Images ofSommer 401 

### E. Ring Factory Road Bel Air, Maryland 21014 info@billrettberg.com
August 14, 2015

U. S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part21;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 Siror Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Images ofSommer, developer and operatorofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photographyforthe motion picture, television and commercial video industry, hereby applies 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 underthe conditions outlined herein oras may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permitthe operation of small, unmanned and relatively inexpensive sUAS undercontrolled conditions in airspace that is 1) limited 2) predetermined 3) controlled asto access and 4) would provide safety enhancementstothe already safe operations in the film and television industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety andfulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "

...establish requirementsfor the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act.

The name and address ofthe applicant is:
Images of Sommer Ph: 410-893-3620 Email: info@billrettberg.com Address: 401 

### E. Ring Factory Road, Bel Air, Maryland, 21014



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• Built in No Fly Zone Database, with no-fly perimeters around all airports.(See AppendixA)

All flights will occur over private orcontrolled access property with the property owner's prior consent and knowledge. Filming will be ofpeople who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place.

Satisfaction ofthe criteria provided in Section 

### 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security- provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofapplicant's UAS in the motion picture and television industry pursuantto the Manual appended hereto.

Sincerely

# ~4L William Rettbe Images ofSommer

11Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) ' 14CFR 91.9 (b) (2) 14C.F.R. 91.103 14 C.F.R. 91.109 14C.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 expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This lawdirectsthe Secretary ofTransportation to considerwhethercertain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do notcreate a hazard to users ofthe NAS orthe public orpose athreatto national security in light ofthefollowing:

• The UAS's size, weight, speed, and operational capability;
• Operation ofthe UAS in close proximity to airports and populated
• Operation ofthe UASwithin visual line ofsight ofthe operator.

Reform Act § 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." ld. §333(c) (emphasis added) A

AApplicant interprets this provision to place the duty on the Administratorto notonly process applications for exemptions undersection 333, butfortheAdministratorto craft conditions forthe safe operation ofthe UAS, ifit should be determined thatthe conditions setforth herein do notfulfill the statutory requirements for approval.



### 2The Federal Aviation Act expressly grantsthe FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

TheAdministrator may grant an exemption from a requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administratorfinds 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).

Images ofSommer's sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. Theywill operate only in line ofsight and will operate only within the sterile area described in the Flight Safety Manual, attached as Exhibit B (hereinafter "the Manual"). Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." 8

Given the small size ofthe sUASs involved and the restricted sterile environmentwithin which they will operate, the applicantfalls squarelywithin that zone ofsafety (an equivalent level of safety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations of UASsto commence immediately. Also dueto the size ofthe UASs and the restricted areas in which the relevant 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 of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant 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 havethe characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent oreven higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancementto the already safe movie and television filming operations conducted with conventional aircraft.

8 Reform Act Section 333 (b).



### 3These limitations and conditions towhich Images ofSommer agreesto be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flightswill be operated within line ofsight ofa pilot and/or observer. 3. Maximum total flight time for each operational flightwill be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur priorto the 25 minute limit.

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

5. Minimum crewfor each operation will consist ofthe sUAS Pilot, the Visual Observer, and the Camera Operator.

6. sUAS pilotwill be an FAA licensed airman with at least a private pilot's certificate and third class medical. The observerwill hold at least athird class medical.

7. sUAS Pilotwill be Pilot in Command (PIC). 8. The UAS will only operatewithin a confined "Sterile Area" as defined in the Manual. Section C ofthe Manual requires the establishment ofa "Security Perimeter" forthe flight operations
area.

9. A briefing will be conducted in regard to the plannedsUAS operations priorto each day's production activities. Itwill be mandatorythat all personnel whowill be performing duties within the boundaries ofthe safety perimeter be presentforthis briefing.

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

11. The operatorwill obtain the consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 100feet oftheflight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required by Section F ofthe Manual. With the advanced permission ofthe relevant FSDO, operations at closer range can be approved. (See Section Bin the Manual Appendix B)

12. The operatorwill submit a written Plan ofActivities tothe FSDO three days before the proposed shoot as required in Section C ofthe Manual.

13. Pilot and observerwill have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated as required Sections G ofthe Manual.

14. Observerand pilot will at all times be able to communicate by voice. 15. Written and/ororal permission from the relevant property holderswill be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, orother 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 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}
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1 ). Given the size and



### 4limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meetsthe 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 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 ofthe particular UAS. In all cases, an analysis ofthese criteria demonstratesthatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuantto the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation as is nowdone.with conventional filming. The FAAwill have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threat to national security posed by the UAS, dueto its size, speed ofoperation, location of operation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. 

