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### 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 existsfor 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 S ecretary 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 proceduresfor 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 datacollection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pres ented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial (seeDocket No. FAA

−2014

− 0352), 11109 to Clayco, Inc. (seeDocket No. FAA

−2014

− 0507), 11112 to VDOS Global, LLC (see Docket No. FAA

−2014

− 0382), and 11213 to Aeryon Labs, Inc. (seeDocket 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 signi ficantly greater proporti ons, 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 torelief previously re quested 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 inthe 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 payl oad. 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 PI C 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 betweenthe conditions and limitations in this exemption and the pro cedures 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 revi se 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 aff ect 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 functi onal 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 f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C 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, vehi cles and structures. PIC qualification flight hours and currency mustbe 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 nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants 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 rule s (SVFR) are not authorized. 16. The UA may not operate within 5 nautical mile s 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 whenvisibility 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 f light 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 tothe 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 es sential 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-s cene operation of the UAS; d. Make, model, and serial or N

−Number of UAS to be used; e. Name and certificate number of UAS PI Cs 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 Service33 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 1 35 Ph: + 1 -(857)-204-2448 Email: mindi@msaerial.com

VVeb: msaerial.com

MSPhotography, December 31, 2014 Re: Exemption Request Pursuant To Section 333 of th e 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 cu rrent operation of sUASs for commercial purposes has been halted to comply with recently enacte d federal aviation regu l ations pertaining to sUASs. As descr ibed more fu ll y below , the requested exemption wou ld permit the operation of small, unmanned and re l ative l y inexpensive multirotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on -s ite safety personnel controlling access, and 4) wou ld provide increased safety and enhancements to clients' business operations.

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

- (857)-204-2448 Emai l: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 1 3 (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 Ex t e nt of Re lie f MS Aerial S e e k s a nd t h e Re ason I t Seeks Suc h Re li e f : MSAerial submits this application in accordance with the R efo rm 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 industri es, 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 characte ri stics, 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 contro lled operation in populated areas, 33 SEA AvE, QuiNCY, MA 02169-3135 MINDI@MSAERIAL.COM 

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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of201 2

• Operat ion of the UAS by VLOS.
• Coordinatio n by a minimum of4 persons, three staff members of MSAerial a nd one safety official from the cl ient. Spec i fic co n side r ati on is outline below

. 1 4 C.F.R. Pa r t 2 1 , Sub p art H : Airworthin ess Ce r ti fi cat es 14 C.F. R
. §91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the procedural re quire

m e nt s for th e issuance of airworthiness certificate s as required by F AR §91.203 (a) (1 )

. Given the size and limit e d ope r atin g area associated sUASs, an exemption from Part 21 Subpar t H m ee ts the requireme nts of an e quival e nt level of safety under Part 11 and §333 of th e Refo rm Ac t. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act bo t h authorize the FAA to exempt aircraft from the requirement for an airworthiness ce rtificate, upon consideration of the size, w e i g ht, speed, operational capability, and proximity to airports and populated areas of the particu l ar sUAS. In all cases, an anal ysis of these criteria demonstrates that th e UAS operated without an airworthiness certific ate , in the res tricted environment and under the conditions proposed will be at least as safe, or safer, than a conve ntional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated by MSAerial is les s than 11k g. wit h maximal payload consisting of remote se n sing instrumentation, carr i es neither no per sons, carries no explosive or flammable mate rial s including combustib le fuels, and operates exclusively wi thin a secured area. Unlike other civil airc raft , operations under this exemption will be tightly controlled and monitored by both the pilot (P I C), 'spotter' role designated to act as both the remote sensing controller and secondary monitor for safety i ssues, and a technician, which assists in matters related to maintaining the sUAS and also m onitors for sa fety concern s and liasons to the on - s it e safety officials. These enhancements to current safety practices and regulations, which already apply to civ il aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operation s conducte d with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H
. Lastly, application of these same crite ria demonstrates that there is no intrin s i c cre dibl e threat to national secu rity po se d by the UAS, due to its size, speed of operation, lo cation ofoperation, l ack of in trinsi c exp losive materials or flammable liquid fuels, and inability to carry a substantial exte rn al load.
1 4 C.F.R. §45.23 (b ). Marking of th e Airc raft The regulation re quires: When marks include only th e Roman capit al le tte r "N" and the registration number is displayed on limit e d , re st ricte d or light-sport category aircraft or ex p er im e ntal or provisionally certificated aircraft, the operator must al so display on that aircraft n ear eac h e ntr a n ce to th e cabi n , cockpit, or pilot station, in lette r s n ot less than 2 in c h es nor more than 6 inch es high, the words " limited; ' "restricted;' "light-sport;' "expe rim enta l ;' or "provisional;' as applicable.

