### August 18, 2015

Exemption No. 12497 Regulatory Docket No. FAA

− 20 15

− 0917

Mr. Kirk Mays Owner KM Video Productions, LLC 1110

- A Broad Street Camden, SC 29020
Dear Mr. Mays : This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated June 8, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of KM Video Productions, LLC ( hereinafter petitioner or operator ) for an exemption

. The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial video and photography of construction sites, real estate, nonprofit and other community special events

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

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not s et 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 Phantom 2 Vision +

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited

### 2

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 , C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s
. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly 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 reque sted 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, KM Video Productions, LLC 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 petit ioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

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

### 3

Conditions and Limitations
In this grant of exemption, KM Video Productions, LLC is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.
1. Operations authorized by this grant of exemption are limited to the DJI Phanto m 2 Vision + when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.
3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
5. The UA mus t 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. driv er’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 ; e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the dura tion 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 t his exemption and the procedures outlined in the operating documents,

### 4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The 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 amendm ent to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.
8. Any UAS that has undergone maintenance or alterations that affect the UAS 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 con dition 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, it ems, 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. T he operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.
13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appr opriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, profic iency, 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 onl y be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance fro m 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 symbo l as denot ed 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 ava ilable to the Administrator or any law enforcement official upon request.
17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre
- determined location within the pr ivate or controlled

- access property.
19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
20. The PIC is prohibited from begi nning 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 manufactu rer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

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

.

### 6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.
23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear a nd 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, v ehicles, 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 protectio n. 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 t rainees or essential persons are not considered nonparticipating persons under this exemption.
27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. P ermission 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 FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

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

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used; e. Name and certificate number of UAS PICs invol ved 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 operati on.
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.

### 8

This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded. Sincerely, / s/ John S. Duncan Director, Flight Standards Service

Enclosures1 IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

# KM Video Productions, LLC

.

Docket ID : FAA

- 2015

- 0917

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 2 VISION+

UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on June 8 , 2015
KM Video Productions, LLC
Kirk Mays, Owner

1110

- A Broad Street
Camden, SC 29020
kirk@kmvideoproductions.com2

TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

................................................... .................................. 3

SUMMARY ..................................................................................................................... ..... 4

INTRODUCTION AND INTERESTS OF PETIT IONER....................................................

... 4

BACKGROUND ...................................................................................

............................... 5

BASIS FOR PETITION ..............................................

........................... .............................. 5

NAME AND ADDRESS OF PETITIONER. ...........................................................

............. 8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH KM Video Productions, LLC

SEEKS EXEMPTION

........................................................................ ................................ 8

THE EXTENT OF RELIEF KM Video Productions, LLC SEEKS AND THE REASON
KM Video Productions, LLC SEEKS THE RELIEF...............

.............................. ............ 15

THE REASONS WHY GRANTING KM VIDEO PRODUCTIONS, LLC REQUEST WOULD

BE IN THE PUBLIC INTEREST ........................................................................

............ 18

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY .........................................................................

.......... 38

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ....

............... 46

EXHIBITS.......................................................................................

............ 4 73

GLOSSARY OF ABBREVIATIONS
AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control ATO Air Traffic Organization
AV Aerial Vehicle CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration FAR Federal Aviation Regulation
GCS Ground Contro l Station GPS Global Positioning System

LOL Loss of Link NAS National Airspace System

NOTAM Notice to Airman
PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures
UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules
VLOS Visual Line of Site VMC Visual Meteorological Conditions4

VTOL Vertical Takeoff and Landing

SUMMARY
KM Video Productions, LLC seeks exemption from the requirements of 14 C.F.R § §
61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),
and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of
the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will p ermit KM Video Productions LLC to operate an Unmanned Aircraft System (UAS) for the commercial
purpose of conducting aerial video and photography of construction sites, real estate, Nonprofit
and other community special events, and the Camden, South Caroli na and the midlands of South Carolina area.

INTRODUCTION AND INTERESTS OF THE PETITIONER
KM Video Productions, LLC . provides its commercial clients with affordable highest quality digital content for use in their commercial, personal, and other photography related projects. KM Video Productions, LLC also provides the community and Non

- Profit organization our services for little or no charge as a way of giving back to the community.

The objective of KM Video Productions, LLC aerial video and photography op erations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

- Profit and Community Organizations5

Aerial photography and video to support Economic Development and Tourism

BACKGROUND
Unmanned Aircraft Systems: DJI Phantom 2 Vision UAS
KM Video Productions, LLC seeks an exemption to operate DJI systems for compensation or

hire within the NAS. The DJI Phantom 2 Vision+ is a vertical takeoff and landing
(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing
electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a maximum
gross weight of appro ximately 2 pounds 11 ounces, while having a length of 16 inches
width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots.
The DJI Phantom 2 Vision+ UA is equipped with four main rotors; driven by Lithium
Polymer battery powered electric motors.
The DJI Phantom 2 Vision+ UA that will be operated by KM Video Productions, LLC will be
registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14
C.F.R Part 47, Aircraft Registration, and marked in ac cordance with 14 C.F.R. Part 45.
Identification and Registration Marking.

