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Melinda Sokoloski
April 16, 2015 

 Exemption No. 11333 

 Regulatory Docket No. FAA-2015-0004 

Ms. Melinda Sokoloski 

MSPhotography dba MSAerial 

33 Sea Avenue 

Quincy, MA 02169 

Dear Ms. Sokoloski: 

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. 

The Basis for Our Decision 

By letter dated December 31, 2014, you petitioned the Federal Aviation Administration 

(FAA) on behalf of MSPhotography dba MSAerial (hereinafter petitioner or operator) for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct aerial photography for the media and advertising industries. 

See Appendix A for the petition submitted to the FAA describing 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. 

Airworthiness Certification 

The UAS proposed by the petitioner is a DJI S1000. 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
2 

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, Certification 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. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 Labs, 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 greater 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— 

x They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

x The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

x 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, MSPhotography dba MSAerial 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. This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, MSPhotography dba MSAerial is hereafter referred to as 

the operator. 
3 

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 DJI S1000 when 

weighing less 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 

(not) permitted. 

3. The UA may not 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 than 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 maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for 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 this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations 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 operator 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 
4 

operator must also present updated 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 FAA’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 operation 

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 must 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 is 

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 components, 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 Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

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 

maintaining 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 
5 

(training, 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 operations may only be conducted during dedicated training sessions. During 

training, 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 symbol 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 must 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 signal, the UA must return to a 

pre-determined location within the private or controlled-access property. 

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

20. The PIC is prohibited 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 conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

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) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable. 
6 

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 nonparticipating 

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 remain 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 controlled-access property with 

permission from the property owner/controller or authorized 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 operational area as defined by the applicable COA must be reported 

to the FAA'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. 

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 motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 
7 

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 area 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 the 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 certificate 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 to 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 

essential 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 specified 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. 

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

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

 
33 Sea Ave, Quincy, MA 

Docket Management System 

U.S. Dept. of Transportation 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

J, , J,IIJ,,,,J,J,J,J,,JJ .... J •• JI 

Addr: 33 Sea Ave 

Quincy, MA, 02169-3 135 

Ph: + 1-(857)-204-2448 

Email: mindi@msaerial.com 

VVeb: msaerial.com 

MSPhotography, December 31, 2014 

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

Dear Sir or Madam, 

Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, 

MSPhotography DBA MSAerial, operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct 

aerial photography for the media and advertising indestries for pre-planned, controlled area, photographic 

and surveying services, 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 under 

the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as 

required by §333. MSAerial's current operation of sUASs for commercial purposes has been halted to comply 

with recently enacted federal aviation regulations pertaining to sUASs. 

As described more fully below, the requested exemption would permit the operation of small, unmanned 

and relatively inexpensive multirotor aircraft under controlled conditions in airspace that is 1) contained 2) 

predetermined 3) has on-site safety personnel controlling access, and 4) would provide increased safety and 

enhancements to clients' business operations. 

The name and address of the applicant is: MSPhotography db a MSAerial Attn:Melinda Sokoloski Ph:+ l-

(857)-204-2448 Email:mindi@msaerial.com Address: 33 Sea Ave, Quincy, MA 02169 

MSAerial respectfully requests a grant of an exemption of the following sections of Title 14 of the Code of 

Federal Regulations: 

o 14 CFR 21; 

o 14 CFR 91, et seq.; 

o 14 CFR 45.23 (b); 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

• 14 CFR 61.113 (a) & (b); 

• 14 CFR 407 (a)(l); 

• 14 CFR 409 (a)(2); 

• 14CFR417(a)&(b). 

MSAerial also respectfully requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 

• 14 CFR 45.23(b); 

• 14 CFR Part 21; 

• 14 CFR 61.1 13 (a) & (b); 

• 91.7 (a); 

• 91.9(b)(2); 

• 91.103(b); 

• 91.109; 

• 91.119; 

• 91.12 1; 

• 91.151(a); 

• 91.203(a) & (b); 

• 91.405 (a); 

• 91.407 (a) (1 ); 

• 91.409 (a) (2); 

• 91.417 (a) & (b). 

I. The Exte nt of Relief MSAerial Seeks and the Reason It Seeks Such Relief: 

MSAerial submits this application in accordance with the Reform Act, 112 P.L. 95 §§331-334, seeking relief 

from any currently applicable federal aviation regulations PARs pertaining to UASs (unmanned aircraft 

systems) and operating to prevent MSAerial contemplated commercial photographic, mapping, and other 

flight operations within the U.S. national airspace system. 

The Reform Act in §332 provides for such integration of civil UASs into our national airspace system as 

it is in the public's interest to do so. MSAerial's lightweight UASs meet the definition of "small unmanned 

aircraft" as set forth in §331 and combined with a sterling safety record in similar industries, MSAerial's light 

duty UASs are ideal recipients of exemption by the intent of the Reform Act. 

Considerations for relief include a combination of sUAS physical characteristics, safety features, and safe 

practices identiied in §333: 

• sUAS weight, 

• sUAS overall size, 

• sUAS speed over ground, 

• sUAS flight zone characteristecs, 

- Non-operation near airports (civilian or military), 

- Tightly controlled operation in populated areas, 

33 SEA AvE, QuiNCY, MA 02169-3135 

MINDI@MSAERIAL.COM + 1 - (8 57) - 204 - 244 8 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of201 2 

• Operation of the UAS by VLOS. 

• Coordination by a minimum of 4 persons, three staff members of MSAerial and one safety official from 

the client. 

Specific consideration is outline below. 