### § 45.23 (b). Marking ofthe Aircraft

The regulation requires:

When marks include onlythe 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 neareach entrance to the cabin, cockpit, or pilot station, in letters not lessthan 2 inches nor morethan 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 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 ofthe sUAV, two-inch lettering will be impossible. Theword "Experimental" will be placed on the fuselage in compliance with §45.29 

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

### (f) where the pilot, observer and others working with the sUAV



### 5will seethe identification ofthe UAS as "Experimental." The FAA has issuedthe following exemptions to this regulation to Exemptions Nos. 10700, 8738, 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 ofcurrent operations by requiring the PIC operating the aircraft to have a private pilot's license ratherthan a commercial pilot's license to operatethis small UAS. Unlike a conventional aircraftthat carries the pilot and passengers, the sUAS is remotely controlled with
no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as setforth 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 aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot as the PIC exceeds the present level ofsafety 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 operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be 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 lists priorto each flight, as set forth in Sections C 

### & D, an equivalent level ofsafetywill be provided.

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

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

... (2) Forwhich 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 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 because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.



### 6The equivalent level ofsafetywill be maintained by keeping the flight manual atthe ground control pointwherethe pilot flying the sUAS will have immediate accessto it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A,9565,9565B, 10167, 10167A,10602,32827,and10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command totake certain actions before flight to insure the safety offlight. As FAAapproved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level of safety will be provided as setforth in Sections D ofthe Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.

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

Section 91.103 providesthat no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction 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 ofa control boxthat communicates with the aircraft via radio communications. The FAA has approved exemptions forflight training without fully functional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided bythe factthat neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. Safe simulation and practice 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 operation ofcivil aircraft. Section 91.119 (d) allows helicoptersto be operated at lessthan the minimums prescribed, provided the person operating the helicopter complies with any route oraltitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopterand the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allowsuch operations. As setforth herein, exceptforthe limited conditions stated in the Manual, the UAS will never operate at higherthan 400 AGL. Itwill however be operated in a restricted areawith security perimeter, where buildings and peoplewill not be exposed to operationswithout their pre-obtained consent.



### 7The equivalent level ofsafetywill be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. Noflightwill be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance noticeto the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations as set forth in Section C ofthe Manual. Compared to flight operations with aircraft or rotorcraftweighting far morethan the maximum 551bs. 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 low-altitude operations ofthe sUAS will ensure separation between these smaiiUAS operations and the operations ofconventional aircraftthat must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport oran appropriate altimeter setting available before departure." Asthe sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Checklist, 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 VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecastweather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed- (1) During the day, tofly afterthatfor at least 30 minutes; or (2) At night, tofly afterthat for at least 45 minutes."

The battery powering the sUAS provides approximately 40 minutes ofpowered flight. To meet 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 of its proposed operations within a predetermined area, a longertime 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, with less than 30 minutes of reserve fuel, does not engenderthetype of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10 minuteswould greatly reduce the utilityfor which the exemption will be granted.



### 8Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 25 minutes or25% of battery power whichever happens first. This restriction would be more than adequateto return the sUAS to its planned landing zone from anywhere in its limited operating
area.

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 pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it haswithin it the following:
(1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance sothat it is legible to passengers or crew.

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 orto display them on the sUAS.

An equivalent level ofsafety will be achieved by keeping these documents atthe ground control pointwherethe pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative 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): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected
as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter.

..," and others shall inspect or maintain the aircraft in compliance with Part43.

Given thatthese section and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not apply to the applicant. Maintenancewill be accomplished by the operator pursuantto the flight manual and operating handbook as referenced in the Manuai.(See Sections B, D and G) An equivalent level ofsafety 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 oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feetAGL. As provided in the



### 9Manual, the operatorwill ensurethatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suited to maintain the aircraft in
an airworthy condition to provide the equivalent level ofsafety.

Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:
Applicant seeks an exemption from thefollowing 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 (551bs or less) in motion picture and television operations.
Approval ofexemptions allowing commercial operations ofsUASs in the film industrywill enhance safety by reducing risk. Conventional film operations, usingjet or piston power aircraft, operate at extremely low altitudesjustfeet from the subject being filmed and in extreme proximityto people and structures; and present the risks associated with vehicles that weigh in the neighborhood of4,0001bs., carrying large amounts ofjetA orotherfuel (140 gallons forjet helicopters shown below). Such aircraft mustfly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried tothe film set and notflown. The sUAS will carry no passengers or crew and, therefore, will not exposethem to the risks associated with manned aircraftflights.

The operation ofsmall UASs, weighting lessthan 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicantfrom the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close tothe ground, and in a sterile environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximityto the ground and people.



