Mid Michigan Cam Fighters Ben Fowler 4245 Lyle Rd Coleman, Michigan 48618 skysthelimitpictures@gmail.com
March 7, 2016
U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part21 ;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2) ;91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1) ; 91.409 (a) (2);91.417 (a) & (b).
Dear Sir or Madam:
Pursuantto Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11 , Mid Michigan Cam Fighters, developer and operator of Small Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial electronic data collection c and aerial photography for the commercial video industry, herebyapplies 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 FAA as required by Section 333.
As described more fully below, the requested exemption would permitthe operation of small, unmanned and relatively inexpensive sUAS undercontrolled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the aerial filming and monitoring industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "

...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) of the Reform Act.

c Aerial Data Collection" which includes any remote sensing and measuring by an instrument(s) aboard the UA

. Examples include imagery (photography, video, infrared, etc.) , electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), orany other gathering ofdata by instruments aboard the UA

1The name and address of the applicant is: Mid Michigan Cam Fighters Ben Fowler Ph: 989-701-6287 Email: skysthelimitpictures@gmaiLcom Address: 4245 Lyle Rd, Coleman, Michigan, 48618 Regulations from which the exemption is requested:
14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14C.F.R. 91.103 14C.F.R. 91.109 14C.F. R. 91.119 14C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)
This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS orthe public or pose a threat to national security in light ofthefollowing:

• The sUAS's size, weight, speed, and operational capability; • Operation ofthe sUAS in close proximityto airports and populated areas • Operation ofthe sUAS within visual line of sight of the operator. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "mayoperate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." ld. §333(c) (emphasis added) A

A Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation ofthe sUAS, if it should be determined that the conditions set forth herein do notfulfill the statutory requirements for approval. 

### 2The Federal Aviation Act expressly grantsthe FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as theterm is defined under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.
The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section oranysections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S

.C. §44701 (f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Mid Michigan Cam Fighters's sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously

. Theywill operate only in line of sight and will operate only within the sterile area described in the Flight Safety Manual, attached as Exhibit B (hereinafter "the Manual"). Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." 8

Given the small size of the sUASs involved and the restricted sterile environment within which theywill operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned thatthe FAA must, by exemption, allowcommercial operations of UASs to commence immediately

. Also due tothe size of the sUASs and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing sUASs for commercial video operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent oreven higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe commercial video filming operations conducted with conventional aircraft.

8 Reform Act Section 333 (b).



### 3These limitations and conditions to which Mid Michigan Cam Fighters agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1 . The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 20 minutes

. Flights will be terminated at 25% battery power reserve should that occur priortothe 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist ofthe sUAS Pilot and the Visual Observer. 6. sUAS pilot will be an FAA licensed airman with at least a sport or recreational certificate (or the minimum required certification at the time of the flight) and a valid driver's license. The observer will also hold a valid driver 's license. 7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC.

8. The sUAS will only operate within a confined "Sterile Area" as defined in the Manual. Section C ofthe Manual requires the establishment ofa "Safety Perimeter" fortheflight operations area.

9. A briefing will be conducted in regard tothe planned sUAS operations priorto each day's production activities. Itwill be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeter be present forthis briefing.

10. 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.

11. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100feet ofthe flight operation, and this radius may be reduced to 30feet based upon an equivalent level of safety determination, as required by Section F of the Manual. With the advanced permission of the relevant FSDO, operations at closer range can be approved. (See Section B in the Manual Appendix B)

12. The operator will submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The three-day notification may be waived with the concurrence of the FSDO.

13. Pilot and observer will have been trained in operation of sUAS generally and received upto-date information on the particular sUASto be operated as required.

14. Observer and pilot will at all times be able to communicate by voice. 15. Written and/or oral permission from the relevant property holders will be obtained. 16

. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, orother appropriate governmental agencies.

17

. Ifthe sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a pre-determined location within the Security Perimeter and land.

18

. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.



### 414 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C
.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of air worthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meetsthe requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular sUAS

. In all cases, an analysis of these criteria demonstrates thatthe sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.
The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations underthis exemption will betightly controlled and monitored by both the operator, pursuant to the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already applyto civil aircraft operated in connection with motion picture and television production, provide a greater degree of safety to the public and property ownersthan conventional operations conducted with airworthiness certificates issued under 14C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates thatthere is no credible threat to national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive materials orflammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking ofthe Aircraft
The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entranceto the cabin , cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light-sport," "experimental," or "provisional," as applicable.
Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin , cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAV, two-inch lettering will be
5impossible. The word "Experimental" will be placed on the fuselage in compliance with §45

.29 (f). The equivalent level of safetywill be provided by having the sUAV marked on its fuselage as required by§45.29 (f) where the pilot, observer and others working with the sUAV will seethe identification of the sUAS as " Experimental. " The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167and 10167 A.
14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.
Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operatethis small sUAS. Unlikea conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as setforth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Asthere 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, as set forth in Sections C & D, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.
Section 91

.9 (b) (2) provides: No person may operate a U

.S.-registered civil aircraft

... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.