BASIS FOR PETITION
Petitioner, KM Video Productions, LLC , pursuant to the provisions of the Federal Aviation
Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012
(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby6

petitions the Administrator to commercially operate the DJI Phantom 2 Vision+ UAS in
the National Airspace System (NAS), and for an exemption from the requirements of 14

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), and 91.417(a) & (b).
In consideration of the speed, weight, size, and limited operating area associated
with the unmanned aircraft and its operation, KM Video Productions, LLC operation of DJI
Phantom 2 Vision+ UAS meets the conditions of FMRA Section 333 and therefore, will
not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Accordingly, KM Video Productions, LLC requests r elief from Sections 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for
maintenance that only apply to aircraft with an airworthiness certificate.
KM Video Productions, LLC submits that the requested relief is proper since an equivalent level
of safety will always be ensured (see Exhibit D). KM Video Productions, LLC w ill use licensed
technicians or the manufacturers service centers to perform maintenance, alterations, or
preventive maintenance on the UASs using the methods, techniques, and practices
prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom
2 Vision+ Instruction Manual). Furthermore, KM Video Productions, LLC will document and maintain

all maintenance records for the DJI Phantom 2 Vision+ UAS.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot
privileges and limitations: Pilot in command, is requested by KM Video Productions, LLC to the extent7

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level
certificate, as well as an airman medical certificate, and who has demonstrated, by meeting
minimum flight

- hour and currency requirements, that the PIC is able to safely operate the

D JI Phantom 2 Vision+ UAS in a manner consistent with this exemption, including
evasive and emergency maneuvers and maintaining appropriate distances from people,
vessels, vehicles and structures.
KM Video Productions, LLC seeks relief from Section 91.7(a), entitled Civil aircraft
airworthiness, because the DJI Phantom 2 Vision+ UAS do not require an airworthiness
certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, KM Video Productions, LLC

submits that it will ensure that the DJI Phantom 2 Vision+ UAS are in an airworthy
condition, prior to every flight, by determining that the UASs are in compliance with the
operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+
Instruction Manual), and that the aircraft are in a con dition for safe flight.
KM Video Productions, LLC also seeks an exemption from the requirements of Section 91.121,
entitled Altimeter Settings, as the DJI Phantom 2 Vision+ UA will not have a typical
barometric altimeter onboard. However, altitude informat ion of the DJI Phantom 2
Vision+ UA will be provided to the PIC via Global Positioning System (GPS) equipment
and radio communications telemetry data link, which downlinks from the UA to the GCS

for active monitoring of the flight path. This altitude information, combined KM Video Productions, LLC operation of the DJI Phantom 2 Vision+ UAS within visual line of sight, at or8

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.12 1 and our
additional safety requirements as outlined in Exhibit D..
Additionally, KM Video Productions, LLC seeks an exemption from the requirements of Section
91.151(b), entitled Fuel requirements for flight in VFR conditions. K
submits that safety will n ot be affected by operation of the DJI Phantom 2 Vision+ UA
during daylight hours in visual meteorological conditions (VMC) under visual flight rules
(VFR), with enough battery power to fly for a total duration of approximately 13.5
minutes to the first po int of intended landing and, assuming normal cruising speed, to fly

after that for at least 4.5 minutes.
In accordance with 14 C.F.R. § 11.81, KM Video Productions, LLC provides the following
information in support of its petition for exemption:

A. Name an d Address of The Petitioner.
The name and address of the Petitioner and point of contact is as follows:
KM Video Productions, LLC
Kirk Mays

1110

- A Broad Street
Camden, SC 29020

803

- 713

- 7777 email: kirk@kmvid eoproductions.com9

B. The Specific Sections Of 14 C.F.R. From Which KM Video Productions, LLC

Seeks Exemption.

1. KM Video Productions, LLC Seeks Exemption From The Requirements Of Section
61.113(a) And (b).
Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,
subsections (a) and (b) prescribe the following, in relevant part:
(a) No person who holds a private pilot certificate may act as a pilot in command
(PIC) of an aircraft that is carrying passengers or property for compensation or
hire; nor may that person, for compensation or hire, act as PIC of an aircraft.
(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in
connection with any business or employment if

— (1) The flight is only incide ntal to that business or employment; and
(2) The aircraft does not carry passengers or property for compensation or hire.

2. KM Video Productions, LLC Seeks Exemption From The Requirements Of Section
91.7(a).
Section 91.7, entitled Civil aircraft airworthi ness, subsection (a), states the following:
(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. KM Video Productions, LLC Exemption From The Requirements Of Section

91.121.10

Section 91.121, entitled Altimeter settings, subse ction (a), states the following, in
part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight
level of that aircraft, as the case may be, by reference to an altimeter that is set,
when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and
within 100 nautical miles of the aircraft;
(ii) there is no station within the area prescribed in paragraph (a)(1)(i) of
this section, the current reported altimeter setting of an appropriate
available station; or
(iii) the case of an aircraft not equipped with a radio, the elevation of the
departure airport or an appropriate altimeter setting available before
departure.

4. KM Video Productions, LLC Exemption From The Requirem ents Of Section
91.151(b).
Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection
(b), states the following:
(b) No person may begin a flight in a rotorcraft under VFR conditions unless
(considering wind and forecast weather conditions) there is enough fuel to fly11

to the first point of intended landing and, assuming normal cruising speed, to
fly after that for at least 20 minutes.

