August 31, 2015

Exemption No. 12667 Regulatory Docket No. FAA

− 20 15

− 0953

Mr. Curt Daniels Seminole Club, Inc. dba Flatwater Studios 709 West Park Avenue

, Suite D Edgewater, FL 32132

Dear Mr. Daniels :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter s dated April 7 and July 29, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Seminole Club, Inc. dba Flatwa ter Studios ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct closed

- set filming, mapping, photography, and videography

.
See Appendix A for the petition submitted to th e FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

.
The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. However, the FAA received six comments in support of the petition made to the docket.

Airworthiness Certification

The UAS proposed by the petitioner are the Gryphon Dynamics X8 and DJI Inspire 1

.
The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria2

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is
not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1 and closed set motion picture and filming

. The FAA has issued grants of exemption in circumstances similar in all material respects to thos e presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly grea ter proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are sim ilar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Seminole Club, Inc. dba Flatwater Studios is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection and closed set motion picture and filming. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Seminole Club, Inc. dba Flatwater Studios is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Gryphon Dynamics X8 and DJI Inspire 1 when weighing les s than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are permitted.

3. The UA may no t be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater t han the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in thi s grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the4

Administrator upon request. If a discrepancy exists between the conditions and limita tions in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present up dated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and mu st remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable comp onents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and main taining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (trai ni ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operat ions may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport sy mbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management mus t be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a
pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibi ted from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to co nduct operations that cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) ma rkings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

.
The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certific ate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available t o the inspector upon request;
g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essenti al to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specifie d in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

EnclosuresApril 7, 2015

United States Department of Transportation Docket Management Sy stem 1200 New Jersey Ave., SE West Building Ground Floor Room W12

- 140 Washington, DC 20590

**Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012**

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and C.F.R. Part 11, Seminole Club, I nc., DBA: Flatwater Studios , owner and operator of Small Unmanned Aircraft S ys tems (UASs), request to be exempted from the Federal Aviation Regulations (FARs) listed below so that Seminole Club, Inc., DBA: Flatwater Studios may

operate UASs commercially in airspace regulated by

the Federal Aviation Administration; as long as such operations are conducted within and under t he conditions outlined herein or as may be established by

the FAA as required by

section 333.

The Name and address of the applicant is:

Seminole Club

, In c . (SCI) DBA: Flatwater Studios Attn: Curt Daniels 709 West Park Ave Suite D Edgewater, Florida 32132 curt@flatwaterstudios.com 386

- 957

- 3925

As d escribed below, the requested exemption would permit the operation of lightweight (less than 55 lbs total take off gross weight) UASs under controlled conditions for commercial use b y professional certificate d pilots thereb y enhancing safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to “.... establish requirements for the safe operation of such aircraft sy stems in the national airspace
sy stem." Section 333(c) of t he Reform Act.

SCI respectfull y requests the grant of an exemption to the following specific sections of the Title 14 Code of federal Regulations allowing it to operate lightweight UAS's for commercial use:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 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)

SCI submits this application in accordance with the Reform Act, 112 P.L. 95 331

- 334, seeking relief from an y currentl y applicable FAR's operating to p revent SCI’ s future commercial use of small UASs to operate in the national airspace s ys tem as described below. The Reform Act Section 332 provides for such integration of civil unmanned aircraft s ys tems into our national airspace s ys tem as it is in the public's interest to do so. SCI ’s lightweight UASs meet the definition of "small unmanned aircraft" as defined in section 331 and therefore the integrati on of SCI’s lightweight UASs are expressly
contem plated b y the Reform Act. SCI would like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certa in unmanned aircraft s ys tems may operate safel y in the national airspace s ys tem (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 t ypes of UASs do not create a hazard to users of the NAS or the public or pose a threat to national securit y in light of the following:

• The UAS's size, weight, speed and operational capability • Operation of the UAS in close proximity to airports and populated areas • Operation of the UAS within visual line of sight o f the operator Reform Act 333 (a)

If the secretary

determines that such vehicles "may operate safel y in the National Airspace S ys tem, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace S ys tem."

SCI 's UAS ’ s are rotorcraft weighing less than 55 pounds including pay load. They operate at a speed of less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simult aneously

. The UAS will operate onl y within the line of sight of the pilot within a protected flight area as described below. Such operations will insure that the UASs will not create a hazard to the users of the national airspace system or the public.