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 for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1 ). Given the size and 

limited operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal Aviation Act (49 

U.S.C.§4470 1 (f)) and §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 sUAS. In all cases, an analysis of these criteria 

demonstrates that the 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 conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated by MSAerial is less than 11kg. with maximal payload consisting of remote 

sensing instrumentation, carries neither no persons, carries no explosive or flammable materials including 

combustible fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under 

this exemption will be tightly controlled and monitored by both the pilot (PIC), 'spotter' role designated to 

act as both the remote sensing controller and secondary monitor for safety issues, and a technician, which 

assists in matters related to maintaining the sUAS and also monitors for safety concerns and liasons to 

the on-site safety officials. These enhancements to current safety practices and regulations, which already 

apply to civil aircraft, provide a greater degree of safety to the public and property owners than conventional 

aircraft 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 intrinsic credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of intrinsic explosive materials 

or flammable liquid fuels, and inability to carry a substantial external load. 

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

The regulation requires: When marks include only the Roman capital letter "N" and the registration number 

is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each 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 sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS 

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. 

Given the size of the sUAS, two-inch lettering will be impossible. The word "Experimental" will be placed on 

the frame in compliance with §45.29 (f) at a size suitable for the available space. 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as 

"Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 

8738, 10167 and 10167A. 

Further markings include the use of flashing green LED illumination on the underside of the sUAS frame 

which stands at contrast against a blue or white sky. 

33 SEA AvE, QuiNCY, MA 02169 - 3135 

MIND I @MSAERIAL.COM + 1 - (8 57) - 204 - 2448 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

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

§61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot 

or passengers, the proposed operations can achieve the equivalent level of safety of current operations by 

requiring a ground crew member to have a private pilot's license rather than a commercial pilot's license to 

operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no persons on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance. 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 drafted, that 

allowing operations as requested with a private pilot in the ground crew exceeds the present level of safety 

achieved by 14 C.P.R. §61.1 13 (a) & (b). 

14 C.P.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 for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a 

subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided. 

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

§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. 

The sUAS, given its size and configuration has no ability to carry a physical flight manual 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 sUAS will have immediate access to it. The FAA has issued the following exemptions to 

this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658, 10167, 10167A, 10602,32827, 

and 10700. 

14 C.F.R. §91.103: Preflight action 

This regulation requires each PIC 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. The PIC 

will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances 

and aircraft performance data before initiation of flight. Further, we have proprietary manuals created 

with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and 

continue to work with these organizations to ensure best safe practices are adhered to. 

14 C.P.R. §91.1 09: Flight instruction 

§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 fully functional dual controls. Flight control is accomplished through the 

use of a control box that communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number 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 

33 SEA AvE, QurNCY, MA 02169-3135 

MINDI@MSAERIAL.COM + 1 - (8 57)- 204 - 2448 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

speed of the aircraft. Enhancing this safety is the technology inherent in the remote controls utiziling digital 

communications which is paired to the sUAS making it nearly impossible to unintentionally or intentionally 

have the con trol communications interrupted. 

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

§91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated 

at less than the minimums prescribed, provided the person operating the helicopter complies with any route 

or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that closely mimics the 

behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an 

exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher 

than 400 AGL or beyond unaided visual line of sight, whichever is closer. It will however be operated in a 

restricted area with security officials tasked with ensuring public safety, and where buildings and people will 

not be exposed to operations without their pre-obtained consent and training. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location 

where it is operated. No flight operation will be taken without the permission of the property owner in the 

case of private property or local officials i the case of public property or private property with public interests. 

Because of the advance notice to the property owner and participants in the remote sensing activity, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft 

or rotorcraft weighting fa r more than the maximum 11kg of MSAerial's sUASs 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 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 §91.119. 

14 C.F.R. §91. 121 Altimeter Settings 

§91.121 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, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. The PIC and Technician will also 

ensure effective pairing with multiple GPS sources to guarantee accurate detection of height. 

14 C.F.R. §9 1.15l(a): Fuel Requirements for Flight in VFR Conditions 

§9 1.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless 

(considering wind and fo recast weather conditions) there is enough fuel to fly to the first point of intended 

landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes:' The battery powering the sUAS provides approximately 

15 minutes of powered flight in hover mode with out payload. MSAerial's sUAS will not be able to meet the 

30 minute reserve requirement in 14 CPR §91.151. 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 power, does not engender the type of risks that Section 9l.l51(a) was 

intended to alleviate given the size and speed of the small UAS. MSAerial believes that an equivalent level of 

safety can be achieved by limiting flights to » 10 minutes or 25% of battery power whichever happens first. 

This restriction would be more than adequate to return the sUAS toils planned landing zone from anywhere 

in its limited op erating area. 

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

33 SEA AVE, QUINCY, MA 02169 - 3135 

MINDI@MSAERIAL.COM + 1- (8 57) - 204 - 24 4 8 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

10808. 

14 C.P.R. §91.203 (a) & (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 and 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 cockpit entrance 

so that it is legible to passengers or crew. 

The sUAS fully loaded weighs no more than llkg 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 numerous exemptions to this regulation. A representative sample of other exceptions 

includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.P.R. §9 1.405 (a); 407 (a) (1); 409 (a) (2); 4 17(a) & (b): Mainten an ce 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 prescribed in part 43 of this chapter ... ;' and others shall inspect 

o r 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 applicant. Maintenance will 

be accomplished by the operator pursuant to the flight manual. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 

An exemption granted to MSAerial would permit its operation of lightweight, unmanned, remotely 

controlled, sUASs in a tightly controlled environment with limited airspace. MSAerial utilizes local business' 

safety officers in specifically determined areas (designed flight zone) to mitigate injury and property damage 

while fulfilling clients' goals. Technical enhancements to current safety controls will allow MSAerial to 

operate exceeding current safety specifications, and stay ahead of, or meet, new ones being implemented 

by the FAA and Department of Transportation. Further, MSAerial conducts its operations in compliance 

with protocols described herein or as otherwise established by the FAA. 

