1

Dunnlights Inc

Richard Dunn 116 Copper Hills Drive

Canton

, Georgia 30114 dunnlights@aol.com

Dec ember 2 , 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 o r Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Dunnlights Inc , developer and operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to condu ct aerial electronic data collection c and aerial photography for the c ommercial 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 ar e 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 requested exemption would permit the operation of small, unmanned and relatively inexpensive sUA S 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 Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

c Aerial Data Collection” which includes any remote sensing and measuring by an instrument(s) aboard the
UA. Examples i nclude imagery (photography, video, infrared, etc.), electronic measurement (precision sur veying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments

aboard the UA2

The name and address of the applicant is: Dunnlights Inc

Richard Dunn

Ph: 678

- 761

- 2366

Email: dunnlights@aol.com

Address: 116 Copper Hills Drive

, Canton

, Georgia

, 30114

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 expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely i n 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

sUAS s do not create a hazard to users of the NAS or t he public or pose a threat to national security in light of the following:

• The s UAS’s size, weight, speed, and operational capability; • Operation of the s UAS in close proximity to airports and populated areas • Operation of the s UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 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 sect ion 333, but for the Administrator to craft conditions for the safe operation of the s 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 th e 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 the requirement that all civil aircraft must have a

current airworth iness 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).

Dunnlights Inc ’s sUASs are rotorcraft, weighting 55 or fewer 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. They will operate only in line of sight and will operate only within the sterile area described in the Flight Safety Manual, attached a s Exhibit B (hereinafter “the Manual”). Such operations will insure that the sUAS will “not create a hazard to users of the national 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 envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the siz e of the s UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as ame nded; 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 s UASs for commercial vi deo operations, the grant of the 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 th at the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. 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 commercial video filming operations conducted with conventional aircraft.

__________________________________________________________________________ B Reform Act Section 333 (b).4

These limitations and conditions to which Dunnlights Inc agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lb s. 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 the 2 0 minute li mit. 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 consist of the sUAS Pilot, the Visual Observer, and

th e 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 driver’s license. 7. sUAS Pilot will be Pilot in Command (PIC). If a pilot c ertificate 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 s UAS will only operate within a confined “Sterile Area” as de fined in the Manual. Section C of the Manual requires the establishment of a “Security Perimeter” for the flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations 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 t he 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 equivalent 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 Section B in the Manual Appendix B)

12. The oper ator will submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The three

- day notification may be waived with the concurrence of

the FSDO. 13. Pilot and observer will have been trained in operation of s U AS generally and received up

to

- date information on the particular s UAS to be operated as required. 14. Observer and pilot will at all times 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, fire, or other appropriate governmental agencies.

17. If the sUAS loses communications or loses its GPS signal, the s 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)5

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited ope rating 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 Federal 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 s UAS. In all cases, an analysis of these criteria demonstrates that the s UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventio nal aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area as set out in the Manual. Unlike other civi l aircraft, operations under this exemption will be tightly controlled and monitored 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 th e 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 connection with motion picture and television production, provide a greater degree of safety 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 of these same criteria demonstrates that there is no credibl e threat to national security posed by the s UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a

substantial external load.

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

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 mu st also display on that aircraft near each entrance 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," "experimental," or "provisional," as applicable.

Even though the s UAS will have no airworthiness certificate, an exemption may be

needed as the s 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 be6

impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and othe rs working with the sUAV

will see the identification of the s UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

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

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the s UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations b y requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small s UAS. Unlike a conventional aircraft that carries the pilot and passengers, 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 aircraft. 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 d rafted, 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 pers on may operate 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 standard will exist for determining airworthiness.

Given the siz e of the aircraft and the requirements 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 Aircraft Fli ght 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 the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof.7

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not on ly because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sU AS will have immediate access to it. The FAA has issued the following exemptions to this regulation: 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 r equires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft 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 including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

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

Section 91 .103 provides that 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 f ully 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 approved exemptions for flight training without fully functional dual controls for a nu mber of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed

of the 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 li fe below.

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the he licopter 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 400 AGL, or not more than 200 above an elevated pla tform from which filming is planned, an exemption may be needed to allow such operations. As set forth

herein the s UAS will never operate at higher than 400 AGL. It will however be operated in a8

restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the s UAS as well as the location where it is operated. No flight will be taken without the permis sion of the property owner or local officials. 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 fli ght 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 low

altitude operations of the sUAS will ensure separation between these small

- UAS operations and the operations of conventional 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 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 altitu de of the 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 under VFR

conditions unless (considering wind 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 f or at least 45 minutes.”