Even though the sUAS will have no airworthiness certificate, an exe mpti on may be n ee ded as the sUAS will have no entrance to the cabin, cockpit or pilot station on which t he word "Experim enta l " can be placed. G iven the size of the sUAS, two-inch lettering will be impossible. The wo rd "Expe rim ental" will be placed on the frame in compliance wi t h §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 other s working with the sUAV will see the identification ofthe UAS as "Expe ri mental." The FAA has issued the following exe mpti ons to this regulation to Exemptions Nos. 10700, 8738, 101 67 and 101 67A.

Further m arkings include the use of flashing green LED illumination on the underside of the sUAS frame which s tand s at co ntra st against a blue or white sky.

33 SEA AvE, QuiNCY, MA 02169

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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

14 C.P. R. §6 1.11 3 (a) & (b): Private Pilot Pri vil eges 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, th e proposed ope rations can achieve the eq uivalent level of safety of current operations by requiring a ground crew member to have a private pilot's license rather than a comme rcial pilot's lic ense 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).
1 4 C.P.R. §91.7(a): C ivil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unl ess 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 ofwhich are provided in enclosed Supplemental material, an equivalent level of safety will be provided.
14 C.F.R. §91.9 (b) (2): C ivil Aircraft Flight Manual in t h e Aircraft. §91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft

... (2) For which an Airplane or Rotorcraft F light Manual is not required by §21.5 of this chapter, unles s th e re is available in the aircraft a current approved airp l ane or Rotorcraft Fli ght Manual, approved manual material, markings, and p l acards, 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. §9 1.10 3: 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 airc r aft performance data before initiation of flight. Further, we have proprietary manuals c reated 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 in s truction §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 cont rols. Flight control is accomp lished 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 

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### Re: Exemption Request Pursuant To Section 333 of the FAA Ref orm Act of2012 speed of the aircraft. Enhanci ng this safety is the t echnology inh ere nt in the remote controls utiziling digital com muni cati on s wh i ch is paired to the sUAS m aking it n early impossible to unintentionally or intentionally h ave the con trol commun ications interrupted.
1 4 C.F.R. §9 1.119 : M in imum safe altitudes §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimu m s prescribed, provided the person operating the h eli co pter complies with any route or altitudes prescribed for helicopters by the FAA. As this exe mpti o n is for a sUAS that closely mimic s the behavior of a h elicopter, and the exemption reque sts authority t o operate at altitudes up to 400 AG L, an exempt ion may be needed to allow such operations. As se t forth herein, th e UAS will never operate at higher than 400 AGL or b eyo nd unaided visual line of sight, whichever is closer. It will however be operated in a r es tricte d area with sec urity officials tasked with ensuring pub l i c sa f e ty , and where buildings and people will not be exposed to operations without their pre -obtained consent and training.