The small nature of the UASs utilized by SCI com bined with the safet y protocols outlined below will allow for a greater than equivalent level of safet y in which Congress envisioned that the FAA must, by exemption allow commercial operations of UASs to

commenc e immediatel y. Also due to the size of the UASs and the areas and altitudes they will operate, approval of the exemption presents no national securit y issue and absolutely minimal safety concerns which have been mitigated through a rigorous risk management
process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safet y surrounding the proposed operations, the significant public benefit, includin g enhanced safet y, reduced emissions utilizing UASs vice traditional aircraft as well as the economic impact of greatly

reducing the cost of aerial photography thereby benefiting the greaterpublic's interest. Accordingl y, the applicant requests that the FAA grant the requested

exemption without delay

. The following limitations are considered to be binding for the operation of UASs for commercial purpo ses by

SCI :

1. Flights will be operated in the line

- of

- sight by a ground

- based pilot 2. Flights will onl y occur in the daytime and clear of clouds 3. The UASs will weigh less than 55lbs at take off and during flight 4. Flights will be terminated with 25% of battery life remaining 5. Flights will be operated at an altitude at or below 400' AGL 6. Pilots, camera operators and observers wil l be trained as to the applicable portion of the UAS's manual as well as the SOPs. 7. Minimum UAS crew will be one certific ated Commercial pilot or higher rating with a current FAA medical. A camera operator and or observer may be added as required to further reduce the possibility of task saturation by

the pilot depending on the mission requirements. 8. Pilot, observer and camera o perator will maintain real time communication capability throu ghout flight operations. 9. The UAS Pilot will conduct a full site survey to determine the Area of Responsibility (AOR). This AOR is the actual area for UAS operations for a particular day . Each survey will include the assessment of potential hazards to in clude but not limited to airspace classification, NOTAMS, temporary flight restrictions, clo sest airport proximity , natural and manmade obstacles, and unnecessary persons which may

pose a risk to operations or safet y. If deemed necessary, the crew will emp loy additional personal as safety observers. 10. SCI will employ

s afety observers as well as sign notifications in areas close to public activity

. 11. A thorough briefing will be conducted, prior to the first flight of the day in an AOR, utilizing the brie fing guide in the SOPs. All persons who will be in the AOR while UAS flights are conducted will be present for this briefing. 12. SCI will obtain cons ent (verbal or written) for any pe rsons who need to be within 100 feet of UAS flight operations. 13. Writt en and or verbal permission from th e relevant propert y owners will be obtained prior to flight. 14. All r equired permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other governmental agencies. 15. If the UAS loses communications or loses it s GPS signal, the UAS will have the capability to return to a pre

- determined location within the AOR and land autonomously

. 16. The UAS will have the ability 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. 91.7(a), 91.203 (a)(1)** Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of

necessary airwor thiness certificates in relation to FAR 91.203(a)(1) The size, weight and defined area of operations for SCI UAS flights permits exemption from Part 21 because SCI meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is au thorized to exempt aircraft from the airworthiness certificate requirement under both the ACT ( 49 U.S. C. 44701(f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate requirement i n consideration of weight, size, speed, maneuverability and proximity

to areas such as airports and dense populations. SCI meets or exceeds each of these elements.

14 C.F.R. 91.203 (a &b) provides for carry ing of civil aircraft certifications and registr ations. They

are inapplicable for the same reasons stated above. The equivalent level of safety

will be achieved by

maintaining such certifications and registrations at SCI ’s flight o perations center.

14 C.F.R. 91.7(a) prohibits the operation of an aircr aft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this regulation is inapplicable.

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

14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots of passengers, and given the size of the UASs, this regulation is inapplicable. An equivalent level of safet y will be achieved b y maintaining an operators manual at the flight operations cente r. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

**14 C.F.R. 91.103(b) Preflight actions** 

14 C.F.R. 91.103 Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include: (b) For an y flight, runway lengths at airports of intended use, and the following takeoff and landing distance information. Thi s subparagraph is not applicable due to our off airfield operations.

**14 C.F.R. 91.109 Flight instructions**  **; Simulated instrument flight and certain flight**  **tests.**

14 C.F.R. 91.109 and all the subparagraphs address the operation of a civil manned aircraft in conjunction with training and flight tests. The UAS to be emplo yed by SCI are not designated in this category

.**14 C.F.R. 91.121 Altimeter Settings**

14 C.F.R. 91.121 regarding altimeter settings is inapplicable because SCI UASs utilize GPS sy stems and internal gy roscopes to provide spatial stability and a reference datum.

**14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions**

14 C.F.R. 91.151 prohibits an individual from beginning a "flight in an airplane under VFR conditions unless (conside ring wind and forecast weather conditions) there is enough fuel to fl y to the first point of intended landin g, and assuming normal cruising speed

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

The battery

powering the UAS provides approximately 25 minutes of powered flight, which is less than the reserve requirement alone by F ARs for day

or night VFR flight. Given the limitations on the UAS's flight envelope, proposed AOR size, bat tery life and its ability to land immediately

it is reasonable to allow an exception.