5. KM Video Productions, LLC Exemption From The Requirement Of Section
91.405(a).
Section 91.405, entitled Maintenance required, subsection (a), states the following:
Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall
between required inspections, except as provided in paragr aph (c) of this
section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. KM Video Productions, LLC From The Requirements Of Section 91.407(a)(1) Section
91.407, entitled Operation after maintenance, preventive maintenance,

rebuil ding, or alteration, subsection (a)(1), states the following:
(a) No person may operate any aircraft that has undergone maintenance, preventive
maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person autho rized under §
43.7 of this chapter[.]

7. KM Video Productions, LLC Seeks Exemption From The Requirements Of Sections
91.409(a)(1) And 91.409(a)(2).
Section 91.409, entitled Inspections, subsection (a), states the following:
(a) Except as provided in paragr aph (c) of this section, no person may operate an12

aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has
been approved for return to service by a person authorized by § 43.7 of this
chapter; or
(2) An inspection for the issuance of an airworthiness certificate in accordance
with part 21 of this chapter.

8. KM Video Productions, LLC Exemption From The Requirements Of Sections
91.417(a) And 91.417(b).
Section 91.417, entitled Maintenance records, subsections (a) and (b), state the
following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each
registered owner or operator shall keep the following records for the periods
specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved
inspections, as appropriate, for each aircraft (including the airframe) and
each engin e, propeller, rotor, and appliance of an aircraft. The records must

include

-- (i) A description (or reference to data acceptable to the Administrator) of
the work performed; and13

(ii) The date of completion of the work performed; and
(iii) The signature, an d certificate number of the person approving the

aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and

each rotor.
(ii) The current status of life

- l imited parts of each airframe, engine,
propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which
are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircr aft, including the time since the
last inspection required by the inspection program under which the
aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety
directives including, for each, the method of compliance, the AD or
safety directive number and revision date. If the AD or safety directive
involves recurring action, the time and date when the next action is
required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each
major alteration to the airframe and currently installed engines, rotors,14

propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods
prescribed:
(1) The records specified in paragraph (a)(1) of this secti on shall be retained
until the work is repeated or superseded by other work or for 1 year after the
work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraf t is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.11 of
this chapter shall be retained until the defects are repaired and the aircraft is
approved for return to service.

C. The Extent Of Relief KM Video Productions, LL C Seeks And The Reason KM Video Productions, LLC Seeks The Relief.

1. Extent Of Relief KM Video Productions, LLC Seeks And The Reason KM Video Productions
Seeks Relief From Section 61.113(a) And (b).
Relief from Section 61.113(a) and (b) entitled Private pilot privileges and
limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a
private pilot or higher level certificate, as well as a current and valid airman medical
certificate, and who has met certain flight

- hour and currency requirements, to conduct the
proposed UAS flight operations for compensation or hire.15

This relief is requested since the limitations set forth in Section 61.113(a) and (b)
state that a private pilot may, for compensation or hire, act as PIC of an aircraft in
connection with any business or employment if: (1) The flight is only incidental to that
business or employment; and (2) The aircraft does not carry passengers or property for
compensation or hire.
As set forth more fully below, KM Video Productions, LLC submits that an equivalent level of
safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2
Vision+ other than the person listed as Kirk Mays , who has 2 years’
experience in RC/VAV operation. In addit ion all flights must full under the safety
guidelines of Exhibit D, which will be updated as new FAA guidelines take place.
Further, KM Video Productions, LLC submits that all flights of the DJI Phantom 2 Vision+
UAS, conducted by the PIC pursuant to the g rant of this Petition: (1) will be incidental to
KM Video Productions, LLC business; and (2) will not carry passengers, packages or property for
compensation or hire.

2. Extent Of Relief KM Video Productions, LLC Seeks And The KM Video Productions, LLC See ks Relief f rom Section 91.7(a).
Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the
extent required to allow KM Video Productions, LLC to determine that the DJI Phantom 2 Vision+ UAS
are in airworthy condition prior to ev ery flight by ensuring that the UAS is in compliance
with the operating documents (i.e., the KM Video Productions, LLC Aerial Operations Manual, Monthly16

Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual).
KM Video Productions, LLC seeks the req uested relief because the DJI Phantom 2 Vision+ UAS
do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Therefore, KM Video Productions, LLC will ensure that the DJI Phantom 2 Vision+ UAS are in
airworthy condition based upon its compliance with the operating documents (i.e.,
Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual) prior to every
flight, and further, determine that the aircraft are in condition for safe flight, as stated in the

conditio ns and limitations below.

3. Extent Of Relief KM Video Productions, LLC Seeks And The Reason KM Video Productions, LLC Seeks Relief From Section 91.121.
Relief from Section 91.121, entitled Altimeter settings, may be required to allow
flight operations of the DJI Phantom 2 Vision+ UAS, which utilize a barometric pressure
sensor, GPS equipment, and a radio communications telemetry data link to downlink
altitude information from the UA to the PIC at the ground control station (GCS). Since the
FAA requires that any altitude information concerning UAS operations be reported to air
traffic control (ATC) in feet above ground level (AGL), KM Video Productions, LLC seeks the
requested relief because the DJI Phantom 2 Vision+ UA’s altimeter may be set on the

groun d to zero feet AGL, rather than the local barometric pressure or field altitude, before
each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR
91.121 is sought to the extent necessary to comply with the applicable cond itions and17