The battery powering t he sUAS provides approximately 2 5 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights wou ld be limited to approximately 2 0 minutes in length. Given the limitat ions on the s UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small s UAS, in a tightly controlled area where only people and property owners or offici al representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small s UAS. Additionally, limiting s UAS flights to 2 0 minutes would greatly reduce the utility for which the exemption will be granted.9

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 2 0 minutes or 25% of battery power whichever happens first. Th is restriction would be more than adequate to 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 has within it the following:

(1) An appropriate a nd current airworthiness certificate. . . .

(b) No person may operate a civil aircraft 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 cockp it entrance so that it is legible to passengers or crew.

The s 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 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 issued numero us 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 inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as p rescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft 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 appl icant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual.(See Sections B, D and G) An equivalent level of safety will be achieved because

these small s 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 s UAS can land10

immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator w ill ensure that the s UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraf t in an airworthy condition to provide the equivalent level of safety.

Pursuant to 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 exemp tion 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 operations of sUASs in the film industry will enhance safety by reducing risk. Conventi onal film operations, 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 present the risks associated with vehicles that weigh in the neighbo rhood of 4,000lbs., carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass a nd 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 s U ASs, 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 environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximit y to the ground and people.

s UASs Details: See Appendix C

Safety Features:

● Emergency “Return

- To

- Home ”

○ At the beginning of each flight a home point is set. This home point is set in accordance with the manual to allow for a safe take

off and return. Should the pilot’s control lose signal with the s UAS11 or manually request a return, the s UAS will return to the starting point.

Privacy

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

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and na tional security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s s UAS in the commercial video production industry pursuant to the Manual appended hereto.

Sincerely

Dunnlights Inc

Richard Dunn12



# Appendix A: N o - Fly Zones

Dunnlights Inc ’s Pilots will not be operating within 5 nautical miles of any airport.

As a safety precaution, Dunnlights Inc ’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 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 NOTAM as required by the operators COA. The letter 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 n ot operate within 5 nautical miles of an airport reference 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 Certificate of Waiver or Authorization (COA). The letter of agreement with the airport management must be made available to the Administrator upon request."

Dunnlights Inc reque sts the same flexibility as exemptions 11153 and 11195 for acquiring agreement with the airports' management should operations fall within 5 nautical miles of an airport.13 Appendix B: Safety Manual

A. Maintenance

a. The s 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 s UAS must pass a flight test with both a pilot and a man ufacturer trained technician 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 s 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 perimeter from the planned flight path

will be identified in order to set a “sterile” environment for th e operation.

1. Dunnlights Inc 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 Dunnlights Inc will carry $1mm in general liability insurance in case of any damage to property or persons within the safety parameter

c. Identify potential obstacles

i. Before each flight, an inventory will be taken for a ll 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 Checklist14 a. Take Off Location/ “Home”

i. The s UAS will mark its take off location as a safe area to return to should

the s UAS lose signal with the control or if the pilot signals the craft to

return to its “home” location.

1. Take off locati on will be in an area with a 25ft radius with no obstructions, maintaining said radius vertically 200ft.

2. The s UAS will take off and land in the same location.

3. GPS Altimeter will be marked as 0’ elevation

b. Flight Canceling Events

i. All flights will be cancelle d 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 s 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 s 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 ensure they are tightened and free of damage

3. Camera mount and gimbal will be inspected to ensure it is fully

at tached and operating.

4. s UAS will be checked for any damage that may have taken place

in transit.

5. The s 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 shows a damaged part or parts, the s 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 s UAS will be thoroughly inspected for any damage that occur red 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. A s cent

1. 10 m/s

ii. De s cent

1. 4 m/s

iii. Flight Speed

1. The s UAS is never to exceed 10m/s

b. Altitude

i. The s UAS is never to exceed 400ft

c. Emergency

i. If it appears that the s UAS, any property or humans are at risk, the s UAS will be grounded immediately to a safe location.

d. Sight

i. The pilot must keep the s 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 s 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 informati on on the

s 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: 3DR Solo

See Appendix D for user manual

S/N: S111A580316417 Appendix D: User Manual1819202122232425262728293031323334353637383940414243444546474849505152535455565758596061626364656667686970717273