The eq uival e nt l e vel of safety w ill be achieved given th e size, weight, speed of th e UAS as well as the location wh e re it is o p erated

. No flight operation will be take n without th e permission of th e property owner in t he case of private prope rty o r loc a l officials i the case of public prope rty or private property with public interests. B ecau se of th e adva nc e notice to the property owner and participants in the remote sensing activity, all affected individu als will be aware of the planned flight operations. Compared t o flight operations with aircraft o r rotorcraft weighting fa r m ore 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 t hose presently pre se nted with conventiona l ai rcraft operating at or below 500 AGL. In addition, the low

- altitud e operations of the sUAS will e n sure separation between these s mall

- UAS operations and the operatio ns of conventiona l aircraft that must comply with §91.119.
14 C.F. R
. § 91. 1 21 Altime t er Settings §91.121 requires eac h person operating an aircraft to maint ain cruis in g altitud e by refe rence to an altimeter that is set "
... to the el evati on of the departure airport or an appropri ate altim ete r setting available before d eparture." As th e sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption m ay be ne e d e d

. An equivalent lev e l of safety wi ll b e achieved by th e operator, confirming the altitud e of th e launch s ite sh own on the GPS altitude indicator b efo re flight. The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee accurate dete c tion of height.
14 C.F.R. §9 1.15l (a): Fue l Requirements for Flig ht in VFR Conditions §9 1.1 5 1 (a) prohibits an individual from beginning "a flight in an airp l a n e und er VFR conditions unl ess (considering wind an d fo recast weather conditions) there i s enough fuel to fly to the first point of inte nd ed landing, and, assuming normal cruising speed- (1) During the d ay, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes:' The batt ery 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 §9 1.15 1. Operating the small UAS, in a tightly controlled area where on ly people and property owners or official representatives who have s igned waivers will be allowe d , with less than 30 minutes of reserve powe r , does not enge nd e r the type of risks that Sectio n 9l.l51(a) was intended t o alleviate give n the size and speed of the s mall 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 o p e ra ti n g area .

Similar exe mption s h ave been granted to other operation s, includin g E xemptions 2689F, 5745, 10673 , and
33 SEA AVE, QUINCY, MA 02169

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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012
10808.

1 4 C.P. R
. §9 1. 2 0 3 (a) & (b): Car ryin g C i v il A ircraft Cert i fica ti on a nd Reg i str a t ion 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 civi l 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 wi ll 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.
1 4 C.P. R. §9 1. 405 (a); 4 0 7 (a) ( 1 ); 4 0 9 (a) (2); 4 1 7(a) & ( b ): Mai nte n a n ce I nsp ect i o n s 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 sma ll 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 in itiating 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 wou l d 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 determ i ned areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goal s. Technical enhancements to current safety controls will allow MSAerial to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being imp lemented by the FAA and Department of Transportation. Further, MSAerial conducts its operations in compliance with protocols described here i n or as otherwise established by the FAA.
II. C o m me rci a l and Publi c Benefit s 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 so lvable 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 

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### Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 by photographic, videographic or lidar based s ur veying. By moving these functions onto sUAS base d a ircraft, the potential for l oss of life or prop erty is diminished due to the g reater con tro l in a smaller and safe r aircraft that holds no persons. Second, th ere are n o r eac tiv e or combustible mate rial s on board the sU AS and thus the potenti al for fire or explosions is greatly diminished. Third , the s mall size and extreme man e uverability of MSA er ials UASs allow the PIC to avo id hazards. Lastly, du e to the natu re of the remote se nsing instrumentation onbo ard, the sUAS can maint ain quite a safe dis t ance between the aircraft and the objec t (s) undergoing sc rutin y. Acco rdingly, MSAerial's UASs have operated and will contin ue to operate at and above current safety levels.
A
. The cos t s and b enefits of you r propo s ed a ction t o socie t y in general and s p eci fi c gro up s wi th in s ociety 

### A s described above, MSAerial's past customers hav e been s m all to medium bus iness seeki ng a remote se n s in g solution to specific issu es before a large r effort on th eir part would com e und e rway. Examp les includ e co n s truction efforts that so u ght elevated photog raphic imagery of specific landform s to minimize cost of e ffort s to develop, a regional park se rvice that wanted to quantify the changing lif ecycle of it's flora by way of m easu r ing leaf health through gra dual chlorophyll depletion, an d a local ci ti es' Dep t. of Public Works that sought to collect images and 30 st ructural data by way of Lidar sensi ng 