II. Commercial and Public Benefits 

We at MSAerial believe that granting this exemption request furthers the public interest by providing safe 

(by way of an unmanned system) and efficient means to meet technical problems solvable by elevated data 

collection instruments. MSAerial's client base are typically small to medium sized business' looking to 

increase their awareness of structures or landscape on their respective properties through data collection 

33 SEA AVE, QUINCY, MA 02169-3135 

MINDI@MSAERIAL . COM + 1 - (8 57) - 204 - 244 8 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

by photographic, videographic or lidar based surveying. By moving these functions onto sUAS based 

aircraft, the potential for loss of life or property is diminished due to the greater control in a smaller and 

safer aircraft that holds no persons. Second, there are no reactive or combustible materials on board the 

sUAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme 

maneuverability of MSAerials UASs allow the PIC to avoid hazards. Lastly, due to the nature of the remote 

sensing instrumentation onboard, the sUAS can maintain quite a safe distance between the aircraft and the 

object(s) undergoing scrutiny. Accordingly, MSAerial's UASs have operated and will continue to operate at 

and above current safety levels. 

A. The costs and benefits of you r proposed action to society in general and specifi c gro ups within society 

As described above, MSAerial's past customers have been small to medium business seeking a remote sensing 

solution to specific issues before a larger effort on their part would come underway. Examples include 

construction efforts that sought elevated photographic imagery of specific landforms to minimize cost of 

efforts to develop, a regional park service that wanted to quantify the changing lifecycle of it's flora by way of 

measuring leaf health through gradual chlorophyll depletion, and a local cities' Dept. of Public Works that 

sought to collect images and 30 structural data by way of Lidar sensing en masse of it's bridges to serve as a 

supplement to it's routine repair and planning documentation. 

The impact to society, financial and otherwise, would be extremely minimal. Indeed, it's been demonstrated 

that sUASs have the ability to drasticially increase the information availible to policymakers at a frac tion of 

the cost of measuring this data by terrestrial means. One such impact would be inconvenience to directly 

proximal and non-essential personnel that would be displaced from public or business owned property if it is 

deemed to be unsafe. In this case we relay our needs for a f1ight zone with the requirement that it be safe from 

casual intrusions and allow the business time to shift operations in order to minimize potential safety issues. 

This is best performed with the aid of safety personnel that actively steer non-essential persons around the 

flight zone. 

1. The effect of an exemption fo r MSAerial o n t he quality of the natural and social e nvironments 

Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an on board 

pilot, time consuming adherance to regulations surrounding bookeeping and submission of flight paths 

to local civiliar or military airports, and detrimental effects to the environment caused by operating a 

combustible fuel based, large scale aircraft, with restrictions on the proximity to the target for remote sensing. 

Ill. Flig ht Capabilities a nd Characteristics of MSAe rial's UASs 

Persuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and 

characteristics of the sUAS. 1 

MSAerial UASs utilizes eight (8) counter-rotating propellers paired oppositely to each other for balance, 

control and stability. The total span of the sUAS is ""'1.2m allowing for stable flight or landing even with 

the sudden onset of detrimental environmental conditions. The sUAS's have a maximal unit+ payload mass 

of llkg, including cinematic/photographic or other surveying equipment. MSAerial's sUAS is designed to 

primarily hover in place to capture photographic data and then operate at less than a 35 knot maximum speed 

to the next point of interest. They are capable of vertical and horizontal operations but, in practice, is operated 

only within unaided VLOS of the PIC. In addition to the PIC, MSAerial employs a spotter (VOS role) and a 

technician (secondary VOS and on-site personnelliason) which are within unaided verbal communication 

range. These personnel are supplemented by safety offcials provided by the client who are instructed to cordon 

1

More characteristics have been outlined in the enclosed supplemental materials. 

33 SEA AvE, QuiN CY, MA 02169-3135 

Ml NDI@MSAER IAL .COM + 1- (8 57)- 204-2448 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

off and otherwise minimize pedestrian access in the flight zone of the client's grounds. In the event of loss of 

visual of the UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r,a ,h) 

based controls which allows the PIC to utilize one controller axis to recall the VAS to the PIC's position 

without concern to the current heading of the sUAS. In the event of loss of sight of the sUAS into an area 

containing hazards or possible hazards, the spotter has a heads-up-display containing a live video feed which 

can be used to locate the UAS while it maintains it's position in hover mode. The sUAS has demonstrated 

it's ability to maintain it's position by GPS coordinates in hover mode in "-'2Skph wind gusts at rv25 feet 

representing an extreme environmental condition beyond the range of conditions within the scope for sUAS 

operation. 

All ofMSAerial's sUASs utilize LiPo (lithium polymer) battery based power sources, decreasing safety risks 

from more easily combustible, fuel based, power sources. Flight times generally last between eight (8) to ten 

(1 0) minutes allowing the staff to work with small flight areas per phase. The maximum flight time without 

payload is 15 minutes, however practical safe operation limits this to 10 to give ample time to control the 

sUAS to a safe landing zone. MSAerial further restricts flight time by not operating its sUASs with less than 

twenty five percent battery capacity. Further safety management systems in place include a GPS mode that 

allows MSAerial sUASs to hover in place if communication with the PIC is lost and optionally follow a set 

of waypoints at a set speed and height to a 'home base' predesignated safe landing zone. In the event of 

unforseen motor(s) failure, the system will enter into a controlled descent while allowing full use of all UAS 

flight controls by the PIC. All commands sent via remote controller received during a controlled descent are 

translated to an 'as meant' paradigm meaning the flight control package will use it's realtime 3 dimensional 

position and compensate rotors control the sUAS regardless of spin velocity. Landing gear is also programmed 

to deploy based on sensing of range to ground from non-GPS based sources. This assures that if one system 

is compensated a safe and successful landing can still occur. 