limitations stated below. As more fully set forth herein, an equivalent level of safety will
be maintained since the DJI Phantom 2 Vision+ UAs are equipped with a barometric
pressure sensor and GPS equipment, which automatically ensures that a g round level
pressure setting will be established prior to each flight, and provides the PIC with altitude

information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief KM Video Productions, LLC Seeks And The KM Video Productions, LLC Relief From Section 91.151(b).
Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR
conditions, is requested to the extent required to allow flights of the battery powered DJI
Phantom 2 Vision+ UAs during daylight hours in visual meteorolog ical conditions (VMC),
under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of
intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes. KM Video Productions, LLC seeks the request ed relief because without an exemption from
Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 Vision+
UA will severely constrain the practicality of any aerial video or still photo flight
operations that KM Video Productions, LLC proposes to conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the DJI Phantom 2
Vision+ UAS, the DJI Phantom 2 Vision+ operating documents, and KM Video Productions, LLC
proposed operating limitation s, ensure that KM Video Productions, LLC will safely operate the battery
powered DJI Phantom 2 Vision+ UAs during daylight hours in visual meteorological18

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total durati on of 13.5 minutes to the first point of intended landing and,
assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief KM Video Productions, LLC Seeks And The Reason KM Video Productions, LLC Seeks Relief From Sectio ns 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &
(b) only apply to aircraft with an airworthiness certificate, KM Video Productions, LLC
requests relief from these Sections because the DJI Phantom 2 Vision+ UAS does not require
airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+
UAS meets the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, KM Video Productions, LLC will use trained technicians to perform
maintenance, alterations, or preventive maintenance on the UASs using the methods,
techniques, and practices prescribed in the UAS operating documents (i.e., the Aerial
Operati ons Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction
Manual). Furthermore, KM Video Productions, LLC will document and maintain all maintenance

records for the DJI Phantom 2 Vision+ UAS.
D. The Reasons Why Granting KM Video Production s, LLC Request Would Be In The
Public Interest; That Is, How It Would Benefit The Public As A Whole.
Granting the present Petition will further the public interest by allowing KM Video Productions, LLC to safely, efficiently, and economically perform aeria l video and photography

for Non

- Profit and Community Organizations, as well as, pursue revenue for a19

Small Business in the USA as we provide commercial services for Homes and Land for
sale, Places of Lodging, Golf Courses, and other commercial properties s eeking the
described services for marketing purposes over certain areas of the midlands of South Carolina
and surrounding area.
Additionally, use of the DJI Phantom 2 Vision+ UAS will decrease congestion of the NAS and reduce pollution, since past aerial p hotography required large manned ai rcraft for extended periods of time. Notably, the benefits of KM Video Productions, LLC proposed
operation of the DJI Phantom 2 Vision+ UAS will be realized without implicating any
privacy issues.

1. The Public Will Benef it From Decreased Congestion Of The NAS.
The DJI Phantom 2 Vision+ UA are battery powered and serve as a safe,
efficient, and economical alternative to the manned aircraft traditionally utilized to obtain
aerial imagery. By reducing the amount of manned ai rcraft needed to perform aerial
acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ UAS would
reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well
as increase the safety of life and property in the air and on the ground (as outlined in
Exhibit D).
Furthermore, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced.
The DJI Phantom 2 Vision+ UA do not require an airport to takeoff or land. Likewise, a
reduction of manned aircraft conducting aerial video and photography missions would20

result in fewer aircraft that must be handled by air traffic control during the ground,
takeoff, departure, arrival, and landing ph ases of flight operations.
2. The Public Will Benefit From The Safety And Efficiency Of The

DJI Phantom 2 Vision+ UAS.
Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of
manned aircraft, will greatly benefit the public by drastic ally reducing the levels of air
and noise pollution generated during traditional aerial video and still photography flight
operations. By using battery power and electric motors, the DJI Phantom 2 Vision+
UAS produce no air pollution, and is the most viabl e environmentally conscious 17
alternative to the cabin class, six cylinder internal combustion engine aircraft that are
typically utilized for aerial video and photography, while burning approximately 20

- 30
gallons per hour of leaded aviation fuel. The DJ I Phantom 2 Vision+ UA, while
reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as
the UAs are propelled by battery powered electric motors, rather than an internal
combustion engine.
By using the DJI Phantom 2 Vision+ UAS to perform aerial acquisitions, the
substantial risk to life and property in the air and on the ground, which is usually
associated with traditional manned aircraft flight operations, will be substantially
reduced or completely eliminated. Aside from t he lack of flight crew members located
onboard the aircraft, the DJI Phantom 2 Vision+ UA (weighing approximately 2 pounds21

11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with
lengths of 16 inches and 17.3 inches respectively , widths of 16 inches and 17.7 inches
respectively, and with no fuel on board), has less physical potential for collateral damage
to life and property on the ground, and in the air, compared to the manned aircraft that
typically conduct similar operations (weighing approximately 6,000 pounds with a
wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180
gallons).
3. Performing Aerial Video and Photography Operations with The DJI