### en masse of it's bridges to serve as a suppleme nt to it's routine repair and planning documentation.

The impact to society, financial and otherwise, would be ext remely minimal. In deed, it's bee n demonstrated th at sUASs have the abi lity to drasticially increase the inf o rmation availible to policymakers at a frac ti on of the cos t of measurin g th is d ata by terrestrial m ean s. One s uch impact would be inconvenience to directly proximal and non -esse ntial p ers onne l that wou ld b e displaced from public or busin ess owned p r operty if it is d ee med to be unsafe. In this case we relay our needs for a f1ight zone with the requirem en t that it be safe from casual in trusions and allow the business time to sh ift operations in order to m i nimize potential safety issues. This is best performed with the aid of safety p erso n ne l that actively steer no n -essent ial persons around th e flight zone . 1
. Th e e ffe ct of an exe m p t io n f o r MSA e rial o n t h e qua lity o f t he n atu ral and socia l e n vi ro nments 

### Utilizing sUASs minimizes the requirement for con ventional airc raft. Th is eliminates the need for an on boa rd pilot, time consumin g adherance to regulations s urroundin g bookeeping a nd s ubmi ss ion of fli ght path s to local civiliar or milit ary airports, and detrim ental effec ts to the environment caused by operating a co mbustib le fuel bas ed, large scale aircraft, with r es tri ct ions on the proximity to the targ e t for remote sensing.
Ill. F lig ht Capabi liti e s a n d Ch a ra ct eris ti c s of MSA e ri a l's UAS s 

### Persuan t to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and characteristics of the sUAS. 1



### MSAerial UAS s utili zes eight (8) counter-rotating propellers paired oppositely to each other for balance, control and stability. The total s pan of the sUAS is ""'1.2 m all owing for stab le flight or landing even with the sudden onset of d etrim e ntal e nv ironmental conditions. The sUAS's hav e a maximal un it+ payload ma ss of llkg, including cinematic/photographic or other surveyi ng equipment. M SAeri al's sUAS is designed to prim arily hover in place to cap ture photographic data and then operate a t less than a 35 knot maximum s p eed to th e n ext point of interest. They are capable ofvertical and horizontal operations but, in practice, is operated only wi thin 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 perso nn el are suppleme nted by safety offcials provided by the client who are instructed to cordon

1 More characteristics have been outl in ed in the enclosed supp lemen tal materials. 33 SEA 

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### + 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 a ll ows the PIC to utilize one controller axis to recall the VAS to the PIC's position without concern to the cur rent heading of the sUAS. In the event of loss of sight of the sUAS into an area co nt aining hazards or possible hazards, the spotter ha s a heads

- up-display containing a live video feed which can be used to locate the UAS wh il e 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 cond itions within the scope for sUAS operation. All ofMSAerial's sUASs utilize LiPo (lithium polyme r) 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 amp le time to control the sUAS to a safe landin g zone. MSAerial further restricts flight time by not operating it s 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 compensate d a safe and successful landing can still occur. I V. Reasons Why an Exempt i on to MSAeria l Wi ll 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 th e 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 Co ngress's contemplated safety zone. MSAerial sUASs have an established safety record bolstered by multi-point preflight check li st, awareness of their surroundi ngs and intim ate knowlege of the behaviour of the sUAS platform in many weather conditions. TI1is safety record and impl emented 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 close l y 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 damag e or injury. MSAerial also continues to work closely with thi s organizatio n to identify and mitigate sUAS platform risk due to their expertise in several industries closely related to th e aviation and transportation.

