircraft that must complywith Section 91.119.

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net14 C.F.R. §91.121 Altimeter Settings
This regulation requires each person operating an aircraft to maintain cruising altitudeby reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriatealtimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead aGPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuant to the Manual and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFRConditions
Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly tothe first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."
The battery powering the sUAS provides approximately 40 minutes ofpowered flight. Tomeet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight or nightVFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. 

### See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, withless than 30 minutes ofreserve fuel, does not engender the type ofrisks that Section 91.151(a) was intendedto alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% ofbatterypower whichever happens first. This restriction wouldbemore than adequate to return the sUAS to its planned landing zone from anywhere in its limited operatingarea.
Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration
The regulation provides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless ithas within it the following: ( 1) An appropriate and current airworthiness certificate

....

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net(b) No person may operate a civil aircraft unless the airworthiness certificate requiredby paragraph (a) ofthis 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 orcrew.
The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them onthe sUAS.
An equivalent level ofsafety will be achieved bykeeping these documents at the groundcontrol point where the pilot flying the sUAS will have immediate access to them, to the extent theyare applicable to the sUAS. The PAA has issued numerous exemptions to this regulation. Arepresentative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.


### 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & 

### (b): Maintenancelnspections
These regulations require that an aircraft operator or owner "shall have that aircraft inspectedas prescribed in subpart E ofthis part and shall between required inspections, except as providedin paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part43.
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 tothe flight and operating handbook as referenced in the Manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payloadand operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS canland immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual,the operator will ensure that the UAS is in working order prior to initiating flight, performrequired maintenance, and keep a log of any maintenance performed. Moreover, the operator is the personmost familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to providethe equivalent level ofsafety. 

### ********* Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in theFederal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.P.R. §21, subpart H; 14 C.P.R45.23(b);14 C.P.R.§§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a smallunmanned vehicle (55lbs or less) in motion picture and televisionoperations. Approval ofexemptions allowing commercial operations ofsUASs in the film industrywill enhance safety byreducing risk. Conventional film operations, usingjet or piston power aircraft, operate at extremely low altitudesjust feet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of4,000lbs., carrying large amounts of jetA or other fuel (140 gallons forjethelicopters shown below). Suchaircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. and poweredby batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried Q'\

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 

### §ln C1l 0..on board. The sUAS is carried to the film set and not flown. The sUAS will carryno passengers orcrew and, therefore, will not expose them to the risks associated with manned aircraftflights.
The operation ofsmall UASs, weighting less than 55lbs., conducted in the strictconditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and ina sterile environment and, as a result, are far safer than conventional operations conducted withturbine helicopters operating in close proximity to the ground andpeople. 

### Privacy
All flights will occur over private or controlled access property with the property owner'sprior consent and knowledge. Filming will be ofpeople who have also consented to being filmed orotherwise have agreed to be in the area where filming will take place.
Set forth below are pictures ofaerial filming conducted in both day and night environment, as flown today in highly populated and/or urban areas, with turbine powered helicopters. The grant ofthis exemption request will provide improved safety in both day and night operations.

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.netNight operations will also be conducted by sUASs and as shown in the photographs below, such operations are fully lighted so that visibility is as though filming was conducted during daylighthours.

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of20 12--size,weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual lineof sight and national security- provide more than adequatejustification for the grant oftherequested exemptions allowing commercial operation ofapplicant's UAS in the motion picture andtelevision industry pursuant to the Manual appendedhereto.