Phantom 2 Vision+ UAS Will Benefit Non

- Profit and Co mmunity Organizations.
As stated earlier in this petition, KM Video Productions, LLC provides free services to NonProfit
and Community Organization that normally could not afford to have their event or
site professionally photographed. There the Camden, South Carolina and
surrounding area benefits.
4. Performing Aerial Video and Photography Operations with The
DJI Phantom 2 Vision+ UAS Will Benefit The Economy.
In addition to being safe and efficient, the DJI Phantom 2 Vision+ is also an

economical alter native to using manned aircraft to conduct similar aerial operations. As
such, operation of the DJI Phantom 2 Vision+ UAS will allow United States based
companies, like KM Video Productions, LLC , to remain competitive and contribute to growth of the U.S.

e conomy. Specifically, with the rising cost of aviation fuel and the Environmental22

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S.
owned and operated companies must adopt new and alternative technology in order to

remain competitive. Operating the battery powered DJI Phantom 2 Vision+ UAS is one
such technology that not only allows companies greater operational flexibility compared
to manned aircraft, but provides such flexibility without the high operational cost of a

tr aditional manned aircraft. By operating the DJI Phantom 2 Vision+ UAS, companies such as KM Video Productions, LLC , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately cont ribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision+ UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.
5. There Are No Privacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for
decades, KM Video Productions, LLC proposed operation of the DJI Phantom 2 Vision+ UAS will notimplicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ UAS will be operated only in compliance with operating documents (i.e., the KM Video Productions, L LC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction
Manual) which requires property owner involvement as well as local law enforcement
notification, and in accordance with the Federal Aviation Regulations, including the
minimum altitude requirements of 14 C.F.R. § 91.119.
E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,
Or How The Exemption Would Provide A Level Of Safety At Least Equal To23

That Provided By The Rule From Which KM Video Productions, LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ UA Meet The Conditions Of
The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.
In consideration of the size, weight, speed, and limited operating area associated

with t he unmanned aircraft and its operation, KM Video Productions, LLC operation of the DJI
Phantom 2 Vision+ UAS meet the conditions of FMRA Section 333, and will not
require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness
certification and sets forth requirements for considering whether a UAS will create a
hazard to users of the NAS or the public, or otherwise pose a threat to national security.
Specifically , FMRA Section 333 states the following, in part:
(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not
later than 180 days after the date of enactment of this Act, the Secretary of
Transportation shall determine if certain unman ned aircraft systems may
operate safely in the national airspace system before completion of the plan
and rulemaking required by section 332 of this Act or the guidance required
by section 334 of this Act.
(b) Assessment of Unmanned Aircraft Systems.

-- In m aking the determination
under subsection (a), the Secretary shall determine, at a minimum

--24

(1) which types of unmanned aircraft systems, if any, as a result of their
size, weight, speed, operational capability, proximity to airports and
populated areas, a nd operation within visual line of sight do not
create a hazard to users of the national airspace system or the public
or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization,

or airworthiness certificat ion under section 44704 of title 49, United
States Code, is required for the operation of unmanned aircraft
systems identified under paragraph (1).
(c) Requirements for Safe Operation.

-- If the Secretary determines under this

section that certain unmanned aircraft systems may operate safely in the
national airspace system, the Secretary shall establish requirements for the
safe operation of such aircraft systems in the national airspace system.
In seeking this exemption, KM Video Productions, LLC submits that the DJI Phantom 2
Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as
demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ UAS; (b) the pilot
certification requirement; and (c) the specific operating limitations

. a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate

Its Safe Characteristics.

The DJI Phantom 2 Vision+ UAS does not create a hazard to users of the NAS or
the public, or otherwise pose a threat to national security considering its size, w eight,25

speed, and operational capability.
i. Technical Specifications Of The DJI Phantom 2 Vision+ UAS.
The technical specifications of the DJI Phantom 2 Vision+ UAS is set forth by the
DJI Phantom 2 Vision+ Specifications and Data Sheet, attached hereto a s Exhibit A.
ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And
Navigation Modes Enable The UAS To Remain Within A
Defined Operational Area.
The DJI Phantom 2 Vision+ UAS may be operated in both manual and fully
autonomous flight modes. A complete des cription of the flight and navigational modes of
the DJI Phantom 2 Vision+ UAS is provided at pages 25

- 32 of the DJI Phantom 2 Vision+ User Manual, attached hereto as Exhibit B.
iii. The DJI Phantom 2 Vision+ UAS Are Designed For

Automatic Return To Home P oint Or Hover In The Event Of
Loss Of The Control Link Or Navigation.

When the control link is lostm the DJI Phantom 2 Vision+ UA will remain
stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2
Vision+ UA does not reacquire control link data from the GCS, the UA will assume that
the Control Link is lost and the UA will return to the home position (i.e., failsafe mode)
via GPS, and will descend to the takeoff position and shutdown.
A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+26

UAS are set forth at pages 27 through 28 of the DJI Phantom 2 Vision+ User Manual,

attached hereto as Exhibit B.
iv. The DJI Phantom 2 Vision+ GCS And Its Operation.
A complete description of the operation and specifi cations of the DJI Phantom 2
Vision+ GCS and flight control software is provided at pages 32 through 43 of the DJI

Phantom 2 Vision+ User Manual. DJI Phantom 2 Vision+ User Manual is attached hereto

as Exhibit B.
b. Flight Operations Of DJI Phantom 2 Visio n+ UAS Are Limited To
The Line Of Sight Of A Certificated Pilot in Command With A
Safety Observer. KM Video Productions, LLC will only utilize certificated pilots who have completed the required taining to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+ UAS. Additionally, a safety observer will assist all pilots during flight time. Andthe guidelines exhibited in D, will be followed at all