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

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### Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform A ct of20 12
MSAerial standardized on the foll owing practices to ensure safe operation of it's UASs:

• Work wi th on-site personnel to plan the flight goa l s,
• Work with on-site personnel to restrict access to non -esse ntial persons,
• Operation by unaided VLOS operation only,
• Operation in phases 10 minutes in length,
• Operation to minimal 25% battery power,
• Operation of d ev ice to GPS aided readout to 300ft at maximum,
• Num e rous pre - programmed fail

- safes that ensure specific b e havior per i ss u e,
• Three m ain roles s upplemented by on -s ite safety p e rsonn e l , • Empl oy contro ll ed life cycle management of compon en ts to guard against multiple failures,
• Preform a site check day(s) before flight t o identify poten ti al issues,
• Subscribe to relevant local weather and safety al erts,

Expertly choose data collection in stru m ents and accessories to minimize flight requirements or expe r tise,

MSAerial has exper ience in sim ilar fields and has ad apted this experience in it's use of UASs to increase safety. In co mbination to th e ever expanding knowlege reposito ri es from hobbyist s and experts alike, M SAeria l i s constantly evo l ving it's practice s when th e re is a clear benefit to ope ration s or increas ed safety e l ement. **A. Summary**  Pursuant to 14 C.F. R. Part 11 , the following summary i s provid e d for publication in the Federal Register, sho uld it b e d eter min ed that publication is needed:

MSAerial {applican t) see k s an exemption from the fo llowin g rul es : 1 4 C.P.R. §2 1, s ubpart H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03{b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 9 1.4 09 (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 re mo te sensing ope r at i ons. Approval of exemptions allow in g commercial operat ion s of sUASs in the the media indu st ry will e nhan ce safety by reducing r isk associated with conventional aircraft ope r ations and othe r means of elevated re m ote sensing involving persons. The public benefit se rved by approval of this petition i s increased aware n ess o f characteri stics of difficult imaging targets. A sUAS we i ghing fewer than 1lkg and powered by sealed batteries eliminates virtually all associate d risk inherent in operating conven tion al aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able t o collect needed d ata.

The operation of small UASs, we ighting less than 55lbs., co ndu cted in the str ic t conditions outlined above, will provide an eq uival e nt level of safety supporting the grant of the exemptions requested herein, including exempting the app li ca nt from the requirements of Part 21 and allowing c omm erc ial operations. 33 SEA AVE, QUIN CY, MA 02169

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### 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 p rofessional in the various photographic industries. Mrs. Sokoloski and her companies have been producing and delivering media and tec h nical solutions for the media service in du stry for ten ( 1 0) years with a spotless safety record. The FAA has b een given the authority to iss ue the exemption to MSPhotography DBA MSAerial purs u ant 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 

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

• All regular and irregular ope r ations are noted w ith t imestamps, relevant UAS metrics and co rrective

action procedures (CAP) t hat are performed.

- Note: All irregu l ar behavior have root cause analysis performed before UAS operation is resumed.
VI. Emergency Pr oce du res

• Loss of Remote Signal

- The flight package features an optional enhanced fail-safe which returns the UAS to the h ome base waypo int via the same path taken to point of lost signal.

- The UAS will then prefo r m a hover over this waypoint and then a co n tro ll ed landing.
• Loss of GPS signal

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

- 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 prefo r med by a seperate system and so l oss of GPS wi ll 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 a r e trans l ated based on current orientation and will behave as normal operation to the PIC to ensure a safe l anding,

- I n the event of multiple rotor or motor failures the flight package can be configured to preform a safe l and ing 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 w ill not affect operation of the flight. The unit will be piloted to a safe l anding area and then l anded so that examination of the link can be made.



### Norfolk, SS
. Commonwealth of Massachusetts December 

### i H , 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 an d deed and for its stated purpose .

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## 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 CERT IFI CATE 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), AUT HORIZ ED 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 : C e rtain Underwrite rs at Lloyd '&, London INSURED INSURER·B : MS Photography INSURER·C : 33 Sea Ave INSURER·D : Quincy MA 02169 I N SU RER·E : INSURER · F : COVERAGES :ERTIFICA.rE REVISION THIS IS TO CERTIFY THAT THE POUCIES OF INSURANCE USTED BELOW HAVE BEEN ISSUED TO TH E 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 ISS UED 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 GEN ERALLIABILITY PP4003590 l/21/2014 1/21{2015 EACH OCCURRENCE $1,000,000 X CO MMERCIAL GENERAL LIAB I LITY D AMAG E TO RENTED PREMISES $ 1 00,000 fXl occuR {Ea occu rrence) CLAI MS MAD E 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) $