### UASs Details: See Appendix 8

Safety Features:
• Emergency "Return-To-Home" 

### I One-Key Go-Home

o Atthe beginning ofeach flight a home point is set. This home point is set in accordance with the manualto allowfor a safe takeoffand return. Should the pilot's control lose signal with the UAS

10

### 2. Blades visually checked for any damage at all 

### 3. Battery checked for damage 

### E. Mid-Air Safety Protocol
a. Max Speed i. Accent 1. 6m/s ii. Decent 

### 1. 2m/s iii. Flight Speed 1. The UAS is neverto exceed 1Om/s 

### b. Altitude i. The UAS is neverto exceed 400ft 

### c. Emergency i. If it appearsthat the UAS, any property or humans are at risk, the UAS will be grounded immediatelyto a safe location. 

### d. Sight i. The pilot must keep the UAS within eyesight at all times unassisted by anytechnology. 

### F. Participation by non-pilot staff
a. All staff involved in the production orfilming using the UAS will consent to maintain a safe distance ofat least 30ft during the filming. 

### G. Pilot/SpotterTraining
a. Before flying, both the Pilot and spotterwill receive updated information on the UAS and its firmware. 

### i. The controller allows for a simulatortraining, both the pilot and spotter are allowed to run through the simulatortraining



### 168. At least 5 nautical miles from the nearest airport or helipad. 

### D. Pre-Flight Checklist


### a. Take Off Location/"Home" 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 ifthe pilot signalsthe 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 offand land in the same**location~** 3. GPS Altimeterwill be marked as 0' elevation 

### b. Flight Canceling Events i. All flights will be cancelled for a minimum of2 hours ifany ofthe below
occur: 1. Police activity in the area 2. Lowflying aircraft in the area 3. Medical/News Helicopters active in the area 4. Wind exceeding 10 mph 5. Any emergency requiring emergency services occurswithin the sterile environment 6. PIC is unableto complete flight without losing visual ofthe UAS 7. Any precipitation 8. Heavy bird presence in the area that could cause a mid-air collision. 9. Any defects ordamagefound during preflight exam 

### c. Physical Inspection i. Before each flight the UAS will be checked to ensurethat it is safe for flight. 1. Battery voltage will be checked to ensure it is >75% 2. Bladeswill be inspected to ensure 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 damagethat 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 damagethat could affect its charge ii. Ifany party ofthe inspecting shows 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 forany damage that occurred in flight. 1. Body inspected for any damage

15

### Appendix 8: 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. Ifany maintenance is undergone, the UAS must pass a flight test with both a pilot and a manufacturertrained technician beforeflight. 

### 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 operatorwill file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office. 

### b. Safety Parameter 

### i. Before filming occurs, a 100 yard perimeterfrom the planned flight path will be identified in orderto set a "sterile" environment forthe operation. 1. Images ofSommer must obtain written or oral permission from all landowners in sterile environment. 2. 48 hours before filming, all residents or businesses within 100 yards ofthefilming will be notified with printed flyers.
a. Flyers will contain date offlight, time offlight, and contact information. 3. Streets and sidewalks that cross intothe sterile environmentwill be marked with 'Warning Lowflying Aircraft

- Stay Back 150ft" signs towarn the public. 4. At all times Images ofSommerwill carry $1mm in general liability insurance in case ofany damage to property orpersons within the safety parameter


### c. Identify potential obstacles i. Before each flight, an inventorywill be taken for all potential obstacles that must be avoided while in flight. Including: 1. Powerlines 2. Cell Phone Towers 3. Trees 4. Flocks ofbirds that may take flight 5. Heavilytraveled roadways 6. Utility wires 7. Elevated structures



### 14Baltimore/Washington International J't<tlserm;e

Washington DC/ Andrews Air Force BaseAirport !1art-i Isla



### 13

# Appendix A: Maryland No-Fly Zones

The below no-flyzones are built into the crafts firmware. The No-Fly zones are broken down into 2 categories: red and blue. The red zones are around larger airports and as an added layer of security the UAS cannot take offfrom within the Red zone (1.5 miles radius). With smaller airports(blue), the UAS will be unable to fly ortake offwithin 0.6mi for the restricted area. Although these zones show areas where the UAS is unable to fly, Images of Sommer's Pilots will not operating within 5 nautical miles of any airport.

As a safety precaution, Images of Sommer's pilots will not operating within 5 nautical miles of any airport similarto the permission granted in Exemption No. 11153

- Regulatory Docket No. FAA20140519, page 25, "20. The UA maynotoperate within 5 nauticalmiles ofan airpott reference pointas denoted on a current FAA-publishedaeronautical chartunless 

### a letterof agreement with that airports managementis obtained, and the operation is conducted in accordance with 

### a NOTAM as requiredbythe operators COA. The letterofagreement with the airportmanagementmustbe made available to the Administratorupon request."

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

!mages ofSommer requests the same flexibility as exemptions 11153 and 11195for acquiring agreementwith the airports' management should operations fall within 5 nautical miles ofan airport. 

### Firmware Restricted Zones

12

### Appendix B : UAS Information

DJI Phantom

Model: Phantom 

### Ill Professional S/N: P77DCF17013865

See

### AppendixC 

### forusermanual

17