Sincerely,



# C,:-/O;J

# ~ Craig Peck Flying Media

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.netGENERAL [135.21 and 23] This manual sets forth Flying Media procedures and policies that are acceptable to the Administrator of the Federal Aviation Administration. This manual will be kept current with revisions as necessary. One copy ofthis manual will be maintained in current form at the principal operations base. A copy of this manual will be issued (including all changes and additions) to all flight operators, observers, maintenance personnel, and ground operations personneL A!! Flying Media flight, ground, and maintenance personnel must use this manual in conducting ail sUAS maintenance and flight operations. As required by FAR 135.293(a)(i), a!! personnel will be tested annually on their knowledge ofthis manuaL Flying Media has furnished the Federal Aviation Administration with a current and complete copy ofthis manual. The Director of Operations wi!! furnish the FAA with a!! changes and additions to this manual in a timely manner. Flying Media keeps a current and complete copy ofthis manual with each sUAS. This manual is not contrary to any applicable Federal regulations, applicable foreign regulations, Flying Media operating certificate, or Flying Media operations specifications. If you find a conflict between the Federal Aviation Regulations, certificate, or operations manual specification, the Federal Aviation Regulations will take precedence. You are required to bring any such conflict to the attention of the Director of Operations for correction.

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### 2015MANAGEMENT PERSONNEL [135.23(a)]
FLYING MEDIA has appointed the following persons to the management positions listed:
Director of Operations

....................................................... Craig Peck Chief Pilot

..................................................................... Andrew Wargo Director of Maintenance

................................................ Craig Peck
OPERATIONAL CONTROL
i. Operational Control is defined in FAR 1 as "the exercise of authority over initiating, conducting, and terminating a flight". Operational Control is exercised through both active and passive means. Passive control consists of developing and publishing policies and procedures for operational control personnel and flight operators to follow in the performance of their duties and assuring adequate information and facilities are available to conduct the planned mission. Active control consists of making those decisions and performing those actions necessary to operate a specific flight such as crew scheduling, accepting commercial engagement from the public or governmental entities, reviewing weather, NOTAMs, and flight planning. Flying Media is responsible for ensuring that night operations personnel and operational control employees comply with published policies and procedures.
2. Operational Control systems vary with the type of operation authorized. In accordance with company policy, the major responsibility for operational control is with the Director of Operations. The Director of Operations may delegate the active control of flight to the pHot-in-command, but always retains full responsibility. DUTiES AND RESPONSIBILITIES
Each ofthese people has the authority to act for FLYING MED!Aand, in his respective sphere, exercises operational control under FAR Part 135.77. Their specific duties and responsibilities are: Director of Operations

1. Supervises the Chief Pilot and other employees as directed bythe President. 2. Ensures that all flight operations are conducted safely and in compliance with all Federal Aviation Regulations, Operations Specifications, and Company policies. 3. Holds the FAA certificate authorization and signs all FAA correspondence and R&M Aerial Imagery operations specifications. 4. Communicates with the FAA Flight Standards District Office (FSDO) and the National Transportation Safety Board (NTSB). Files all required reports and documents. 5. Coordinates all revisions to this manual. Submits the proposed revisions to the FSDO, receives confirmation from the FSDO that the revisions are acceptable, and then distributes those revisions to all Flying Media manual holders. 6. Schedules aircraft flight availability and maintenance actions (required inspections) in concert with the Director of Maintenance.

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### 20157. Coordinates with the Director of Maintenance the timely correction of mechanical irregularities and discrepancies. 8. Hires and fires personnel.
Chief Pilot 1. Reports to the Director of Operations. 2. Supervises flight operations personneL 3. Conducts or supervises aH training activities offlight operations personneL 4. Advises the Director of Operations regarding the training offlight operations personnel. 5. Assists the Director of Operations in formulating operations policies, coordinates those policies, and coordinates operations and training. 6. Ensures that all aircraft are properly equipped for applicable operations. 7. Disseminates information to a!! flight operations personnel pertaining to airports, NOTAMS, company policies, and regulations. 8. Maintains proficiency as Pilot-in-Command. 9. Schedules flight operations personnel, including assigning Pl!ot-in-Command duties. 10. Prepares and maintains proficiency records, pilot files, flight schedules, duty time records, reports, and correspondence pertaining to flight operations activities. 11. Submits a!! reports regarding flight personnel to the Director of Operations. 12. Keeps the aircraft copies of this Operations Manual current. 13. Ensures that all flight crew personnel are certified and supervised according to the requirements specified in the Federal Aviation Regulations.