## - ALLOWNED 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 I RETENTlON$ W0RJ<ERS COMPENSATION 

# · ll
OTHER AND EMPlOYERS' UA8ILITY **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 LIM IT $ Hired & Non-owned Auto Liability Is Inc lu d ed 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 REPRESENT ATIVE 

# J 8

ACORD 25 (2010/05) The ACORD name and logo are reg istered marks of ACORD33 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

S uppl e m e nt A : Physical C h arac t e r i s t ics of M SAeri a l's UAS

Dear Sir or Ma d am, 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 dis covered 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 spec ification extrema contained herein constitute normal MSAerial flight parameters.
I. Ge n e ral M an ufacturer Details

Specification Manufacturer Model Website Contact (Ph) Contact (Em) Value 

## DJI SlOOO (S preading 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 F ram e Weight Landing Gear Size

Specification Motor Specification Stator Size KV Max Power Weight Value 41 xl4m m 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 Va lue Performan ce engineered plastic 15 x5 .2inch 

### 13g

Flight Parameters Value TakeoffWeight (w ith payload) Total Weight (sys t em 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 

# o c Max lost. Power Hovering Power Hovering Time Working Temp

33 SEA AvE, QuiNCY, MA 02169

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- 204-244833 Sea Ave, Qu i ncy, MA
Docket Management System U.S. Dep t. ofT r a n sportation 1200 N ew J e r sey A ve., SE W as hington, 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 )-2 04-2448 E m ai l: mi ndi@msaeri a l. com

VVeb: msaerial.com

MS Ph otography, December 31, 2014 S u pp l ement B : S u mm a ry S ec tion s of Fligh t O pe r ation s an d P rocedu re Ma n ua l ( F OP M )

Dea r Sir or Madam , I. I ntroduction This manual describes the n otable roles, tasks, and operations performed by MS photography/MS Aeria l. The aim is to d ocument everything that is needed to be done du r in g a m i ssion, so it can act as a refe rence poin t for team m e m bers.
I I. R o les and R e spon sibi l iti es As mu c h a s is po ss i b le, M S Ae ri al s ta ff atte mpt to h ave re dund ancy in ex p e r t ise a nd s kill se ts re late d to ope r at io n s of th e U A S.

P il ot in Co m ma n d ( PI C)

• Piloti n g the UAV. This will in clu d e:

- Tak eoff,

- Norm al Fli g ht ,

- Flight durin g eme rge n cy proc e dures,

- La ndi ng, • Assembli ng the UAV • Perfo r ms pre - flight checks of the fir m wa re ,

### 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 Tec hn ician

• 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- Fligh t Chec kl is t A. Bef o r e P ower A ppl ie d


### • Check f or physical damage and any missing hardware , • Check all elec tronic s 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 collect ion equ i pment fo r issues that wou ld impact safe operation of fl ight pac kage. B

. Afte r Po we r So ur ce Appli e d


### • 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 controlle r, • Confirm secondary controller connection to UAS onboard flight cont roller, • 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 approximate l y 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 prox im ity 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 possi ble 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 Aeria l

Operations Area (Attached VFR Chart with Coordinates) 

## 41° 59' 13" N 

# I 70° 57' 54" 

# wACORD 0 

## CERTIFICATE OF AIRCRAFT INSURANCE 

# I OA TE (MMIDOIYYYY)

10/6/201 4 THIS CERT I FI CATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO R I GHTS UPON THE CERTIFICAT E HO L DER. THIS CERTIFICATE DO E S NOT AFF I RMATIVELY OR NEGA T IVELY AMEND , EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW

