April 8, 2015

 Exemption No. 11308

 Regulatory Docket No. FAA–2014–0989

Mr. Dennis J. Seabright

Owner

Sky Shots Aerial Imaging Services

414 Devland Drive

Winchester, VA 22603

Dear Mr. Seabright:

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 posted to the public docket on November 25, 2014, you petitioned the Federal 

Aviation Administration (FAA) on behalf of Sky Shots Aerial Imaging Services (hereinafter 

petitioner or operator) for an exemption. The exemption would allow the petitioner to operate 

an unmanned aircraft system (UAS) in motion picture and television operations.

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 are the DJI Model P330z and DJI Model S1000+.
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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 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 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 and closed set motion picture and 

filming. 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—

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

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

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

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Sky Shots Aerial Imaging Services is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection and closed set motion picture and filming. This exemption is subject to 

the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Sky Shots Aerial Imaging Services is hereafter referred to as 

the operator.
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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 Model P330z

and DJI Model 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 

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 
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documents to the Administrator or any law enforcement official upon request. The 

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 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(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 FAApublished 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 predetermined 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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.
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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.
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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 Barbagallo

Acting Deputy Director, Flight Standards Service
 Sky Shots Aerial

414 Devland Dr

Winchester, Va 22603

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from: 14 CFR 61.113 (a) and (b); 91.103; 91.119 (c); 91.121;

91.151 (a); 91.405 (a); 91.407 (a)(1); 91.409 (a)(1); and 91.417 (a) and (b); 91.203 (a) and (b);

91.715.

 Dear Sir or Madam:

 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”)

And 14 C.F.R. Part 11, Sky Shots Aerial Imaging Service an operator of Unmanned Aircraft

Systems (“UASs”) for aerial Photography for the Outdoor television industry, hereby applies for

an exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of

its UAS platforms.

 On or about Sept 25, 2014 the FAA granted exemptions to six UAS operators, including

Astraeus Aerial. As set forth in Top Shot’s Flight Operations and Procedures Manual (the

“FOMP”) and Motion Picture Television Operations Manual (both submitted separately under

14 CFR 11. 35 (b), Sky Shots will Adhere to the terms of the Astraeus Exemption.

 Sky Shot’s requested exemption would permit the operation of small, unmanned UAS under

controlled

And “sterile” conditions in the “outdoor television filming” airspace that is: (1) limited, (2)

predetermined, (3) subject to controlled access, and (4) provide greater safety in connection

with aircraft operations in the Outdoor film and television industry. As established by the

exemptions already granted by the FAA, approval of Sky shot’s exemption would enhance

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to

establish requirements for the safe operation of such aircraft systems in the national airspace

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system. Section 333 © of the Reform act.

Below is an example how leading film organizations feel about using UAS’s by aerial production

companies; — The following is a statement from Neil Fried, Senior Vice President, Government and

Regulatory Affairs for the Motion Picture Association of America, Inc.,

 “Unmanned aerial systems (UAS) offer the motion picture and television industry an innovative and

safer option for filming. This new tool for storytellers will allow for creative and exciting aerial shots,

and is the latest in a myriad of new technologies being used by our industry to further enhance the

viewer experience. We welcome the FAA’s leadership and support their guidance to safely authorize

the use of UASs for the motion picture and television industry.”

This application is submitted by:

Sky Shots Aerial Imaging Services

Owner: Dennis Seabright. Ph 540-877-1679

Email contact: Dennyseabright@comcast.net

Address: 414 Devland Dr, Winchester, Va 22603

Regulations from which the exemption is requested :

14 CFR 61.113 (a) and (b)

14 C.F.R 91.103

14 C.F.R. 91.119

14 C.F.R. 91.121

14 CFR. 91.151 (a)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) and (b)

14 CFR 91.203 (a) and (b)

14 CFR 91.715

 UASs operated by Sky Shots weigh less than 55 pounds, including all payload. The operate at

speeds of less than 50 knots, can hover, and can simultaneously move in multiple directions.

Shy Shots will only operate its UASs in line of sight and will operate only within the sterile

environment described in the FOPM. Such operations will insure that the UAS will not create a

hazard to users of the NAS or public.

 Given the small size of our UASs and the restricted area that they will be operated, Sky shot’s

UAS operations adhere to the Reform Act’s safety requirements.