Director of Maintenance 1. Reports to the Director of Operations. 2. Responsible for ail maintenance and inspection personnel. 3. Ensures that company aircraft are maintained in an airworthy condition. 4. Ensures that all inspections, repairs, and component changes are accomplished in accordance with manufacturer's specifications. 5. Ensures compliance with maintenance procedures, service bulletins, service letters, and applicable Federal Aviation Regulations. 6. Coordinates with maintenance contracting agencies when maintenance activities are being performed on company aircraft. 7. Provides the Director of Operations with the current airworthiness status of the aircraft and the forecast down times to facilitate maintenance scheduling and insure timely deferral or correction of aircraft discrepancies. 8. Maintains a close liaison with manufacturer's representatives, parts supply houses, and repair facilities.

Version 1.1, 20159. Makes available to maintenance personnel the necessary overhaul manuals, service bulletins, service letters, airworthiness directives, applicable sections ofthis manual, and any other required technical data. 10. Maintains aH necessary work records and logbooks, including aircraft permanent maintenance records, including records of aircraft repair and return to service. 11. Maintains the total weight records for all aircraft, batteries and accessories.

PIC AND Observer 

### 1. Keep his or her assigned navigation charts current and up to date. 2. Keep his or her assigned copy ofthis Operations Manual up to date. 3. Report for duty 60 minutes prior to dispatch time. This is for the accomplishment of preflight planning, airframe inspection and documentation. 4. Notify the Director of Operations whenever the pilot may violate any rule due to being dispatched
on a mission. 5. Notify the Director of Operations whenever a medical deficiency exists that would affect the safety of flight. 6. Notify the Director of Maintenance whenever an aircraft material deficiency exists that would affect the safety of flight. 7. The Observer will assist the PIC with all flight planning. During flight operations; maintain a constant lookout for other aircraft or hazards, communicate with the PIC as needed, and respond to PIC safety of flight commands.

WEIGHT AND BALANCE CONTROL [135.23(b)]
Weight and Balance Procedures Not applicable (NA) to sUAS operations. sUAS will always be conducted with no passengers and there are no changes to airframe total weight, from fuel consumption. Flights will never exceed manufactures stated maximum take-off weight

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ACCIDENT NOTIFICATIONS REQUIREMENTS [135.23(d)]
1. The occurrence of any of the following requires Flying Media to notify the National Transportation Safety Board: a. An aircraft accident, as defined in NTSB Part 830 b. A flight control system malfunction or failure.
c. The inability of any required flight PIC to perform his normal flight duties as a result of injury or illness. d. Aircraft collide in flight
e. Damage to property (other than an aircraft) ifthe cost of repair is estimated to exceed $25,000. If the property is considered a total loss, then notification is required if the lesser of the estimated repair cost or its fair market value exceeds $25,000.

2. Flying Media personnel wli! notify the NTSB in the most expeditious means available as follows a. The Pilot-in-Command (PIC) shall notify the Director of Operations, who will immediately notify the NTSB. This notification may be through the FAA (ATC or FSDO), if possible; or may be direct to the NTSB, if necessary. b. If the PIC cannot immediately contact the Director of Operations, the PIC will immediately notify the NTSB. This notification may be through the FAA (ATC or FSDO), if possible; or may be direct to the NTSB, if necessary.
c. If the Director of Operations has good reason to believe the PIC cannot contact him, and that one of the occurrences requiring notification has happened, he wil! immediately notify the NTSB. This notification may be through the FAA (ATC or FSDO), if possible; or may be direct to the NTSB, if necessary.