IV. Reasons Why an Exemption to MSAerial Will Not Adversely Affect Safety Standards 

MSAerial's contends that operation of it's sUASs will not "create a hazard to users of the national airspace 

system or the public:' as stated in 112 P.L. 95 §333 (b). Given the diminuative size and weight of MSAerial's 

sUASs, combined with their operation in cordoned off and well-controlled areas, MSAerial's sUASs falls 

within Congress's contemplated safety zone. MSAerial sUASs have an established safety record bolstered 

by multi-point preflight checklist, awareness of their surroundings and intimate knowlege of the behaviour 

of the sUAS platform in many weather conditions. TI1is safety record and implemented operational practices 

demonstrate an awareness of public safety. 

MSAerial operations routinely provide a level of safety at least equal to existing rules, and in nearly every 

instance, exceeds existing rules. MSAerial has worked very closely with the regional vendors and support for 

this unit to create a tightly integrated and highly fauh tolerant platform that has been tested throughly by a 

vendor with a proven record for safety and solid designs. 

Though it does not mitigate safety it is of note that as of Nov 2014 there are few companies that will 

insure sUAS operations and sUAS based companies. The sUAS of use at MSAerial is one of two models 

(by current awareness) that qualify for protection against damages or injury. MSAerial attained the maximal 

level of insurance to rectify accidental damage or injury. MSAerial also continues to work closely with this 

organization to identify and mitigate sUAS platform risk due to their expertise in several industries closely 

related to the aviation and transportation. 

MSAerial does not operate its UASs on or near airports and generally has only operated its fleet on private 

grounds with cordoned off areas or areas under the control of the property owner I client with assistance by 

safety officials employed by the business. MSAerial determines the areas needed to fulfill the clients' goals 

and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols 

set forth initially by the RC UAS trade and hobby groups and recently codified by relevant FARs. 

33 SEA AVE, QUINCY, MA 02169-3135 

MIND! @MSAER IA L. COM + 1 - (8 57) -204-2448 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

MSAerial standardized on the following practices to ensure safe operation of it's UASs: 

• Work with on-site personnel to plan the flight goals, 

• Work with on-site personnel to restrict access to non-essential persons, 

• Operation by unaided VLOS operation only, 

• Operation in phases 10 minutes in length, 

• Operation to minimal 25% battery power, 

• Operation of device to GPS aided readout to 300ft at maximum, 

• Numerous pre-programmed fail-safes that ensure specific behavior per issue, 

• Three main roles supplemented by on-site safety personnel, 

• Employ controlled lifecycle management of components to guard against multiple failures, 

• Preform a site check day(s) before flight to identify poten tial issues, 

• Subscribe to relevant local weather and safety alerts, 

Expertly choose data collection instruments and accessories to minimize flight requirements or 

expertise, 

MSAerial has experience in similar fields and has adapted this experience in it's use of UASs to increase 

safety. In combination to the ever expanding knowlege repositories from hobbyists and experts alike, 

MSAerial is constantly evolving it's practices when there is a clear benefit to operations or increased safety 

element. 

A. Summary 

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: 

MSAerial {applicant) seeks an exemption from the following rules: 14 C.P.R. §21, subpart H; 14 C.F.R 

45.23(b); 14 C.P.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) & (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 (11kg or less) in elevated photographic and remote sensing 

operations. 

Approval of exemptions allowing commercial operations of sUASs in the the media industry will enhance 

safety by reducing risk associated with conventional aircraft operations and other means of elevated remote 

sensing involving persons. The public benefit served by approval of this petition is increased awareness 

of characteristics of difficult imaging targets. A sUAS weighing fewer than 1lkg and powered by sealed 

batteries eliminates virtually all associated risk inherent in operating conventional aircraft in close proximity 

to buildings or persons or otherwise elevating persons to a position they would be able to collect needed d ata. 

The operation of small UASs, weighting less than 55lbs., 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. 

33 SEA AVE, QUIN CY, MA 02169 - 3135 

MlNDI@MSAERlAL .COM + 1- (8 57) - 204-24 48 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

As identified and described herein, Melinda Sokoloski, and her company MSPhotography DBA MSAerial, 

is an experienced, recognized media services professional in the various photographic industries. Mrs. 

Sokoloski and her companies have been producing and delivering media and technical solutions for the media 

service industry for ten ( 1 0) years with a spotless safety record. 

The FAA has been given the authority to issue the exemption to MSPhotography DBA MSAerial pursuant 

to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your consideration and approval 

of this petition. 

PIC VLOS Best, 

encl: Supplement A: Physical characteristics of UAS 

encl: Supplement B: Flight Operation and Procedures Manual (FOPM) related to operation 

encl: Supplement C: Flight maps in MSAerial regional base 

33 SEA AvE, Qu i NCY, MA 02169-3135 

MINDI@MSAERIAL. COM + 1- (8 57)- 204 - 2448 
Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM) 

• All regular and irregular operations are noted with timestamps, relevant UAS metrics and corrective 

action procedures (CAP) that are performed. 

- Note: All irregular behavior have root cause analysis performed before UAS operation is resumed. 

VI. Emergency Procedures 

• Loss of Remote Signal 

- The flight package features an optional enhanced fail-safe which returns the UAS to the home base 

waypoint via the same path taken to point of lost signal. 

- The UAS will then preform a hover over this waypoint and then a controlled landing. 