- times ensuring the safety of all involved.
c. Flights Of DJI Phantom 2 Vision+ UAS Will Be Conducted Pursua nt
To Specific Operating Limitations.
In seeking this exemption, proposes to commercially operate DJI Phantom 2
Vision+ UAS for the special purpose of conducting aerial video and photography over

certain areas of Camden, South Carolina and surrounding area s, pursuant to the following 22
specific operating limitations:
1. Operations authorized by this grant of exemption will be limited to the
following aircraft described in the operating documents, rotorcraft UASs27

weighing less than 55 pounds maximum gross w eight: DJI Phantom 2 Vision+
Unmanned Aircraft System. Proposed operations of any other aircraft will
require a new petition or a petition to amend this grant.
2. UAS operations under this exemption will be limited to conducting
operations for the purpose of aerial video and photography.
3. The UAs may not be flown at an indicated airspeed exceeding 25 knots.
4. The UA must be operated at an altitude of no more than 4 00 feet above ground
level (AGL), as indicated by the procedures specified in the operating
documents unless a special request is made and approved by ATC. All
altitudes reported to ATC must be in feet AGL.
5. The UAs 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

. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is
not permitted.
7. All operations must utilize a safety observer (SO). The SO may be used to
satisfy the VLOS requirement as lon g as the PIC always maintains VLOS
capability. The SO 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 her28

designation for the duration of the flight. The PIC must ensure that the SO can
perform the functions prescribed in the operating documents.
8. The SO must not perform any other duties beyond assisting the PIC with seeing
and avoiding other air tra ffic and other ground based obstacles/obstructions and
is not permitted to operate the camera or other instruments.
9. The operating documents and the grant of exemption must be accessible
during UAS operations and made available to the Administrator upon request.
If a discrepancy exists between the conditions and limitations contained in the
grant of exemption and the procedures outlined in the operating documents,
the conditions and limitations contained in the grant of exemption 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 d ocuments to the Administrator
upon request. The operator must also present updated and revised documents
if it petitions for extension or amendment to the grant of exemption. If the
operator determines that any update or revision would affect the basis upo n 23
which the FAA granted the exemption, then the operator must petition for
amendment to its grant of exemption. The FAA’s UAS Integration Office
(AFS

- 80) may be contacted if questions arise regarding updates or revisions to29

the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a
condition for safe flight. If the inspection reveals a condition that affects the
safe operation of the UAS, the aircraft is prohibited from operating until the
necessary maintenan ce has been performed and the UAS is found to be in a
condition for safe flight. The Ground Control Station must be included in the
preflight inspection. All maintenance and alterations must be properly documented

in the aircraft records.
11. 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. The PIC who conducts
the functional test flight must make an entry in the aircraft records.
12. The pre

- flight inspection must account for all potential discrepancies,
e.g. inoperable components, items, or equipment, not already covered in
the relevant sections of the operating documents.
13. The operator must follow the UAS manufacturer’s aircraft/component,
maintenance, overhaul, replacement, inspection, and life limit
requirements.
14. The operator must carry out its maintenance, inspections, and record keeping
requirements, in accordance with the operating documents. Main tenance,30

inspection, alterations, and status of replacement/overhaul component parts
must be noted in the aircraft records, including total time in service,
description of work accomplished, and the signature of the authorized person
returning the UAS to s ervice.
15. Each UASs operated under this exemption must comply with all
manufacturer Safety Bulletins.
16. The authorized person must make an entry in the aircraft record of the
corrective action taken against discrepancies discovered between
inspections.
17. The PIC must possess at least a private pilot certificate and at least a

current third

- class medical certificate.
18. The operator may not permit any PIC to operate unless the PIC meets the
operator’s qualification criteria and demonstrates the abili ty to safely operate
the UAS in a manner consistent with how the UAS will be operated under the
exemption, including evasive and emergency maneuvers and maintaining
appropriate distances from persons, vessels, vehicles and structures. PIC
qualification fli ght hours must be logged in a manner consistent with 14

C.F.R.
§ 61.51(b). Flights for the purposes of training the operator’s PICs are
permitted under the terms of the exemption. However, training operations may31

only be conducted during dedicated trainin g 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 C.F.R. §

91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §
19.1. All operations must be conducted under visual meteorological
conditions (VMC). If flight at night is required, a special request will be made

at the FAA office closest to proposed area of operations. Flights under special visual
flight rules (SVFR) are not authorized.
20. The UA may not operate within 5 nautical miles of an airport reference point

as denoted on a current FAA

- published aeronautical chart un less a letter of
agreement with that airport’s management is obtained, and the operation is
conducted in accordance with a NOTAM as required by the operator’s COA.
The letter of agreement with the airport management must be made available

to the Administra tor upon request.
21. 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.
22. If the UA loses communications or loses its GPS signal, it must return to a pre