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### 2015EMERGENCY NOTIFICATION Any Flying Media employee who, under emergency authority, deviates from any Federal Aviation Regulation while on duty will immediately write a complete report of the deviation from Federal Aviation Regulation

.. The employee will include a description of the deviation taken and the reasons for it. This information will be sent to the following address no later than ten business days after the day of the deviation. PA Flight Standards District Office 400 Airport Rd New Cumberland, PA 17070 717-774-8271
The employee will also provide a copy of this deviation report to the Director of Operations.

REPORTING AND RECORDING OF MECHANICAL IRREGULARITIES [i35.23(f), and 135.65(d)]
Whenever a PIC finds a material discrepancy with aircraft or support equipment, they will:
1. Abort the mission. 2. Coordinate with the Director of Maintenance to have the defective equipment repaired.

PREVIOUSLY DEFERRED AND CORRECTED MECHANICAL IRREGULARITIES [135.23(g)]
Not Applicable for sUAS. AI! material discrepancies will be repaired before flight.

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### EMERGENCY PROCEDURES [135.23(m)]
The Pilot-in-Command (PIC) is the sole company employee assigned a!! flight emergency duties. Whenever a Observer is assigned to the flight, the emergency duties are assigned as follows:
Pilot-in-Command • Aviate. If the aircraft can stil! maintain flight, keep flying and maneuver to a safe landing position on the ground. • Navigate. Maneuver to a safe position on the ground. • Communicate. Tel! Observer the prob!em(s) you are having. • Notify proper authorities and request aid. Call after flight termination if necessary. Observer • Assist the P!C with obvious or requested tasks until the aircraft is on the ground. • If the P!C is incapacitated, the Observer will assume all emergency duties.

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### 2015MISSION QUALIFICATION PROCEDURES [!35.23(n)]
Pilot-in-command: Line checks: Routes and airports [135.299(c)]
The P!C and Observer will, before beginning a flight: 1. Study the area on !ow altitude VFR charts as appropriate, noting restricted areas, MEA's, MOCA's, helicopter landing pads, airport routing, and any other pertinent information. 2. Study the area on Goog!e Earth or Bing maps, noting MEA's, routing, buildings, overhead cables, trees, and any other obstacles 3. Study area airports using Airport Facility Directory, noting runway orientations, tower hours of operation, control frequencies and any other pertinent information. 4. in rural areas, study the mission area for bearing and range from any large agricultural fields or crops. Call the local FSS for available aircraft f!ight information. 5. Check current weather conditions and mission time forecast weather at https://www.avlatlonweather.gov/.

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### 201SAPPROVED AIRCARFT INSPECTION PROGRAM [135.23(0)]
Not Applicable. Flying Media does not maintain any aircraft under the provisions of an Approved Aircraft Inspection Program
FUNCTIONAL CHECK FLIGHTS {FSF}
1. Place aircraft on open flat ground with indicator lights facing towards you 2. Power on the controHer and then the aircraft and bind the controller to the aircraft 3. Set the Home Point 4. Push the throttle up slowly to take off 5. Check roll, pitch, an yaw control response 6. Check throttle response 7. Fly outbound from PIC for 100 feet and hover 8. Climb to altitude of 50' and set position and altitude hold 9. Test Failsafe mode with controller switch to (OFF). When aircraft begins return, interrupt with controller switch to (ON) 10. Test return to home (RTH) by pressing button on contro!!er 1

### i. Allow RTG to land aircraft. Throttle down aircraft until motors stop 12. Turn off aircraft and controller

GENERAL OTHER PROCEDURES AND POLICY INSTRUCTIONS [135.23(r)]

AH company flight operations shaH be conducted in a professional and discipline manner. Safety is paramount
All applicable rules, regulations, procedures and policies will be followed. When confronted with a matter of choice or interpretation In determining a course of action where the decisions are a matter ofjudgment, the safer alternative will always be chosen.
The policies and procedures contained herein provide basic operational philosophies and Included general procedures and regulations applicable to a!l Company PIC/Observers. For more specific information on aircraft operating procedures, refer to the appropriate Aircraft Owners ManuaL FLIGHT TRAINING AND TESTING 14 CFR 