### 6The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.
The equivalent level of safety will be maintained by keeping theflight 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 tothis regulation : Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R
. § 91.103(b): Preflight action
This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as setforth in the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:
Section 91.103 provides that no person mayoperate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft 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 bythe size and speed of the aircraft

. Safe simulation and practice flight will be carried out in controlled environments. All simulations will be carried out on a computer using the drone controls. Any practice flying will take place in a safe environment, with no risk to human life below.

14 C.F.R. §91.119: Minimum safealtitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption isfor a sUAS that is a helicopter and the exemption requests authority to operate at altitudes upto 400 AGL, or not morethan 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations

. As set forth herein the sUAS will never operate at higherthan 400 AGL. It will however be operated in a


### 7restricted area with safety perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.
The equivalent level of safety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials

. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 551bs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the lowaltitude operations ofthe sUAS will ensure separation between these smaii-UAS operations and the operations of conventional aircraftthat must comply with Section 91.119

.

14 C.F.R. §91.121 Altimeter Settings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...tothe elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safetywill be achieved by the operator, pursuant tothe Manual and Safety Checklist, 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 underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, tofly afterthat for at least 45 minutes."

The battery powering the sUAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91

.151 , sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91

.151 (a)). Operating the small sUAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel , does not engenderthe type of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small sUAS. Additionally, limiting sUAS flights to 20 minuteswould greatly reduce the utility for which the exemption will be granted.


### 8Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

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

14 C.F.R
. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration
The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unlessthe 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 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the sUAS.
An equivalent level of safety will be achieved by keeping these documents atthe ground control point where the pilot flying the sUAS will have immediate accessto them , tothe 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, and10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### &(b): Maintenance Inspections
These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.

..," and others shall inspect or maintain the aircraft in compliance with Part43.

Given that these section and Part 43 apply onlyto 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 and operating handbook as referenced in the Manuai.(See Sections B, D and G) An equivalent level of safetywill be achieved because these small sUASs are very limited in size and will carry a small payload and operate only in restricted areasfor limited periods oftime. If mechanical issues arise the sUAS can land


### 9immediately and will be operating from no higherthan 400 feet AGL. As provided in the Manual , the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuantto 14 C.F. R

. Part 11 , the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from thefollowing rules: 14 C.F.R. §21 , subpart H; 14C.F.R 45.23(b) ;14 C.F.R

. §§ 61.113( a) & (b);91.7 (a); 91

.9 (b) (2);91.103(b) ;91.109; 91.119; 91.121; 91.151 (a) ;91.203(a) and (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) (2) ; 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (551bs or less) in motion picture and television operations. Approval of exemptions allowing commercial operations of sUASs in the film industry will enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, operate at extremely low altitudesjust feet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,0001bs. , carrying large amounts ofjet A or other fuel. Such aircraft mustfly to and from the film location

. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the film set and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small sUASs, weighting less than 55 lbs. , conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations

. These lightweight aircraft operate at slow speeds, close to the ground, and in 

### a sterile environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

sUASs Details: See Appendix C
Safety Features: • Voltage Alarm This sUAS is equipped with a lowvoltage alarm to give the PIC sufficient time to return to the either the take-off location ora safe landing area when the craft experiences voltage drop or low battery.
10Privacy
All flights will occur over private or controlled access property with the property owner's prior consent and knowledge

. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place.

Satisfaction ofthe 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
- provides more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofapplicant's sUAS in the commercial video production industry pursuant to the Manual appended hereto.

Mid Michigan Cam Fighters Ben Fowler

11

# Appendix A: No-Fly Zones

Mid Michigan Cam Fighters's Pilots will not be operating within 5 nautical miles of any airport.
As a safety precaution, Mid Michigan Cam Fighters's pilots will not be operating within 5 nautical miles of any airport similartothe permission granted in Exemption No. 11153
- Regulatory Docket No

. FAA20140519, page 25, "20. The UA maynotoperate within 5 nautical miles ofan airportreference pointas denotedon 

### a current FAA-publishedaeronauticalchart unless 

### a letterofagreement with thatairports managementis obtained , and the operation is conductedin accordance with 

### a NOTAMas requiredbythe operators GOA. The letterof agreement with the airportmanagementmustbe made available to the Administratorupon request."
As well as in Exemption No. 11195- Regulatory Docket No

. FAA20140884, page 12, "19. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airports management is obtained, andthe operation is conducted in accordance with a Notice to Airmen (NOT AM), as required by the operators Certificate ofWaiver or Authorization (COA). The letter of agreement with the airport management must be made available tothe Administrator upon request."

Mid Michigan Cam Fighters requests the same flexibility as exemptions 11153 and 11195for acquiring agreement with the airports' management should operations fall within 5 nautical miles of an airport.