-32

determined location within the planned operating area and land or be recovered
in accordance with the operating documents.
23. The PIC must abort the flight in the event of unpredicted obstacles
or emergencies in accordance with the operat ing documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and
forecast weather conditions) there is enough power to fly at normal cruising
speed to the intended landing point and land the UA with 25% battery
power remaining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate
of Waiver or Authorization (COA) prior to conducting any operations under
the grant of exemption. This COA will also require the operator to request a
Notice to Airman (NOTA M) not more than 72 hours in advance, but not less
than 48 hours prior to the operation. All operations shall be conducted in
accordance with airspace requirements in the ATO issued COA including class
of airspace, altitude level and potential transponder requirements.
26. All aircraft operated in accordance with the exemption must be identified
by serial number, registered in accordance with 14 C.F.R. part 47, and have
identification (N

- Number) markings in accordance with 14 C.F.R. part 45,
Subpart C. Mar kings must be as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for33

operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency req uirements.
28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be
available to the PIC at the Ground Control Station of the UAS any time
the UAS is operating. These documents must be made available to the
dministrator or any law enforcemen t official upon request.

29. KM Video Productions, LLC abides and enforces the safety checklist to as exhibited in
section D to ensure that we provide safety for everyone in and near to the

site..
30. The UA must remain clear and yield the right of way to all manned
aviation operations and activities at all times.
31. The UAS may not be operated by the PIC from any moving device or

vehicle.
32. Flight operations must be conducted at least 400 feet from all
nonparticipating persons (persons other than the PI C, SO, operator trainees
or essential 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 ensu re that nonparticipating persons
remain under such protection. If a situation arises where34

nonparticipating persons leave such protection and are within 500 feet
of the UA, flight operations must cease immediately and/or;
b. The aircraft is operated near v essels, vehicles or structures where the
owner/controller of such vessels, vehicles or structures has granted
permission 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 un due hazard, and;
c. Operations nearer to the PIC, SO, operator trainees or essential
persons do not present an undue hazard to those persons per §
91.119(a).
33. All operations shall be conducted over private or controlled

- access property with permission f rom the land owner/controller or authorized
representative. Permission from land owner/controller or authorized
representative will be obtained for each flight to be conducted.
34. Any incident, accident, or flight operation that transgresses the lateral o r 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
2. Reasons Why An Exemption From The Requirements Of Section35

61.113(a) And (b) Would Not Adversely Affect Safety.
KM Video Productions, LLC submits that the equivalent level of safety established by Section
61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI
Phantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum flight hour
and currency requirements, that the PIC is able to s afely operate the DJI Phantom 2
Vision+ UAS in a manner consistent with the exemption, including evasive and
emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.
Considering KM Video Productions, LLC prop osed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge
requirements to those of commercial pilot requirements (See Exemption No. 11062); and
the airmanship skills necessary to saf ely operate the DJI Phantom 2 Vision+ UAS, KM Video Productions submits that the additional manned airmanship experience of a commercially

Certificated pilot would not correlate to the airmanship skills necessary for KM Video Productions specific proposed flight operations.
The FAA has previously granted relief from Section 61.113(a) and (b) specific to
UAS, in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 111 09, 11110,
11112,
11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
KM Video Productions, LLC will not allow any PIC to operate the DJI Phantom 2 Vision+36

UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements

or the DJI Phantom 2 Vision+ UAS training and currency requirements, that the PIC is
able to safely operate the DJI Phantom 2 Vision+ UAS in a manner consistent with this 27
exemption, including evasive and emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent
with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the same make and model

of UAS to be used for operations under the exemption). In addition to the hour
requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days
(for currency purposes).
As in Exemption No s. 11062, 11138, and 11153, prior documented flight
experience that was obtained in compliance with applicable regulations will ensure an
equivalent level of safety during KM Video Productions, LLC proposed operations. The
Administrator has held that prior documented flight experience that was obtained in
compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062, the FAA required that prior to conducting operations
for the purpose of motion picture filmin g (or similar operations), the PIC must
have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25
hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as37

a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No.
11062, the PIC must also have accumulated and logged a minimum of 5 hours as
a UAS pilot operating the same make and model of UAS to be used for
operations under the exemption. For clarification, the FAA considers these

minimum hour re quirements to be inclusive rather than additive; i.e. 5 hours
make and model time may be included in the 10 hours of multi

- rotor time and the
10 hours may be included in the total 25 hours of UAS rotorcraft time. In
addition to the hour requirements, the P IC must accomplish 3 takeoffs and
landings in the preceding 90 days (for currency purposes). The FAA finds that at
a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate
to practice and build proficiency in the skills necessary to s afely conduct the
petitioner’s proposed operations. The FAA also finds that prior documented
flight experience that was obtained in compliance with applicable regulations
would satisfy this requirement. Training, proficiency, and experience

- building
flights can also be conducted under the grant of exemption to accomplish the
required flight time. During training, proficiency, and
experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91 .119.
Exemption No. 11138 at page 15.
Accordingly, KM Video Productions, LLC will ensure safe operations by not allowing any PIC38

to operate the DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated, by
meeting minimum flight

- hour and currency requirem ents, that the PIC is able to safely
operate the DJI Phantom 2 Vision+ UAS in a manner consistent with the exemption,
including evasive and emergency maneuvers and maintaining appropriate distances from
people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section
91.7(a) Would Not Adversely Affect Safety.
KM Video Productions, LLC requires a tight set of rules that follow best practices and FAA
requirements and guidelines (Exhibit D).
The equivalent level of safety established by Section 91.7(a) will be maintained
because prior to every flight, plus KM Video Productions, LLC also requires the safety checklist in Exhibit D that ensures that the DJI Phantom 2 Vision+ UAS is in an airworthy condition
based upon the UAS’ s compliance with its operating documents and as stated in the

conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those present ed herein (e.g.Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
4. Reasons Why An Exemption From The Requirements Of Section