### § 91.9 Flying Media's adaptable flight training system wi!! maintain and improve the safety and utility of sUAS flight operations. Flying Media's foundational training program will consistently test a set f!ight proficicies.
All P!Cs for Flying Media will hold a FAA licensed airman certificate. This ensures the basic knowledge of FAA rules, terminology, airspace, aerodynamics and flight.
Pilot logbooks


### 2015Flying Media PICs will maintain a sUAV logbook. Entries will include: • Date • Total Flight time or training time • Flight location • Type and identification of aircraft • Flight Simulator used (Heli-X or OJ! Inspire) Basic Training Course Flying Media flight qualification conducted with company trainer aircraft:
initial upon probationary hire: 1) 2 hours of observed simulator flight a) Controlled Hover at various altitudes b) Controlled night at constant altitude away from PIC c) Controlled flight at constant altitude back and forth in front of PiC d) Simulated emergency landing from altitude 2) 5 hours of observed flight time in 'manual' mode, with designated training sUAS. (Manual mode means flying the sUAS without the use of any autopilot software functions such as; altitude hold, position hold or GPS flight modes.)
Proficiency Tests 1) Preflight and Battery knowledge a) Demonstrate a proper preflight and make ready for flight. b) Estimate total testing flight time and ensure enough charged batteries are on hand to carry out the test. c) Discuss: proper battery handling, temperature issues affecting charge and discharge, discharge rates at various throttle settings. 2) Hover a) Bring the aircraft to a 3 foot hover, nose of the aircraft pointing away 180 degrees (tail on) 6 feet in front of the PIC and evaluator. Visualize a cube 6 foot on each side. Maintain a hover inside this cube for 5 minutes. b) Bring the aircraft to a 3 f foot hover, nose ofthe aircraft pointing toward the PIC (head on) 6 feet in front of the PIC and evaluator. Visualize a cube 6 foot on each side. Maintain a hover inside this cube for 5 minutes. c) Fly the aircraft out 100 foot from the P!C and evaluator, tail on. Bring the aircraft to a 3 foot hover. Visualize a cube 6 foot on each side. Maintain a hover inside this cube for 3 minutes. 3) Vertical Obstacle Survey 30 foot a) Fly to a standoff distance of approximately 6 foot from the evaluator chosen vertical obstacle, tail
on. Keeping the 6 foot standoff distance, climb, in 6 foot sections to the top ofthe obstacle, stopping for 10 seconds at each 6 foot increase of height. At the top of the obstacle, reverse the

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sUAS to head on (to the PIC) and descend the sUAS In 10 foot sections, stopping for 30 seconds each 10 feet. 4) Horizontal Obstacle Survey 50 foot a) Fly to a standoff distance of approximately 6 foot from the evaluator chosen horizontal obstacle, tail on. Keeping the 6 foot standoff distance, and maintaining constant altitude, fly the sUAS parallel down the length ofthe obstacle in no greater than 30 seconds. At the end ofthe obstacle, reverse the sUAS to head on (to the PIC) and fly the sUAS parallel down the length of the obstacle in no less than 90 seconds. 5) Emergency Landing from altitude a) Climb the sUAS to approximately 100 foot and hold position. The evaluator will put down a visible marking about 10 feet in front of the PIC. When instructed, land the sUAS, as soon as possible (undamaged), within 2 feet ofthe landing marker.

STERILE OPERATING REQUIREMENT (FAR 135.100) PICs are prohibited from engaging in any activity during flight, except those required for safe opration of aircraft. Examples of duties and activities prohibited are: 1. Mobile phone cals 2. Eating, drinking 3. Nonessential conversation (remarks not pertinent to safe aircraft operation). STANDARDIZATION OF FLIGHT PROCEDURES PICS and Observers will at all times adhere to published standardized procedures in the conduct of flights. This ensures company aircraft are operated according to procedures that the company deems to be safest

Violaiton of Flying Media Flight operations manual procedures, is considered a breach of code of conduct. Infractions may result in termination of employment.

