1 A Clean Environment
Stan Potter
2071 Cimmaron Road Wilson, Oklahoma 73463 spotter@a-clean.net

October 16, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernizat ion and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, A Clean Environm ent, developer and operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial data collec tion and aerial photography for the commercial video industry, hereby appl ies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the reques ted exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the aerial filming and monitoring industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administ rator’s) responsibilities to “...establish requirements for the safe operation of such aircraf t systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:
A Clean Environment
Stan Potter
Ph: 817-360-2993 Email: spotter@a-clean.net Address: 2071 Cimmaron Road, Wilson, Oklahoma, 734632 Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F. R. 91.119
14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This exemption application is e xpressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This la w directs the Secretary of Transportation to consider whether certain unmanned aircraft sy stems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of
UASs do not create a hazard to users of the N AS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close p roximity to airports and popul ated • Operation of the UAS within visu al line of sight of the opera tor.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secre tary shall establish requirements for the safe operation of such aircraft in th e national airspace system.” Id . §333( c) (emphasis added) A

_________________________________________________________________________ A Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to cr aft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.3 The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from th e requirement that all civil aircraft must have a
current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

A Clean Environment ’s sUASs are rotorcraft, weighting 55 or fewer lbs. including p ayload. They operate, under normal conditions at a s peed of no more than 50 knots and have the capability to hover, and move in the vertical an d horizontal plane simultaneously. They will operate only in line of sight an d will operate only within the ster ile area described in the Flight Safety Manual, attached as Exhibit B (hereinafte r “the Manual”). Such operations will insure
that the sUAS will “not create a hazard to users of the nationa l airspace system or the public.” B

Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envi sioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents
no national securi ty issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act , as amended; the strong equivalent level of safety surrounding the proposed operations, an d the significant public benefit, including enhanced safety, reduction in environmental im pacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant of the requested exemptions is in the public interest. Accordingly, the applic ant respectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed he rein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe movie and television filming operat ions conducted with conventional aircraft.

__________________________________________________________________________ B Reform Act Section 333 (b).4 These limitations and conditions to which A Clean Environment agrees to be bound when conducting commercial operations unde r an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to th e 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consis t of the sUAS Pilot, the Visual Observer, and the Camera Operator.

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

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

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualificatio ns, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC.

8. The UAS will only operate with in a confined “Sterile Area” a s defined in the Manual. Section C of the Manual requires the est ablishment of a “Security Perim eter” for the flight operations

area.

9. A briefing will be conducted in regard to the planned sUAS o perations prior to each day’s production activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office.

11. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivale nt level of safety determination, as required by Section F of the Manual. With the advanced permission of the relevant FSDO, operations at closer range can be approved. (See Se ction B in the Manual Appendix B)

12. The operator will submit a written Plan of Activities to the FSDO three days before the proposed shoot as required in Section C of the Manual.

13. Pilot and observer will have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated as required. 14. Observer and pilot will at all time s be able to communicate by voice. 15. Written and/or oral permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fi re, or other appropriate governmental agencies.

17. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre-determined location wi thin the Security Perimeter and land.

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

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)5 Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as requ ired by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11
and Section 333 of the Reform Act. The Fede ral Aviation Act (49 U.S.C.§44701 (f)) and
Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and unde r the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an
airworthiness certificate without the re strictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. full y loaded, carries ne ither a pilot nor passenger, carries no explosive materials or flam mable liquid fuels, an d operates exclusively
within a secured area as set out in the Manual. Un like other civil aircraft, operations under this exemption will be tightly controlled and moni tored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in c onnection with motion picture and television production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthin ess certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same cr iteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flam mable liquid fuels, and inability to carry a
substantial external load.

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

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display
on that aircraft near each en trance to the cabin, cockpit, or pilot station, in letters
not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimenta l," or "provisional," as applicable.

Even though the UAS will have no airworth iness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two -inch lettering will be imp ossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).6 The equivalent level of safety will be pr ovided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pi lot, observer and others working with the sUAV will see the identification of the UAS as “Experimental.” The F AA has issued the following exemptions to this regulation to Exempt ions Nos. 10700, 87 38, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring t he PIC operating the aircraf t to have a private pilot’s license rather than a commercial pilot’s license to operate thi s small UAS. Unlike a conventional aircraft that carries the pilot and pa ssengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraf t. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when dra fted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

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

The regulation requires that no person may oper ate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standa rd will exist for determining airworthiness. Given the size of the aircraft and the requirem ents contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections C & D, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraf t Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in th e aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any
combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only becaus e there is no pilot on board, bu t because there is no room or capacity to carry such an item on the aircraft.7 The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regu lation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcra ft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth
in the Manual. The PIC will take all actions in cluding reviewing weather, flight battery requirements, landing and takeoff distances and ai rcraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may op erate a civil aircraft (except a manned free balloon) that is being used for flight instructio n unless that aircraft has fully functioning dual
controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has appr oved exemptions for flight training without fully functional dual controls for a number of ai rcraft and for flight inst ruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passe ngers will be carried in the ai rcraft and by the size and speed
of the aircraft.