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Additionally, due to the size of the UASs and the limited area in which they will operate,

approval of this application presents no national safety concerns. Based on the substantial level

of safety surrounding the proposed operations, and the significant public benefit (enhanced

safety). Reduction in environmental impacts in the outdoor setting these UASs will operate

leaving no trace of activity behind, the grant of the requested exemption is in the public

interest. Accordingly, Sky Shots respectfully requests that the FAA grant the requested

exemption.

Aircraft And Equivalent Level Of Safety

 The operating limitations proposed by Sky Shots provide for a higher level of safety because

operations further enhance safety of movie and television filming operations using conventional

aircraft.

 As set forth in the FOPM, the limitations and conditions include:

 The UASs will weigh less than 55 pounds

 Flights will be operated within line of sight of a pilot and observer

 Maximum flight time for each flight will be 30 minutes or at 25% of battery power

reserve

 whichever comes first.

 Flights will be operated at an altitude of no more than 400 feet AGL as indicated

by onboard

 GPS system.

 Minimum crew for each operation will consist of the UAS pilot, the observer and

 a camera operator.

 A UAS pilot will be Pilot in Command (PIC).

 A UAS pilot will be an FAA licensed airman with at least a private pilot’s certificate

and third class Medical

 The UAS will only operate within a confined “sterile area” as defined in the FOPM.

 The FOPM requires the establishment of a “Security Perimeter” for the flight

operations area.

 A briefing will be conducted for Planned UAS operations prior to each day’s flight.

All personnel

 Performing duties within the boundaries of the safety perimeter are required to

attend.

 The operator will file a FAA Form 7711-1 or its equivalent, as modified in light of

the requested exemption, with the appropriate Flight Standards District Office.

 The operator will obtain consent of all persons involved in the filming and ensure

that only

 Consenting persons will be allowed within 100 feet of the flight operation.

 The operator will submit a written Plan of Activities to the FSDO three

days before the proposed shoot as required in the FOPM.

 The Pilot and observer must be trained in UAS operations and received

current information on the particular UAS to be operated as required by

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the FOPM.

 The Observer and Pilot will at all times be able to communicate by voice.

 Written and/or oral permission from the relevant property holders will

be obtained.

 All required permissions and permits will be obtained from territorial,

state, county, or city Jurisdictions, including local law enforcement, fire or

other managing governmental agencies.

 If the UAS loses communications or loses its GPS signal, the UAS will and

does have the capability to return to a pre-determined location within

the Security Perimeter and land safely.

 The UAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies.

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

 Sections 61. 113 (a) and (b) limit private pilots to non-commercial operations. Because the

UAS

Will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of

Safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s

license

Rather than a commercial pilot’s license to operate a small UAS. Unlike a conventional manned

aircraft,

A UAS is remotely controlled by a ground-based operator. The operational area is controlled

and restricted, and all flights are planned and coordinated in advance. The level of safety

exceeds that provided by a single individual holding a commercial pilot’s certificate operating a

conventional aircraft for hire. The risks associated with the use of a UAS are so diminished from

the level of risk associated with commercial operations contemplated by part 61 allowing UAS

use by a private pilot as PIC exceeds the present level of safety sought by 14 C.F.R. 61.113 (a) ab

(b).

14 C.F.R. 91.103: Prefight Action

 Section 91.103 requires each Pilot to preflight an aircraft before flight to insure the safety

of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is

requested. However, an equivalent level of safety will be provided. The PIC will take actions,

including reviewing weather, flight battery requirements, landing and takeoff distances, and

aircraft performance data before each flight.

14 C.F.R. 91.119 (c) : Minimum Safe Altitudes

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 Section 91. 119 establishes safe altitudes for operation of civil aircraft. Section 91.119

provides, in

Pertinent part, that:

 “Except when necessary for takeoff or landing, no person may operate an aircraft below the

following altitudes: .......

 ( c ) Over other than congested areas. An altitude of 500 feet above the surface, except over

open water or sparsely populated areas. In those cases, the aircraft may not be operated closer

than 500 feet to any person, vessel, or structure. “

 Because Sky Shots requests authority to operate at altitudes only up to 400 feet AGL, an

exemption is needed to allow such operations. Except for the limited conditions stated in the

FOPM, the UAS will never operate higher than 400 feet AGL. It will, however, be operated in a

restricted area within a security perimeter, where buildings and people will not be exposed to

operations without their pre-obtained consent.

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

well

as the location where it is operated. No flight will be taken without the permission of property

owners

or local officials. Because of the advance notice to the property owners and participants in the

filming activity, all affected individuals will be informed of the planned flight operations.