• Loss of GPS signal 

- The system will operate in GPS assisted mode with three (3) satellites. 

- At loss of three (3) GPS satellites, manual mode can be activated or the flight package can be 

programmed to preform a controlled landing to the home base waypoint. 

- Ground based height ranging is preformed by a seperate system and so loss of GPS will not impact 

controlled landing in a safe manner. 

• Loss of Engine Power 

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the system will 

enter into controlled spin where all controls are translated based on current orientation and will 

behave as normal operation to the PIC to ensure a safe landing, 

- In the event of multiple rotor or motor failures the flight package can be configured to preform a 

safe landing or attempt operation to home base waypoint. 

- Note : Behavior of the landing location is highly dependant on the position and number of 

rotors/motors that are affected. 

• Loss of Ground Control Software 

Best, 

- This will not affect operation of the flight. The unit will be piloted to a safe landing area and then 

landed so that examination of the link can be made. 

Norfolk, SS . Commonwealth of Massachusetts December iH , 2014 

On this 31st day of December , 2014, before me , the 

undersigned Notary Public, personally appeared Melinda 

Sokoloski, provide to me through satisfactory evidence of 

identification, which was her Mass . Driver's License, to 

person whose name is signed on the preceding 

document, and acknowledged to me that she signed it 

voluntarily as her free act and deed and for its 

stated purpose . 

33 SEA AvE, QuiNCY, MA 02169-3135 

MINDI@MSAERIAL .COM + 1 - (8 57)- 204-244 8 
CERTIFICATE OF LIABILITY INSURANCE I DATE (MM/DDIYYYY) 

1/20/2014 

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS 

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES 

BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED 

REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER. 

IMPORTANT: If the certificate holder Is an ADDITIONAL INSURED, the pollcy(les) must be endorsed. If SUBROGATION IS WAIVED, subject to the 

terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the 

certificate holder in lieu of such endorsement(s). 

PRODUCER CONTACT 

Lockton Affinity, LLC NAME: 

P.O. Box 410679 PHONE I 888-202-1526 FAX 

Kansas City, MO 64141-0679 (AIC No.Ext): (AIC,No):: 

E-MAIL ADDRESS: 

INSURER(S) AFFORDING COVERAGE NAIC 

INSURER·A: Certain Underwriters at Lloyd'&, London 

INSURED INSURER·B: 

MS Photography INSURER·C: 

33 Sea Ave INSURER·D: 

Quincy MA 02169 INSURER·E: 

INSURER·F: 

COVERAGES :ERTIFICA.rE REVISION 

THIS IS TO CERTIFY THAT THE POUCIES OF INSURANCE USTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POUCY PERIOD 

INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH 

THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE 

TERMS, EXCLUSIONS AND CONDffiONS OF SUCH POLICIES. U MITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. 

INSR TYPE OF INSURANCE ADOl $UBR POLICY NUMBER POLICY Eff POLICY EX!' LIMITS LTR INSR W\10 (MM/00/YY) (MM/00/YY) 

A GENERAL LIABILITY PP4003590 l/21/2014 1/21{2015 EACH OCCURRENCE $1,000,000 

X COMMERCIAL GENERAL LIABILITY DAMAGE TO RENTED PREMISES $100,000 

fXl occuR 

{Ea occurrence) 

CLAIMS MADE MED EXP (Any one person) $5,000 

PERSONAL& AC1I/ INJURY $1,000,000 

GENERAL AGGREGATE $2,000,000 

GEN'I. AGGREGATE LIMIT APPUES PER: PRODUCTS • COMP/OP AGG $2,000,000 

X POLICY [] PROJECT n LOC $ 

Al/TOM081LE UA8IUTY COI'ISINEO SINGLE liMIT $ (Eaacddent) 

ANY ALrrO BOOILY INJURY (Per person) $ 

- ALL OWNED AUTOS SCHEDULED AUTOS BOOILY INJURY (Per acx:ldent) $ 

- PROPERTY DAMAGE HIRED AUTOS NON $ ·OWNEO AUTOS (Per accident) 

- UMBRELLA UA8 OCCUR EACH OCCURRENCE $ 

- EXCESS LIA6 CLAIMS HADE AGGREGATE $ 

OED I IRETENTlON$ 

W0RJ<ERS COMPENSATION 

AND EMPlOYERS' UA8ILITY ·ll OTHER lOftY UNITS 

ANY PROPRIETOR/PARTNEJVEXECIITlVE Y/N 

OFFlCEIVMEMBER EXCLUDED? E.L EAOi ACCIDENT $ 

(MANDATORY IN NH) E.L. DISEASE · EA EMPLOYEE $ II yes, describe under 

DESCRIPTION Of OPERATIONS belOw E.L. DISEASE · POLICY LIMIT $ 

Hired & Non-owned Auto Liability Is Included 

CERTIFICATE HOLDER CANCELLATION 

Proof of Coverage SHOULD ANY Of THE A80VE DESCRIBED POUOES BE CANCELLED BEFORE 

THE EXPIRATION DATE THEREOf, NOTICE WILL 8E DEliVERED IN 

ACCORDANCE WITH THE POLICY PROVISIOHS 

AUTHORIZED REPRESENTATIVE 

J 8 

ACORD 25 (2010/05) The ACORD name and logo are registered marks of ACORD 
33 Sea Ave, Quincy, MA 

Docket Management System 

U.S. Dept. of Transportation 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

J,,J,JJJ,,,,J,J,J,J,,JJm,J,,JJ 

Supplement A : Physical Characteristics of MSAerial's UAS 

Dear Sir or Madam, 

Addr: 33 Sea Ave 

Quincy, MA, 02169-3135 

Ph: +1-(857)-204-2448 

Email: mi ndi@msaeri al. com 

VVeb: msaerial.com 

MSPhotography, December 31,2014 

Please find in this document specifications related to the UAS subject to consideration for Exemption. All 

specifications given by the manufacturer. It is of note that these specifications in some instances constitute 

the maximal values discovered by the manufacturer and averaged over several test units. MSAerial utilizes 

these metrics when forming safe and sustainable flight operations and in no way do the specification extrema 

contained herein constitute normal MSAerial flight parameters. 

