Liberty Productions LLC

540 West Main Street

Helena, MT 59601

1 Liberty Productions LLC

Owner: Conrad Evarts

540 W Main Street Helena, MT 59601

406

- 475

- 4994

U. S. Department of Transportation

Federal Aviation Administration

October 27, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Pa rt 11 of the Federal Aviation Regulations from : 14CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91

. 7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119( c); 14 CFR 91.121; 14 CFR 19.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b).

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Conrad Evarts , owner of Liberty Productions LLC, which owns and operates an Unmanned Aircraft System (UAS), herby applies for an exemption from the listed Federal Aviation Regulations (FAR ’ s) to al low commercial operation of it’s UAS, so long as such operations are

con ducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Commercial operations of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following mann er: A erial video and/or photography for public and/or private use including real estate marketing, television, public events, private events, cinematography and news gathering.

Liberty Productions LLC operates two DJI Inspire Professional 1 (4) blade quad copter weighing 6 pounds, 7.5 ounces (see attached manual). The UAS has a maximum airspeed of 40 miles per hour and uses a remote controller operating on frequency range of 2.400

– 2.483 GHZ. The Inspire 1 is equipped with built in ground support technolo gy that allows it to fly utilizing global positioning system (GPS) for stability, tracking, safe flight mode

and a return

- to

- home feature in the event of loss of remote control signal or critical low battery. All flights start with a preflight safety check and all flight data are recorded. The Inspire 1 is equipped with a gimbal mounted camera that sends a live video signal to the controller allowing the person in control signal to the controller allowing the person in control (PIC) to monitor real time vid eo. Flight data, speed height, distance, battery levelLiberty Productions LLC

540 West Main Street

Helena, MT 59601

2 and general aircraft conditions are also displayed during operation. The Inspire

Professional 1 battery has a maximum flight time of approximately 18 minutes and is, therefore, always returned to the o riginal takeoff point and always flown utilizing visual line of sight (VLOS). We have been training on the DJI Inspire for six months and have become proficient in all aspects of flight and safety of this UAS. Our request for exemption would allow us to of fer unique aerial photography and videography services to

our clientele.

UAS Safety Operating Parameters

We will abide by the following additional operating conditions under this exemption, which ensures a level of safety during UAS flight, including ope rating the UAS below 400 feet and within a radius of 1,000 feet from PIC always maintaining VLOS and obtaining permission from the owner/controller of any vessels, vehicles and structures when operations may be conducted closer than 500 feet to any such ve ssels, vehicles or structures. We will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard. Other safety operating parameters include:

O perate the UAS for 10

- 15 minutes, or la nd when 35% is left on battery power,

whichever comes first.

L and UAS prior to the manufactures recommended minimum level of battery powe r

. O perate the UAS during daylight hours only within VLOS.

U tilize the UAS’ GPS flight safety feature whereby it hovers and then slowly lands if communication with the PIC is lost or battery becomes critically low.

A lways obtain all necessary permissions prior to operation.

H ave procedures in place to abort flights in the event of safety breaches or potential danger.

R evie w weather reports prior to flight and never operate UAS in unsafe conditions, high wind, low clouds or conditions that hinder visibility.

O nly operate in safe environments that are strictly controlled, are away from power lines, elevated lights, airports a nd densely populated areas.

A lso conduct extensive preflight inspections and protocols during which safety carries primary importance.

The PIC will also have a minimum of five hours logged on this craft and ten hours minimum flying UAS quad copters under varying conditions and environments and will follow all safety protocol of Liberty Productions

, LLC as well as guidelines of 14 CFR 61.51(b) having the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from people.

Specific Exemptions Requested Given the size, weight, speed and limited operating area associated with the UAS, we feel an exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFRLiberty Productions LLC

540 West Main Street

Helena, MT 59601

3 91.203(a) and (b) (certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR Part

11 and Section 33 of P.L. 112

- 95 (Section333).

We request an exemption from 14 CFR 45.23 Marking of the Aircraft because the UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two

- inch lettering is difficult to place on such a small aircraft wit h dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the work “Experimental” on its fuselage as required by 14 CFR 45.29(f) so that anyone will see the markings.

We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command. The applicant’s UAS do not carry any pilots or passengers not property. The Risks attendant to the operation of the UAS is far less than

the r isk levels inherent in the commercial activities outlined in 14CFR 61. The operation and limitations in the flight operation manual (FOM) will equate to the safe operations of

the UAS.

We request an exemption from 14 CFR 91.7(a) which prohibits the operat ion of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is in applicable. We request an exemption from 14 CFR 91.405(s), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2) and 14 C FR 91.417 (a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution, we will perform a preflight inspection of the UAS before each flight as outlined in the attached operating d ocuments.

We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft, however, since there are no pilots or passengers on board the aircraft, and given its size, this regulation is inapplicable. We believe an equivalent of level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.

We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated Instrument Flight and Certain Flight Tests. The regulation states that “no pers on may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls”. Although the DJI Inspire Professional 1 is capable of dual/linked controls, we will be operating with a single remote contr oller.

We request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the operation of civil aircraft, but allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above 400 feet above grou nd level (AGL). The DJI Inspire Professional 1 has a built in regulator to keep the UAS at or below 400 feet AGL, and it is company policy that the regulator will not be overridden. We will also only operate in safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or below this in relation to minimum safeLiberty Productions LLC

540 West Main Street

Helena, MT 59601

4 altitudes”. Given the size, weight and maneuverability and speed of the UAS, an equivalent or higher level of safety will be achieved.