Safe simulation and pr actice flight will be carried out in controlled environments. All simulations will be carried out on a computer using the drone controls. Any practice flying will take place in a safe environment, with no risk to human life below.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for op eration of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 40 0 AGL, or not more than 200 abo ve an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein the UAS will never operate at higher than 400 AGL. It will however be operated in a restricted area with security perimeter, wher e buildings and people will not be exposed to operations without their pre-obtained consent.8 The equivalent level of safety will be achiev ed given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local official s. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the lowaltitude operations of the sUAS will ensure separation between these small-UAS operations and the operations of conven tional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by
reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUA S may not have a barometric altimeter, but instead a GPS altitude read out, an exem ption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Checklist, confirming the altitude of the launch site sh own on the GPS altitude indicator before flight.

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

Section 91.151 (a) prohibits an i ndividual from beginning “a fl ight in an airplane under VFR conditions unless (considering wi nd and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

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

The battery powering the sUAS provides approxim ately 25 minutes of powered flight. To meet the 30 minute reserve requir ement in 14 CFR §91.151, sUAS flights would be limited to approximately 2 0 minutes in length. Given th e limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermine d area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exempt ion from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lock heed 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 wh o have signed waivers will be allowed, with less than 30 minutes of reserve fu el, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 20 minute s would greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivale nt level of safety can be achiev ed by limiting flights to 20 minutes or 25% of battery power whichever happens first. This re striction would be more than9 adequate to return the sUAS to its planned landin g zone from anywhere in its limited operating

area.

Similar exemptions have been granted to othe r operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no pe rson may operate a civil aircraft unless it has within it the following:

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

(b) No person may operate a civil aircra ft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lb s and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display
them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has is sued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspect ed as prescribed in subpart E of this part and shall between required in spections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43
of t his chapter...,” and others shall inspect or maintain the aircr aft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applican t. Maintenance will be accomplished by the operator pursuant to the flight manual an d operating handbook as referenced in the Manual.(See Sections B, D and G) An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no high er than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the10 operator is the person most familiar with the airc raft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summ ary is provided for publication in the Federal Register, should it be determin ed that publication is needed:

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in motion picture and television operations.

Approval of exemptions allowing commercial op erations of sUASs in the film industry will enhance safety by reducing ri sk. Conventional film operatio ns, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and structures; and pres ent the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters shown below). Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. an d powered by batteries e liminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the film set and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environmen t and, as a result, are far safe r than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

UASs Details: See Appendix C

Safety Features:

● Emergency “Return -To-Home ”

○ At the beginning of each flight a home point is set. This homepoint is set in accordance with the manual to allow for a safe takeof f and return. Should the pilot’s control lose signal with the UAS or manually request a return, the UAS will return to the starting point. (Not available on UAS #2, see Appendix C)12 

# Appendix A: No-Fly Zones

A Clean Environment ’s Pilots will not be operating within 5 nautical miles of any airport.

As a safety precaution , A Clean Environment ’s pilots will not be operating within 5 nautical miles of any airport similar to the permission granted in Exemption No. 11153 - Regulatory Docket No. FAA20140519, page 25, "20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a curr ent FAA-published aeronau tical chart unless a letter of agreement with that airports management is obtained, and the operation is conducted in accordance with a NOTAM as required by th e operators COA. The lett er of agreement with the airport management must be made available to the Administrator upon request."

As well as in Exemption No. 11195 - Regulatory Docket No. FAA20140884, page 12, "19. The UA may not operate within 5 na utical miles of an airport re ference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airports management is obtained, and the operation is conducted in accordance with a Notice to Airmen (NOTAM), as required by the operators Ce rtificate of Waiver or Authorization (COA). The letter of agreement with the airport ma nagement must be made available to the Administrator upon request."