I. General 

Manufacturer Details 

Specification 

Manufacturer 

Model 

Website 

Contact (Ph) 

Contact (Em) 

Value 

DJI 

SlOOO (Spreading Wings) 

www.dji.com 

us.support@dji.com 

+ 1 (818) 235-0789 
II. Physical Characteristics 

Specification 

Diagonal Wheelbase 

Frame Arm Length 

Supplement A : Physical Characteristics of MSAerial's UAS 

Frame 

Value 

Frame Arm Weight(with Motor, ESC, Propeller) 

Center Frame D1ameter 

1045mm 

386mm 

325g 

337.5mm 

1330g 

460mm(L) x 511 mm(W) x 305mm(H) 

Center Frame Weight 

Landing Gear Size 

Specification 

Motor 

Specification 

Stator Size 

KV 

Max Power 

Weight 

Value 

41 xl4mm 

400rpm/V 

so ow 

158g 

Electronic Speed Controller 

Specification Value 

Stator Size 41 x 14mm 

Working Current 40A 

Working Voltage 6S LiPo 

Signal Frequency 30Hz 450Hz 

Drive PWM Frequency 8KHz 

Weight (with Radiators) 35g 

Specification 

Material 

Size 

Weight 

Propeller 

Value 

Performance engineered plastic 

15 x5.2inch 

13g 

Flight Parameters 

Value 

TakeoffWeight (with payload) 

Total Weight (system only) 

Power 

6.0Kg "' ll.OKg 

4.2Kg 

Battery LiPo (6S,10Ah 20Ah,15C(Min)) 

4000W 

1500W (@9.5Kg total load) 

15min (@15Ah @9.5Kg total load) 

-10"' +40 oc 

Max lost. Power 

Hovering Power 

Hovering Time 

Working Temp 

33 SEA AvE, QuiNCY, MA 02169 - 3135 

M INDI@MSAERIAL.COM + 1-(8 57) - 204-2448 
33 Sea Ave, Quincy, MA 

Docket Management System 

U.S. Dept. ofTransportation 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

1 •• 1.111 •••• 1.1.1.1 •• 11 .... 1 •• 11 

Addr: 33 Sea Ave 

Quincy, MA, 02169-31 35 

Ph: + l-(857)-204-2448 

Email: mi ndi@msaeri al. com 

VVeb: msaerial.com 

MSPhotography, December 31, 2014 

Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM) 

Dear Sir or Madam, 

I. Introduction 

This manual describes the notable roles, tasks, and operations performed by MS photography/MS Aerial. The 

aim is to document everything that is needed to be done during a mission, so it can act as a reference point 

for team members. 

II. Roles and Responsibilities 

As much as is possible, MSAerial staff attempt to have redundancy in expertise and skillsets related to 

operations of the UAS. 

Pilot in Command (PIC) 

• Piloting the UA V. This will include: 

- Takeoff, 

- Normal Flight, 

- Flight during emergency procedures, 

- Landing, 

• Assembling the UAV 

• Performs pre-flight checks of the firmware, 
Supplement B :Summary Sections of Flight Operations and Procedure Manual (FOPM) 

• Performs pre-flight checks of the hardware, 

• Preforms pre-flight checks of the software. 

Spotter 

• Relays notable flight parameters such as flight times, battery strength, metrics from the UAS. 

• Primary communication link between pilot and on-site safety personnel, 

• Will hold physical documents related to current flight, 

• Preforms pre-flight checks of the data collection equipment, 

• Monitors ground and greater above-ground environment for safety concerns 

Technician 

• Assembling the UAV, 

• Preforms pre-flight checks of the hardware, 

• Performs pre-flight checks of the software, 

• Secondary communication link between pilot and on-site safety personnel, 

• Relays to the Spotter and records notable flight parameters metrics from the UAS, 

• Monitors ground and greater above-ground environment for safety concerns 

Ill. Pre-Flight Checklist 

A. Before Power Applied 

• Check for physical damage and any missing hardware, 

• Check all electronics present and connected/ check coord connections are tight. 

• Confirm all batteries charged, 

• Check all rotors and moving parts for debris that would prevent proper operation. 

• Check weather patterns the night beforehand. S!OOO should be raised above the ground when testing 

landing gear or recalibrating servo travel. 

• Check data collection equipment for proper operation. 

• Check data collection equipment for issues that would impact safe operation of flight package. 

B. After Power Source Applied 

• Confirm proper power reading of battery, 

• Run hardware based systems check, 

• Run software based systems check, 

• Check flight LED array, 

• Confirm proper radio link to flight controller, 

• Confirm proper radio link to data collection device controller, 

• Confirm secondary controller connection to UAS onboard flight controller, 

• Confirm waypoints and geofences are accurate to current flight, 

• Confirm desired behavior of emergency i[ifailsafes, 

• Check with on-site safety personnel for any changes in goals I flightpath. 