. TH I S CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER ( S ), AUTHORIZED REPRESENTATIVE OR PRODUCER , AND THE C ERTIFICATE H OLDER. IM PORTANT : I f the certificate holder is an ADDITIONA L INSURED , the policy(ies ) must be endorsed. If SUBROGATION IS WAIVED , sub j ect to the terms and condition s of the poli c y , c ertain policies may require an e n dorsement. A s t atement on this certificate does not c onfer rights to th e certif i cate holde r in lieu of such endorse m e nt ( s)

. PRODUCER CONTACT T r ans p ort Ris k NAME : Ri sk 1 242 T im ber Drive , Su i t e 5 I Extl: 720

. 2 08

. 08 44 

### I Nol: 720.208.0845 E · MAIL Co nife r , 0 8043 3 ADDRESS: I I D 1 : INS U R ER (S ) A FFORD I NG COVERAGE % N A IC. I NS U RED I N SU R E R A: St arN e t i nsu r a n ce Company 100 4004 5 M S A e ri a l an d MS P h otog raph y IN S U RER B: 3 3 Se a Avenue Quincy MA 0 2169 I N SU RER C: I NSUR E R D : INSUR E R E : INSU R E R F: THIS IS T O CERT I FY T HAT THE POLICIES OF I NSURANCE LISTED B E LOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR TH E POLICY PERIOD I NDICATED. NOTWITHSTAND I NG ANY REQU I REMEN T , T E RM OR CONDITION OF ANY CON T RAC T OR OTHER DOCUM E NT WITH R ESPECT TO WH I CH T HIS CERTIFICATE MAY BE I SSU E D OR MAY PERTAIN, THE INSURANCE AFFOR D ED BY T H E POLIC IE S DESCRIBED HERE I N I S SUBJECT TO A L L THE TERMS , EXC L US I O NS AND CONDITIONS OF SUCH POLICIES

. LIM I TS SHOWN MAY HAVE BEEN REDUCED BY PA I D CLAIMS

. POLICY INFORMATION CERTIF I CATE NUMBER : 219106 14

PLEASUR E & BUS I COMMERCIAL AIRPLANE HELICO PTER HULL & LIABILITY

YEAR 

# I MAK E 2014 DJ I TERRITORY: AIRCRAFT COVERAGES I L IAB ILITY ONLY 

## I MODEL ls 1 ooo 

# I S E R I AL N U M BER TRM76 7 REVISION NUMBER :
QUOTA SHARE 

# I R EG I STRATION NUMBER N /A

I N S URER LETTER 

# I POL I CY N U MB E R A BA
- 14 - 05 - 00 2 1 0 

# I E FF EC TIVE D AT E 

# I EXPIRATION DATE 5/2 1 /201 4 5/21/20 1 5 ADD I TIONAL INS U RED? (YIN) 

# I S U BROGATION WAIVED? (YIN) y N COVERAGE OPTIONS L IMIT APPLIE S TO LIMI T APPL I ES TO $ $ AIRCRAFT H ULL 1-- 1-- $ $ 1 ,000,000 EAOCC $ EAP E R AI R CRAFT LIABILITY I-- $ EXC L U D E D EAPASS $ AGGR I NCLUDING CREW MEDICAL PAYME N TS 1-- $ 5 , 000 EA PER I EXCLUDING CREW C O

VERA G E C O DE D E SCRIPT I ON OP T I O N S LIMIT APP L

. I ES TO LIM I T APPLIES TO $ $



## - - $ $ $ $ (-- 1-- $ $ f-- f-- $ $ $ $ DESCRIPTION OF OPERATIONS I REMARKS (Attach ACORD 101 Additional Remarks Sch e dule i f more space is required) It is agreed t ha t t h e Certifi ca t e Holder is incl uded as an Additiona l Insu r ed u n der th e A i rcraft Liability Coverages , but only to t he ext ent o f l i a bi l ity v i ca ri o u sly i mpose d up o n the Certifi cate H o l d e r solely as t he r es u lt of an act or omission of t he Named In s ured or i ts em pl oyees in con n ection w i th th e N amed I nsu red 's A i rcraft o p erati ons, s u bject to all p o l i cy t e r ms . c on d i ti on s an d e x c l us i on s . Th e Compa n y has made t he p rovis i on to give t he Certificate Hol d e r prompt not i ce of ca n cellation of a n y policy above