We request an exempti on from 14 CFR 19.121 Altimeter Settings, as it is inapplicable since the UAS utilizes electronic GPS with barometric sensor. We request an exemption from 14 CFR 91.151(a) Fuel Requirements for Flight in visual flight rules (VFR)

conditions. The UAS is 100 percent electric and two low battery alerts are issued

– per the operating documents, the UAS will be landed at the first alert. Also, our flights will last only 10

– 15 minutes each and the UAS has an automated function, which results in

immediate landin g when a low battery is detected. The PIC will not begin a flight unless, considering wind and forecast weather conditions, there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UAS with 3 5

percen t batter y power remaining.

Summary

We will comply with all of the following conditions and limitations should this grant of exemption be provided:

O perations will be limited to the following aircraft described in the operating documents which is a quad

- r otor aircraft weighing less than seven pounds: DJI Inspire Professional 1 Aircraft System.

T he UAS will not be flown at an indicated airspeed exceeding 40 mph.

T he UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by the pro cedures specified in the operating documents.

T he UAS will be operated within VLOS of the PIC at all times.

A ll operations may utilize a visual observer (VO). The UAS will be operated within the

VLOS of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents.

T he operating documents will be accessible during the UAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request.

P rior to each flight, the PIC will ins pect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the

UAS is found to be in a c ondition for safe flight. The G r ound Control Station will beLiberty Productions LLC

540 West Main Street

Helena, MT 59601

5 included in the preflight inspection. All maintenance and alterations will be properly

documented in the aircraft records.

A ny UAS maintenance or alterations that affect the UAS operation or fli ght characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry into the

aircraft records.

T he pre

- flight inspection section in the operating d ocuments will account for all discrepancies i.e. inoperable components, items or equipment not already covered in the relevant sections of the operating documents.

W e will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacemen t, inspections and life limit requirements.

W e will carry out maintenance, inspections and record

- keeping requirements, in accordance with the operating documents. Maintenance, inspection and alterations will be noted in the aircraft records, including to tal flight hours, description of work accomplished and the signature of the authorized person returning the UAS to service.

E ach UAS operated will comply with all Manufacturer Safety Bulletins.

A n authorized person will make an entry in the aircraft reco rd of the corrective action taken against discrepancies discovered between inspections.

T he PIC will also meet the flight review requirements specified in 14 DFR 61.56 in an

aircraft in which the PIC is rated on.

P rior to operations conducted for the pu rpose of aerial videography/cinematography, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of five hours as an UAS pilot operating the make and model of the UAS to be used in operations.

T he PIC will not o perate the UAS for purpose of aerial videography/cinematography, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b) , the ability to safely operate the UAS in a manner consistent with the operating documents, including ev asive and emergency.

U AS operations will not be conducted during night hours, as defined in 14 CFR1.1. All operations will be conducted under visual meteorological conditions (VMC).

T he UAS will not operate within five nautical miles of an airport refere nce point as

denoted on a current FAA

- published aeronautical chart.Liberty Productions LLC

540 West Main Street

Helena, MT 59601

6 T he UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than three statute miles from the PIC.

I f a UAS loses c ommunications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

T he PIC will abort a flight in the event of unpredicted obstacles or e mergencies in accordance with the operating documents.

T he PIC will not begin a flight unless, considering wind and forecast weather conditions, there is enough power to fly at a normal cruising speed to the intended landing point and

land the UAS with 3 0 percent battery power remaining.

B efore conducting operations, the radio frequency spectrum used for operation and control of the UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requireme nts.

T he documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to the PIC at the Ground Control Station of the UAS at any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement

off icial upon request.

T he UAS will remain clear and yield the right of way to all manned aviation operations

and activities at all times.

T he UAS will not be operated by the PIC from any moving device or vehicle.

T he UAS will not be operated over congeste d or densely populated areas unless

contracted out to do events. Due to the nature of our business, the majority of the UAS operations will be in rural and remote locations.

T he UAS will not be used for hunting purposes as the company adheres to a strict “fair

chase ” hunting standard

. We will contact state fish and game departments where use will occur to ensure we are in compliance prior to our arrival on location.

F light operations will be conducted at least 500 feet from all nonparticipating persons,

v essels, vehicles and structures unless:

B arriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. We will ensure that nonparticipating person remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations must cease immediately.Liberty Productions LLC

540 West Main Street

Helena, MT 59601

7 T he aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vess els, vehicles or structures has granted permission 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.

O perations near to the PIC, VO, operator trainees or esse ntial persons do not present an undue hazard to those persons per 14 CFR 91.119(a).

O perations conducted over private or controlled

- access property will be with permission from the land owner/controller or authorized representative. Permission from land

o wner/controller or authorized representative will be obtained for each flight to be

conducted. On public land, proper permits will be in place and prior clearance from state or federal agencies will be obtained for each flight to be conducted.

A ny inciden t, accident or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable certificate of authorization (COA) will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours.

Acci dents will be reported to the National Transportation Safety Board (NTSB) per

instructions contained on the NTSB website: www.ntsb.gov

.

I would like to thank you for your consideration in granting this exemption for Li berty

Productions LLC.

Signed,



### Conrad Evarts

Conrad Evarts , Owner Liberty Productions LLC