An equivalent level of safety can be achieved by

limiting flights to 25% of battery power. This restriction would be more than adequate to return the UAS to its planned landing zone in the AOR.

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

**14 C.F.R. 45.23 Marking of the Aircraft**

Applicable Codes of Federal regulations require aircraft to be marked according to certain specifications. SCI UASs are unmanned; do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is impractical to place on such small aircraft. SCI will, however, place the wo rd "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. 45.29 (f) so that the pilot, camera operator, observer and an y other persons operating in the AOR can see the markings on the UAS. The FAA has previousl y issued exemptions to this regulation throug h Exemptions Nos. 8738, 10167, 10167 A, and 10700.

**14 C.F.R. 91.119 Minimum Safe Altitudes**

14 C.F.R. 91.119 prescribes safe altitudes for the operation of civil aircraft. I t allows helicopters to be operated at lower altitudes in certain conditions. SCI will only operate its UASs at or below 400 AGL. SCI will operate its UASs in a defined AOR that hasbeen carefully reviewed for hazards and minimizes the presence of any persons not essential for operations. Flights will only be conducted over private property with consent of the propert y owner. The equivalent level of safety will be achieved given the size, weight and speed of the UAS as well as the location where it is operated. Compared to flight operations with traditional aircraft or rotorcraft wei ghing far more than 55lbs, operating be low 500 AGL with flammable fuel UAS operations present a far smaller risk.

**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 the aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as prescribed in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

, and others shall inspect or maintain the aircraft in compliance with Part 43.

These regulations only

apply to aircraft with an airworthiness certificate. They will not, therefore, appl y to SCI UASs should its requested exemption be gran ted. As an equivalent level of safe ty SCI requires its pilots to conduct a preflight, through flight and post flight inspection of the UAS to ensure it's flight worthiness prior to launch. Each UAS is flown in compliance with the applicable manufactures manual to include all software update cy cles as well as flight checklists. In the event of a malfunction the UAS can land immediatel y.

**Privacy** All flights will occur over private or cont rolled access property with the property

owner's prior consent and knowledge.

**Summary**

SCI is seeking e xemption from the following rules:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 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).

Approval of the above exemptions allowing commercial operations of small UASs in the service of aerial photography will greatly

enhance safet y b y reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft weighing thousands of po unds and carry ing hundreds of pound of fuel presenting a significant risk to life and propert y. With SCI 's use of small UASs weighing less than 55 lbs, powered b y batteries and operating at or below 400 AGL they virtually eliminate all of the risk associat ed with traditional aerial photograph y. The UASs will carry no people thereb y eliminating the exposure to the risks associated with fly ing while accomplishingthe same task in a much safer manner.

Granting SCI the above exemptions will allow for the expansion of UAS systems into the future, in a professional, safet y conscious culture steep in the tradition of Aviation. The safet y culture established by the founding members of SCI is based on our 35+ y ears of business experience.

. SCI respectfull y re quests that the FAA grant its exception without delay . The FAA has the authority

to issue the exemption sought by SCI pursuant to the Federal Aviation Act, 85 P.L . 726 (1958), as amended (the "Act").

Sincerel y,

Curt Daniels Seminole Club, I nc. DBA: Flatwater Studios 709 West Park Ave Suite D E dgewater, FL 32132July

29, 2015

ID: FAA

- 2015

- 0953

- 000

United States Department of Transportation Docket Management Sy stem 1200 New Jersey Ave

., SE West Building Ground Floor Room W12

- 140 Washington, DC 20590

**Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012** 

Dear Sir or Madam:

In response to you letter dated July 2, 2015, we wish to provide y ou the following information as per your request.

The specific reasons we seek relief is to operate in the following areas of commerce :

1. Closed Set Filming

Our MPTOM is outlined in the document s we provided in our original exemption request. Please refer to the two published documents labeled:

A. Seminole Club, I nc. d/b/a Flatwater Studios

– UAV Flight Operations Manual B. Seminole Club, I nc. d/b/a Flatwater Studios

– Preflight Checklist

2

. Geo graphical Mapping

3

. Agricultural Mapping and Anal ys is

4. Real Estate Photography and Video

5. General Aerial Photograph y and Video

In addition, we are providing to you all of the Release forms we currentl y use in out film and photograph y operations.

We hope this information helps clear up an y concerns the FAA has toward our approval process. If more information is needed, we are alway s available to provide to y our office
any and all requested documentation

. Thank y ou for y ou time and consideration.

Sincerel y,Curt Daniels

Seminole Club, I nc. DBA: Flatwater Studios 709 West Park Ave Suite D Edgewater, FL 32132