A Clean Environment requests the same flex ibility as exemptions 11153 and 11195 for acquiring agreement with the airports' management should operations fa ll within 5 nautical miles of an airport.13 Appendix B: Safety Manual

A. Maintenance a. The UAS must be inspected by a factory trained technician every 10 flight hours.
All maintenance records will be maintained for inspection as set forth in Section

B. b. If any maintenance is undergone, the UAS must pass a flight test with both a pilot
and a manufacturer trained te chnician before flight. B. Record Keeping a. A digital record will be kept for all flights, flight times, and maintenance records. C. Securing Flight Site
a. FSDO Submissions i. The UAS operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight
Standards District Office. b. Safety Parameter i. Before filming occurs, a 100 yard pe rimeter from the planned flight path
will be identified in order to set a “sterile” environment for th e operation. 1. A Clean Environment must obtain written or oral permission from
all landowners in sterile environment. 2. 48 hours before filming, all residents or businesses within 100 yards of the filming will be notified with printed flyers. a. Flyers will contain date of flight, time of flight, and contact
information.
3. Streets and sidewalks that cross into the sterile environment will be marked with “Warning Low flying Aircraft - Stay Back 150ft” signs to warn the public.
4. At all times A Clean Enviro nment will carry $1mm in general liability insurance in case of an y damage to property or persons within the safety parameter

c. Identify potential obstacles i. Before each flight, an inventory wi ll be taken for all potential obstacles that must be avoided while in flight. Including:
1. Powerlines
2. Cell Phone Towers
3. Trees 4. Flocks of birds that may take flight 5. Heavily traveled roadways 6. Utility wires
7. Elevated structures 8. At least 5 nautical miles from the nearest airport or helipad. D. Pre-Flight Checklist

a. Take Off Location/ “Home”14 i. The UAS will mark its take off location as a safe area to return to should the UAS lose signal with the control or if the pilot signals the craft to
return to its “home” location. *
1. Take off location will be in an area with a 25ft radius with no obstructions, maintaining said radius vertically 200ft.
2. The UAS will take off and land in the same location.

3. GPS Altimeter will be marked as 0’ elevation *This feature is not applicable with UAS #2 as show in Appendix C
b. Flight Canceling Events i. All flights will be cancelled for a minimum of 2 hours if any of the below

occur: 1. Police activity in the area 2. Low flying aircraft in the area 3. Medical/News Helicopters active in the area 4. Wind exceeding 10 mph 5. Any emergency requiring emergency services occurs within the
sterile environment 6. PIC is unable to complete flight without losing visual of the UAS 7. Any precipitation 8. Heavy bird presence in the area that could cause a mid-air
collision. 9. Any defects or damage found during preflight exam c. Physical Inspection i. Before each flight the UAS will be checked to ensure that it is safe for flight. 1. Battery voltage will be checked to ensure it is >75% 2. Blades will be inspected to ensu re they are tightened and free of damage 3. Camera mount and gimbal will be inspected to ensure it is fully attached and operating. 4. UAS will be checked for any damage that may have taken place in
transit.
5. The UAS will be tested at a low altitude to ensure all controls are responding correctly. 6. Battery checked for damage that could affect its charge ii. If any party of the inspecting show s a damaged part or parts, the UAS is
deemed non-usable and must be inspected by a factory trained
technician./
d. Post Flight Inspections/Checklist i. After each flight, the the UAS will be thoroughly inspected for any damage that occurred in flight. 1. Body inspected for any damage 2. Blades visually checked for any damage at all 3. Battery checked for damage15 E. Mid-Air Safety Protocol a. Max Speed

i. Accent
1. 10m/s
ii. Decent
1. 4m/s iii. Flight Speed
1. The UAS is never to exceed 10m/s
b. Altitude
i. The UAS is never to exceed 400ft c. Emergency i. If it appears that the UAS, any pr operty or humans are at risk, the UAS will be grounded immediately to a safe location. d. Sight i. The pilot must keep the UAS within eyesight at all times unassisted by any technology. F. Participation by non-pilot staff a. All staff involved in the production or filming using the UAS will consent to maintain a safe distance of at least 30 ft during the filming. G. Pilot/Spotter Training a. Before flying, both the Pilot and spotter will receive updated information on the
UAS and its firmware. i. The controller allows for a simulator training, both the pilot and spotter are allowed to run through the simulator training16 Appendix C
UAS #1: DJI

See Appendix D for user manual

Model: Phantom III

UAS #2: Delta

Model: FW70 fixed wing

This UAS is customized but comp lies with all restrictions set forth in this petition for exemption.17 Appendix D: User Manual18192021222324252627282930313233343536373839404142434445464748495051525354555657585960616263646566676869707172737475