33 SEA AvE, QuiNCY, MA 02169 - 3135 

MIND! @MSAERIAL.COM + 1 - (8 57) - 204 - 2448 
Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM) 

IV. Flight-time Checklist 

• Check with on-site safety personnel for a safe flight area for first flight, 

• Record relevant metrics in flight log, 

• Check for ground hazards at home-base and rectify, 

• Confirm > 8 satellite GPS lock, 

• Confirm initial state of controllers, 

• Initialize rotors and check for proper operation, 

• Perform controlled flight to hover mode approximately 5m above ground, 

• Check landing gear flight mode (up) operation, 

• Perform controlled multi-axis roll procedure to check for proper orchestrated rotor operation, 

• Perform controlled multi-axis (if applicable) control procedure of data collection package, 

• Switch controller mode to radial based, check proper operation to maximum 5m distance to PIC and 

return to initial position, 

• Return UAS to normal orientation, 

• Perform controlled flight to hover mode approximately lm above ground, 

• Check landing gear landing mode (down) operation, 

• Land the UAS and check for proper de-initialization of rotors, 

• Perform controlled flight to hover mode approximately 5m above ground, 

• Check landing gear flight mode (up) operation, 

• Operate UAS to each waypoint I position until maximum flight time is achieved, 

• Return UAS to normal orientation, 

• Perform controlled flight to hover mode approximately 1m above ground, 

• Check landing gear landing mode (down) operation, 

• Land the UAS and check for proper de-initialization of rotors, 

• Remove power to the flight package, 

• Remove power to the data collection package, 

• Remove power to controllers, 

• Complete flight log. 

V. Standing Procedures 

• The Pilot, Spotter, and Technician will be the only MSAerial staff members in the forward flight area. 

On-site personnel will be within verbal range and behind MSAerial staff. 

• The maximum power used to control the device is soft limited to 75% in order to maintain power in 

reserve for unforeseen conditions, 

• Flight time is limited to 15 minutes and goals will be planned in phases to be accomplished during this 

time. 

• Flight time is limited to reserving 25% battery power, 

• Flight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 300ft, 

whichever is less. 

• Flight time is limited to operation in safe environmental conditions, 

• Flight staff will maintain proximity so as to be in clear and unaided verbal range, 

• The PIC will announce all movements to MSAerial and on-site staff so that non-PIC staff members can 

identify possible safety concerns before operation of the UAS to the next waypoint or position, 

33 SEA AvE, Q UINCY, MA 02169-3135 

MINDI@MSAERIAL.COM + 1 - (8 57) - 204-2448 
MS Photography/MS Aerial 

Operations Area (Attached VFR Chart with 

Coordinates) 

41° 59' 13" N I 70° 57' 54" w 
ACORD0 

CERTIFICATE OF AIRCRAFT INSURANCE I OA TE (MMIDOIYYYY) 

10/6/2014 

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS 

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES 

BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED 

REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER. 

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATION IS WAIVED, subj ect to 

the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the 

certificate holder in lieu of such endorsement(s). 

PRODUCER CONTACT 

NAME: Transport Risk 

Risk 

1242 Timber Drive, Suite 5 I Extl: 720.208.0844 I Nol: 720.208.0845 E·MAIL Conifer, 0 80433 ADDRESS: 

I ID 1: 

INSURER(S) AFFORDING COVERAGE % NAIC. 

INSURED INSURER A: StarNet insurance Company 100 40045 

MS Aerial and MS Photography INSURER B: 33 Sea Avenue 

Quincy MA 02169 INSURER C: 

INSURER D : 

INSURER E : 

INSURER F: 

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD 

INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS 

CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, 

EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. 

POLICY INFORMATION CERTIFICATE NUMBER: 21910614 

PLEASURE & BUS I COMMERCIAL AIRPLANE HELICOPTER 

HULL & LIABILITY 

YEAR I MAKE 

2014 DJI 

TERRITORY: 

AIRCRAFT COVERAGES 

I LIABILITY ONLY 

I MODEL 

ls1ooo I SERIAL NUMBER TRM767 

REVISION NUMBER: 

QUOTA SHARE 

I REGISTRATION NUMBER 

N/A 

INSURER LETTER I POLICY NUMBER 

A BA-14-05-0021 0 I EFFECTIVE DATE I EXPIRATION DATE 5/21/2014 5/21/2015 

ADDITIONAL INSURED? (YIN) I SUBROGATION WAIVED? (YIN) 

y N 

COVERAGE OPTIONS LIMIT APPLIES TO LIMIT APPLIES TO 

$ $ AIRCRAFT HULL 1-- 1--

$ 

$ 1,000,000 EAOCC $ EAPER AIRCRAFT LIABILITY I--

$ EXCLUDED EAPASS $ AGGR 

INCLUDING CREW 

MEDICAL PAYMENTS 1-- $ 5,000 EA PER 

I EXCLUDING CREW 

COVERAGE 

CODE DESCRIPTION OPTIONS LIMIT APPL.IES TO LIMIT APPLIES TO 

$ $ - - $ $ 

$ $ (-- 1--

$ $ 

f-- f-- $ $ 

$ $ 

DESCRIPTION OF OPERATIONS I REMARKS (Attach ACORD 101 Additional Remarks Schedule if more space is required) 

It is agreed that the Certificate Holder is included as an Additional Insured under the Aircraft Liability Coverages, but only to the extent of 

liability vicariously imposed upon the Certificate Holder solely as the result of an act or omission of the Named Insured or its employees in 

connection with the Named Insured's Aircraft operations, subject to all policy terms. conditions and exclusions. 

The Company has made the provision to give the Certificate Holder prompt notice of cancellation of any policy above. But, the company assumes no 

responsibility' for failure to provide such notice. This Certificate does not change in any way the actual Qy_ the_Q_oli<;y, 

CERTIFICATE HOLDER CANCELLATION 

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE 

State University 

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN 

131 ummer Street ACCORDANCE WITH THE POLICY PROVISIONS. 