Compared to the flight operations for manned aircraft and the lack of flammable fuel, any risk

associated with the proposed UAS operations is far less than conventional aircraft operating at

or below 500 feet AGL.

 In addition, the low-altitude operations of the UAS will ensure separation between a UAS and

conventional aircraft.

14 C.F.R 91.121 Altimeter Settings

 Section 91.121 requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “... to an elevation of the departure airport or an

appropriate altimeter setting available before departure.” As a UAS may not have a barometric

altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety

will be achieved by the operator, pursuant to the FOPM and Safety Check list, confirming the

altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. 91.151 (a): Fuel Requirements for Flight in VFR Conditions

 Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing, and, assuming normal cruising speed- (1) During the day,

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to fly after that for at least 30 minutes ......”

 The battery powering the Sky Shots UASs provides approximately 20 minutes of powered

flight. To meet the 30 minute reserve requirement in 14 CFR 91.151, UAS flights will be limited

to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area

and its proposed flight area

and proposed operations within a predetermined location, a longer time frame for flight in

daylight VFR conditions is reasonable. Furthermore, operating the UASs in a tightly controlled

area where only people, property owners, or official representatives who have signed waivers

will be allowed, less than 30 minutes of reserve fuel does not engender the type of risk that

91.151 was intended to address.

 The owner/operator of Sky Shots believes that safety can be achieved by limiting flights to

end with a 25% battery reserve as indicated on the PIC’s controller mounted monitor. This

restriction would be more than adequate to return the UAS to its predetermined landing area.

14 C.F.R. 91.405 (a) (1); 407 (a) (1); 409 (a) (2); 417 (a) and (b): Maintenance Inspections

 These regulations require that an aircraft operator or owner shall “have that aircraft

inspected as prescribed in subpart E of this part and shall between required inspections, except

as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43

of this chapter.....,”

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

 Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to Sky shots operations. Maintenance will be accomplished by the

operator. An equivalent level of safety will be achieved because the UASs are limited in size,

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.

 As provided in the FOPM, the operator will ensure that the UAS is in working order prior to

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

Moreover, the operator is the person most familiar with the UAS and best suited to maintain it

in an airworthy condition.

14 C.F.R. 91.203 (A) and (B); 91.715 Airworthiness certificates

 Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft

unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an

effective U.S. registration certificate issued to its owner or, for operation within the United

States, the second copy of the Aircraft Registration Application as provided for in § 47.31(c).

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft

unless the airworthiness certificate 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.

 A UAS has no certificate nor does it have a cockpit door, Sky shots is requesting an

exemption from 91.203 (a) and (b) also 91.715

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Summary for Publication

 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:

Sky Shots seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b); 91.203 (a) and (b); 91.715 to operate

commercially a small unmanned vehicle (55 pounds or less) in motion picture and television

operations.

 As established by the UAS exemptions already granted by the FAA, allowing commercial

operations of UASs in the film industry will enhance safety by reducing risk. Conventional film

operations, using turbine aircraft, operate at low altitudes and present the risks associated with

aircraft that weigh around 4,000 pounds, and which carry large amounts of Jet A fuel. Such

aircraft

must also fly to and from the film location. In contrast, a UAS weighing fewer than 55 pounds

and

powered by batteries eliminates virtually all of that risk given the small size and lack of

combustible

fuel. The UAS is carried, and not flown, to a film set. In this regard, the UAS carries no

passengers

or crew and, therefore, will not expose them to the risks associated with manned flights.

 The operation of UASs conducted in the strict conditions outlined in the FOPM will provide

an equivalent level of safety supporting the grant of the exemption requested herein. The UASs

operate at slow speeds, close to the ground, and in a sterile environment. UAS’s also have far

less impact on the environment compared to normal filming practices it replaces. As a result,

they are far safer than

conventional operations conducted with turbine helicopters flying near the ground and people.

Privacy

 All flights will occur over private or controlled access areas with the property owner’s prior

consent and knowledge. Filming will be only of people who have given their consent or

otherwise have agreed to be in the area where filming will take place.

 Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight,

speed, operating capabilities, proximity to airports and populated areas and operation within

visual line of sight and national security) provide more than adequate justification to grant

Sky Shots requested exemption, allowing for Sky Shot’s UAS commercial operations for the

Outdoor television industry pursuant to the FOPM included herewith.

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If you have any questions or need any additional information, please contact the undersigned at

540-877-1679 or at Dennyseabright@comcast.net.

Sincerely yours,

Dennis J. Seabright

Owner

Sky Shots Aerial Imaging Services

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Dennis J Seabright