. Bu t , the com p an y assumes no respo n sibili ty'f or fa i lure to prov i de such notice. Th i s Certificate does not change in any way the actual Qy_ t he _Q_

ol i <;y, CERTIFICATE HOLDER CANCELLATION SHOU L D ANY OF THE ABO V E DESCR I BED POL I CIES BE CANCEL L ED BEFORE State U n ive rs i ty THE EXPIRA TION DA T E THEREO F, NOTICE WILL BE DELIVERE D I N 131 u mmer Street ACCORDANCE WITH THE POLICY PROV I SIONS

. B ri dgewate r MA 0 2325 AUT H OR I ZED REP RE S E NTA T IVE

Diane Beane © 2009 ACORD CORPORATION. All nghts reserved

. ACORD 21 ( 2009/ 12) The ACORD name and log o are registered marks of ACORD C E RT NO.: 21910614 Diane Deane 10/6/2014 3:20:59 PM (PDTI Page l of 1LiInvoice:#H599494Tuesday,29Aprial2014SOLDTO:MSPhotographyMelindaSogoloski33SeaAveQuincy,02169Massachusetts,UnitedStatesOrder#:H599494ProductsDJIS1000PREMIUM,A2ANDZENMUSE50MKIIICOMBOSN#0200020888FUTABA10JH2.4GHeliR3008SBS/FHSSMode2SN#840313003PLU15-160006PULSELIPO16000mAh6S1P22.2V15CInvoice-rHeliDirect730EasternAve.,Umt096EastBoston,MA02148USA877-HDX-HELI781-443-6185IDELIVERTO:IjMsPhotographyIIMelindaSogoloskiI-j33SeaAveIEjQuincy,02169I!Massachusetts,UnitedStatesI--III..DateofOrder:04/29/2014SKUQtyShip1FUTK92011PLU15-1600061Paymentmethod:CreditCardQtyPrice(EX)80$6,560.00$349.98$0.00SubTotal:ShippingCost:Total:TotalPay!flentPaid:Total Refunded:Total(Inc)$6,560.00$349.98$0.00$0.00$6,909.98$7,519.96$609.98I-t-

# FAA UAS Civil COA Request Any i nformation that is provided is bound by the Freedom of Information Act (FOIA) and may be releasable

. This requ i res compliance to FOIA and consent to the release of your informat i on . If you do not consent to the release of your i nformat ion , you must contact us for further guidance. For more information, please v i sit http://www.foia

. gov/

. 

### Date I 

# J} x. , f.£ i- lb l'l 333 Exemption # or Federa l 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 Characterist i cs Climb Rate (Feet/Minute) 

### 1350 feet per minute Descent Rate (Feet/M i nute) 

### 1250/350 per minute

### Turn Rate 

# la o 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 

## Operat i ona l Information L ocation

A l t i tude Description of Operation Bridgewater State University ( 131 Summer Street, Bridgewater, MA 02324) Possib ly 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 wi ll be a few days of filming

. Projected filming for other companies would take p l ace in similar conditions , meaning saftey and education wou ld be on the forefront. This includes knowijng regu lations 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



## Proc edure s Transmitter @ Yes 

# 0 No

Lost Link Procedures 1. How long to activate LL proce dure 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 o r the signal is dropped it will fly back to where it is told

. I preprogram the altitude it i i: 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. L L A l titude 

# 1450 f eet

4. Lost Link Point Beyond line of sight. We do not fly beyond l i ne 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 s peaking d ist ance . 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 w i th i n speak i ng distance

. lij @ Day @ Yes 

# 0 No 

# 0 N/A 

# 0 Night 

# 0 Both Mode C 

# D

P l ease return completed form to 9-AJV-115-UASOrganization@faa.gov.