Bridgewater MA 02325 AUTHORIZED REPRESENTATIVE 

Diane Beane 

© 2009 ACORD CORPORATION. All nghts reserved. 

ACORD 21 (2009/12) The ACORD name and logo are registered marks of ACORD 

CERT NO.: 21910614 Diane Deane 10/6/2014 3:20:59 PM (PDTI Page l of 1 
Li 

Invoice: #H599494 

Tuesday, 29 Aprial 2014 

SOLD TO: 

MS Photography 

Melinda Sogoloski 

33 Sea Ave 

Quincy, 02169 

Massachusetts, United States 

Order #: H599494 

Products 

DJI S1000 PREMIUM, A2 AND ZENMUSE 50 MKIII COMBO SN # 0200020888 

FUTABA 10JH 2.4G Heli R3008SB S/FHSS 

Mode 2 SN # 840313003 

PLU15-1 60006 PULSE LIPO 16000mAh 6S1P 

22.2V 15C 

Invoice 

-r 

730 

HeliDirect 

Eastern Ave., Umt 096 

East Boston, MA 02148 

8

USA 

77-HDX-HELI 

781 -443-6185 

I DELIVER TO: I 

jMs Photography I I Me linda Sogoloski I 

- j33 Sea Ave I 

EjQuincy, 02169 I !Massachusetts, United States I 

- - I I I 

.. 

Date of Order: 04/29/2014 

SKU 

1 

Ship 

Qty 

FUTK9201 1 

PLU15-160006 1 

Payment method: Credit Card 

Qty Price (EX) 80 

$6,560.00 

$349.98 

$0.00 

SubTotal: 

Shipping 

Total: 

Cost: 

Total Pay!flent Paid: 

Total Refunded: 

Total (Inc) 

$6,560.00 

$349.98 

$0.00 

$0.00 

$6,909.98 

$7,519.96 

$609.98 

I 

-t-
FAA UAS Civil COA Request 

Any information that is provided is bound by the Freedom of Information Act (FOIA) and may be releasable. This 

requires compliance to FOIA and consent to the release of your information. If you do not consent to the release of 

your information, you must contact us for further guidance. For more information, please visit http://www.foia.gov/. 

Date I J}x. ,f.£i- lbl'l 

333 Exemption # or 

Federal Register Docket# 

Proponent Information 

Contact Name !Melinda Sokoloski 

Company Name IMS Photography DBA MS Aerial 

Street Address 1 j33 Sea Ave 

Street Address 2 

City lauincy 

State IMA Zip Code .._10_2_16_9 _____ __, 

Phone Number Iss? -204-2448 

E-mail Address lmindi@msaerial.com 

Aircraft System 

Aircraft Type IUAV 

Aircraft Registration lsN # o2aoo2osss 

Performance Characteristics 

Climb Rate 

(Feet/Minute) 

1350 feet per minute Descent Rate 

(Feet/Minute) 

1250/350 per minute 
Turn Rate lao introversive and a 3° Approach Speed !maximum thrust of 2.!i4 

(Degrees/Second) 

Cruise Max !30-45 mph Min !Hover 

Speed 

Gross Takeoff Weight 111 kg Max Launch/Recovery !Automated Return to 

Operational Information 

Location 

Altitude 

Description of 

Operation 

Bridgewater State University ( 131 Summer Street, Bridgewater, MA 

02324) Possibly other privately owned locations within the New England 

e 

1200 Feet Distance from 

nearest Town/City 

Melinda Sokoloski along with a pilot and an observer have been 

asked to film a few moments of B roll in a tightly controlled 

enviroment. On the Campus of Bridgewater State university. There 

will be a few days of filming. Projected filming for other companies 

would take place in similar conditions, meaning saftey and education 

would be on the forefront. This includes knowijng regulations and 

weather conditions. 

Operations Area (Attach VFR Chart with Coordinates) 

Class of Airspace 

D A 

D Under Mode C Veil 

o o 

llJ G 

Flight Conditions 

llJ VFR D IFR 

Air Traffic Communication 

D VHF 

Transmitter 

0 Yes 

0 No 

D B (Requires FAA HQ approval) 

o c 

D E 

D G (With an operational ATC Tower) 

Receiver 

0 Yes 

0 No 

Guard (Emergency Frequency) 

0 Yes 

0 No 
!Z] UHF 

Procedures 

Transmitter 

@ Yes 

0 No 

Lost Link Procedures 

1. How long to activate LL procedure 

Receiver 

@ Yes 

0 No 

lmmeditely after line of sight may be 

compromised . There are 2 spotters at all times .c 

3. Lost Link Route 

f I tell it to or the signal is dropped it will fly back 

to where it is told . I preprogram the altitude it ii: 

5. Flight Termination Point 

Never beyond line of sight and below 450' 

Lost Communication Procedures 

1. Between Pilot and Air Traffic Control 

Guard (Emergency Frequency) 

@ Yes 

0 No 

2. LL Altitude 

1450 feet 

4. Lost Link Point 

Beyond line of sight. We do not fly beyond 

line of sight. 

The MSPhotography/MS Aerial team would never be within in the range of airfields or restricted 

airspace. The coordinates are: 41 ° 59' 25" N I 70° 58' 32" W 

2. Between Pilot and Observer 

Procedurally we would not allow an observer to be any farther than speaking distance. It can be 

said that fundamentally, the primary role of the observer is to maintain communication with the pilot 

as a first directive .. 
Observer 

Line of Sight of Observer 

1Z1 Yes 

D Other 

Observer Location 

Time of Day 

Transponder 

!Close enough to be within speaking distance. lij 

@ Day 

@ Yes 

0 No 

0 N/A 

0 Night 0 Both 

Mode C D 

Please return completed form to 9-AJV-115-UASOrganization@faa.gov.