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### 2015FLIGHT OPERATIONS
6.1 MISSION PLANNING Mission planning is the responsibility ofthe PIC and will cover all matters pertinent to the mission to be flown. Proper planning prevents piss poor performance.
6.1.1 Weather A complete weather briefing is a prerequisite.
6.2 BRIEFING The success of a flight is a direct measure of the preflight preparations, planning, and briefing
6.2.1 Flight Checklist 1. Pick a Take Off Point; that is flat, dry and located inside the planned flight area. 2. Estimate flight time and battery use for mission photography/survey points. 3. Set recovery point; flat dry location 4. Check wind speed and direction. 5. Check complete horizon for low flying aircraft. 6. Stay clear of structures that could block the Radio Frequency (RF) control or Global Positioning System (GPS) signal; tall buildings, many tal! trees 7. Keep the aircraft away from obstacles, people, animals, overhead !ines, and trees. 8. Turn off Wi-Fi on any mobile devices. sUAS operational control frequencies operate on 2.4Ghz and 5.8Ghz bands. FCC WiFi bands are 2.4Ghz. 9. Do not fly near areas with high electromagnetic fields (EMF); high voltage !ines, large scale power transmission stations, mobile base stations and broadcasting towers.

10. Do not fly the aircraft within no-fly zones specified by local laws and regulations.
6.2.4 Emergencies
1. Aborts 2. Radio failure; unresponsive to inputs (flyoff) or environmental jamming 3. Loss of visual contact with sUAS 4. Crash; ground, structures, persons 6.2.4.1 Failsafe and Return to Home (RTH)
1. Return to Horne will not work ifthe GPS signal is insufficient or GPS is not active. 2. Press the RTH Button on the remote controller to bring the aircraft back to the Home Point instead of turning offthe remote controller. · 3. Tall buildings may adversely affect the Failsafe function. Please adjust the aircraft location, altitude and speed while returning home to avoid obstacles. 4. Make sure to always fly the aircraft within the transmission range ofthe remote controller. 5. When updating the Home Point, do not block the GPS signal of the remote controller Do not update the Home Point neartal! buildings, as the GPS may be blocked and lead to an incorrect location being stored. 6. Only use the Failsafe and Return to Horne functions in case of emergency, as they may be 7. affected by the weather, the environment, or any nearby magnetic fields. 8. Set/check Failsafe altitude before each flight.

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### 20156.2.4.2 Low Battery RTH The low battery level failsafe is triggered when the battery is depleted to a point that may affect the safe return ofthe aircraft. P!C wi!! return home or land the aircraft immediately when these warnings are shown. Aircraft will automatically return to the Hopme Point if no action is taken after 10 seconds countdown.
6.2.4.3 Failsafe RTH ai!safe RTH is activated automatically if remote controller signal is lost for more than 3 seconds provided that Home Point has been successfully recorded and compass is working normally. Return home process may be interrupted and the operator can regain control of the UAS if a remote controHer signa! is resumed.

6.3 MISSION 1. Primary 2. Operating area 3. Sequence of events 4. Communications: voice or electroic comms with observer 5. Landing
6.4 DEBRIEFING Each flight shall be followed with a thorough debriefing by the PIC as soon as practical. All areas offlight should be covered, paying particular attention to those areas where any difficulty was encountered.
7.2 PREFLIGHT INSPECTION 1. Check that a!! parts are in good condition. Do not fly with aging or damaged parts. 2. Remote controller, battery and ground station device are all fu!ly charged. 3. Propellers are mounted correctly and securely. 4. Camera lens clear. Survey equipment readied 5. Memory cards inserted, if necessary. 6. Gimbal is functioning as normal. 7. Gimbal is correctly attached to the aircraft. 8. Motors can start and are functioning as normal. 9. AU firmware has been updated to the latest version.