Appendix B: Safety Manual
12

### A. Maintenance a. The sUAS must be inspected by a trained technician every 10flight hours. All maintenance records will be maintained for inspection as setforth in Section B. b. If any maintenance is undergone,the sUAS must pass a flight test with both a pilot and a manufacturertrained technician before flight. 

### B. Record Keeping a. A digital record will be kept for all flights,flight times, and maintenance records. 

### C. Securing Flight Site a. FSDO Submissions i. The sUAS operator will file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office. 

### b
. Safety Parameter i. Before filming occurs, a 100yard perimeter from the planned flight path will be identified in orderto set a "sterile" environment forthe operation

. 1

. Mid Michigan Cam Fighters must obtain written or oral permission from all landowners in sterile environment. 2

. 48 hours before filming, all residents or businesses within 100 yards of the filming will be notified with printed flyers. a
. Flyers will contain date of flight, time of flight, and contact information. 3

. Streets and sidewalks that cross into the sterile environment will be marked with "Warning Low flying Aircraft
- Stay Back 150ft" signs to warn the public. 4

. At all times Mid Michigan Cam Fighters will carry $1 mm in general liability insurance in case of any damage to property or persons within the safety parameter 

### c. Identify potential obstacles i. Before each flight, an inventory will be taken for all potential obstacles that must be avoided while in flight. Including: 1

. Powerlines 2. Cell Phone Towers 3

. Trees 4

. Flocks of birds that may take flight 5

. Heavily traveled roadways 6

. Utility wires 7. Elevated structures 8

. At least 5 nautical miles from the nearest airport or helipad

. 

### D. Pre-Flight Checklist a. Take Off Location/ "Home" i. The PIC will mark its take off location as a safe area to return to should the conditions change or the PIC decides to terminate flight.

13

### 1

. Take off location will be in an area with a 25ft radius with no obstructions, maintaining said radius vertically 200ft. 2. The sUAS will take off and land in the same location. 3. GPS Altimeter will be marked as 0' elevation 

### b. Flight Canceling Events L 

### All flights will be cancelled for a minimum of 2 hours if any of the below occur: 1

. Police activity in the area 2

. Low flying aircraft in the area 3

. Medical /News Helicopters active in the area 4

. Wind exceeding 10 mph 5

. Any emergency requiring emergency services occurs within the sterile environment 6. PIC is unableto complete flight without losing visual of the sUAS 7

. Any precipitation 8

. Heavy bird presence in the area that could cause a mid-air collision. 9

. Any defects ordamage found during preflight exam c. Physical Inspection i. Before each flight the sUAS will be checked to ensure that it is safe for flight. 1

. Batteryvoltage will be checked to ensure it is >

### 75% 2

. Blades will be inspected to ensure they aretightened and free of damage 3

. Camera mount and gimbal will be inspected to ensure it is fully attached and operating. 4

. sUAS will be checked for any damagethat may have taken place in transit. 5. The sUAS will be tested at a low altitude to ensure all controls are responding correctly. 6. Battery checked for damage that could affect its charge ii. If any party ofthe inspecting shows a damaged part or parts,the sUAS is deemed non-usable and must be inspected by a trained technician. 

### d. Post Flight Inspections/Checklist i. After each flight,the the sUAS will be thoroughly inspected for any damage that occurred in flight. 1

. Body inspected for any damage 2. Blades visually checked for any damage at all 3

. Battery checked for damage E. Mid-Air Safety Protocol a. Max Speed i. Ascent 1. 25m/s ii. Descent

141

. 30m/s iii. Flight Speed 1 . The sUAS is neverto exceed 50m/s 

### b
. Altitude i. The sUAS is neverto exceed 400ft 

### c. Emergency i. If it appears that the sUAS, any property or humans are at risk, the sUAS will be grounded immediately to a safe location. 

### d. Sight i. The pilot must keep the sUAS within eyesight at all times unassisted by anytechnology. 

### F. Participation by non-pilot staff a. All staff involved in the production orfilming using the sUAS will consent to maintain a safe distance of at least 30ft during the filming. 

### G. Pilot/SpotterTraining a. Before flying, both the Pilot and spotter will receive updated information on the sUAS and its firmware. i. The controller allows for a simulator training, both the pilot and spotter are allowed to run through the simulator training



### Appendix C

15

### UAS: Custom Fixed Wing

*This custom sUAS complies with all restrictions setforth inthis petition.This craft's maximum weight (fully equipped)will neverexceed Sibs.* Top Speed: 54.5 mph Weight: 1.43 lbs Weight (with camera): 1.60 lbs Length:44.0inches
Width: 25.0 inches
Thrust: 2.9 lbs Thrust to Weight Ratio: 1.9



### 16Receiver Range: 1.6 miles
Fuel Range: 4-7 miles Payload Capacity: 1.0 lbs



### 17