7.2.1 Compass 1. Ensure the compass is calibrated before every flight. 2. DO NOT calibrate your compass where there is a chance of strong magnetic interference from large metal objects, parking structures, steel reinforcements underground, or under bridges. 3. DO NOT carry ferromagnetic materials with you during calibration, such as keys or mobile phones. 4. The compass shou!d always be reca!ibrated when moving from indoor spaces to outdoor spaces. MAINTENANCE
1. Check every part of the aircraft if it is violently impacted. 2. Old, chipped, or broken propellers or motors should never be used. 3. Regularly check the battery level and overall battery life. When the battery life reaches 0%, it can no longer be used. 4. After every 10 hours offlight time perform a thorough inspection of parts and components to ensure the safe operations
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USE OF CHECKLISTS
The use of checklists to assist in the proper operation of the aircraft is mandatory for all flights. Only those checklists promulgated by R&M Aerial Imagery wi!l be acceptable, including the methodology and procedures developed for checklist use by Company PICs/Observers.
The PIC completing the checklist (whether silently or by challenge) is responsible for visually checking each item on the checklist, and ascertaining that the correct action has been taken.
Certain portions of the emergency checklist are required to be accomplished immediately, from memory, during an emergency. It is the responsibility of every PIC to commit these portions to memory and review the adequacy of their recall on a frequent basis.
The checklist is not intended as a "work!ist" or a crutch to lead crewmembers through their routines of controlling aircraft systems. It is rather envisioned that PIC wil! maintain sufficient familiarity and proficiency with these routines or "flows" that the checklist can be used as a check to ensure the flows are properly accomplished.
No PIC is expected to attempt to accomplish, without omission, every detail of a flow from memory. Such an expectation would negate the rationale and practicality of using a written checklist. The proper method is to accomplish the flow to the extent possible from memory and then to utilize the checklist to ensure that any overlooked items are then accomplished. Upon completion of each individual checklist, the PIC will announce, "(Checklist Name) CHECKLIST
A checklist that cannot be completed when initiated because of an interruption or because an item on the checklist cannot yet be completed will be held untli the interruption is over or the item can be completed. It is not acceptable to skip a checklist item and then depend on memory to accomplish the item later
COLLISION AVOIDANCE Each PIC and Observer is responsible for seeing and avoiding other traffic, terrain and obstacles.

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I agree to comply with the following: DOCUMENT CUSTODY FORM OP-1
1. ! am responsible for keeping this Manual number

___ in usable and current condition, inserting revisions when received and recording revision dates and insertion instructions on the Revision Control Page. 2. ! will immediately return this manual to Fying Media if I resign my position, am terminated, or take an extended !eave of absence. (Date) (Signature)

Position:

------..**--=---=-~"-"'"'''"""------·---·-** ..---- Typed or Printed Name:

Version 

### May 201.5REVISION NOTICE OP-2
Revision Number

__ , dated becomes effective issued to --------------forbook number or Aircraft Number-·----· The person indicated above will complete the revision by removing the outdated pages and inserting the new or revised pages according to the instructions below. He will then sign and date the revision record sheet. Place the upper portion ofthis form in the manual behind the revision record sheet and return the lower portion to the Director of Operations.

Remove: Insert

Return to Director of Operations

I hereby certify that I have received, read, and fully understand the contents of the General Operations Manual Revision Number

__. I further certify that I have revised the operations manual copy in my possession as per the revision instructions.

Signature:

---------------- Date:----·

Version 2015

### September 3, 2015 Docket No FAA-2015-2118 Addendum 1 Flying Media Craig Peck, Owner 837 Willow Rd. Lancaster, PA 17601 cpeck@flyingmedia.net 717.475.2482
Description of aircraft(s) for proposed UAS operation(s):
1. AeroNavics Sky Jib -Ti-QRX4XL, multi-rotor, max. weight (including payload) is 40 lbs.

2. DJI Flame Wheel F550, multi-rotor, max. weight (including payload) is 5.5 lbs.