91.121 Would Not Adverse ly Affect Safety.
As outlined in Exhibit D, KM Video Productions, LLC fly’s only under a very set rules. We
believe these rules include and go beyond current FAA guidelines. Therefore, the equivalent level of safety established by Section 91.121 will be ma intained because the39

altitude information of the DJI Phantom 2 Vision+ UA will be provided to the PIC via
GPS equipment and a radio communications telemetry data link, which downlinks from
the UA to the GCS for active monitoring of the flight path and alti tude. This altitude
information, combined with KM Video Productions operation of the DJI Phantom 2 Vision+
UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety
equivalent to Section 91.121. The altitude information will b e generated by GPS
equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation
point is automatically established by the UASs at ground level.
The FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, in all material respects, to those presented herein (e.g. Exemption
Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,
11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
5. Reasons Why An Exemptio n From The Requirements Of Section
91.151(b) Would Not Adversely Affect Safety.
A grant of this exemption would ensure an equivalent level of safety established
by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI

Phant om 2 Vision+ UAs; (2) the limitations on the proposed flight operations; and (3)
the location of the proposed flight operations. Accordingly, KM Video Productions, LLC will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ UA dur ing
daylight hours in VFR conditions, with enough battery power to fly for a total duration40

of 13.5 minutes to the first point of intended landing and, assuming normal cruising
speed, to fly after that for at least 4.5 minutes.
Here, as in Exemption No. 11 109, the technical specifications of the DJI Phantom
2 Vision+ UAS; the limitations on the proposed flight operations; and the location of the
proposed operations, will ensure an equivalent level of safety established by 14 C.F.R.
Section 91.151(b). Furth ermore, safety will be ensured as the DJI Phantom 2 Vision+
UAS provide audible and visual warnings to the PIC at the GCS when the UAs
experiences low battery voltage, the first warning occurring at approximately 33%
remaining battery power, and again at a pproximately 10% remaining battery power. At
the critically low battery level, the DJI Phantom Vision+ UAS will descend and land
automatically. Significantly, previous exemptions granted by the FAA concerning Section
91.151 establish that safety is not adv ersely affected when the technical characteristics
and operating limitations of the UAS are considered. Relief has been granted for manned
aircraft to operate at less than the minimums prescribed in Section 91.151, including
Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief
from Section 91.151 specific to UAS, in circumstances similar, in all material respects,
to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062,
11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
6. Reasons Why An Exemption From The Requirements Of Sections41

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.
In seeking this exemption, KM Video Productions, LLC submits that the equivalent level of
safety with regard to the regulatory maintenance and alteration requirements established
by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.41 7(a) & (b) will be

met because KM Video Productions, LLC will use trained technicians to perform maintenance,
alterations, or preventive maintenance on the UAS using the methods, techniques, and
practices prescribed in the operating documents (i.e., the KM Video Productions, LLC
Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction
Manual).
Furthermore, KM Video Productions, LLC will document and maintain all maintenance records for the DJI Phantom 2 Vision+ UAS.

Since the DJI P hantom 2 Vision+ UAS will be inspected as prescribed by the
operating documents, KM Video Productions, LLC will maintain the equivalent level of safety
established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI

Phantom 2 Vision+ U ser Manuals are attached hereto as Exhibit B; a copy of the DJI

Phantom 2 Vision+ UAS Maintenance LOG is attached hereto as Exhibit C.
Likewise, the exemption sought will not adv ersely affect safety because KM Video Productions, LLC will use trained techni cians to perform maintenance, alterations or preventive
Maintenance on the UAS using the methods, techniques, and practices prescribed by the
operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the42

DJI Phantom 2 Vision+ UAS will be performed by trained technicians. Maintenance
will be documented and maintained utilizing the monthly maintenance log.
Significantly, previous exemp tions granted by the FAA concerning Sections
91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety
is not adversely affected when the technical characteristics and operating limitations of

the UAS are considered. In cons ideration of KM Video Productions, LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 Vision+ UAS, KM Video Productions, LLC submits that safety will not be adversely affected by granting exemption f rom 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

In additional KM Video Productions, LLC will fly only under a tight set of rules which can be found in Exhibit D, which en sure the safest operation under any foreseen circumstance.
7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
KM Video Productions, LLC requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+ UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe
operation of the UAs for the limited purpose of conducting aerial video and photography
over certain areas of the United States for compensation or hire. FMRA Section 333 sets43

forth the requirements for considering whether a UAS will create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security; and further, provides
the authority for such UAS to operate without airworthiness certification in accordance
with any requirements that must be established for the safe operation of the UAS in the

NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14

C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+ UAS, since the airworthiness
regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standard s, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special
Conditions, states the following:
If the FAA finds that the airworthiness regulations of this subchapter do not
contain adequate or appropriate safety standards for an aircraft, aircraft engine, or
propeller because of a novel or unusual design feature of the aircraft, aircraft
engine or propeller, he prescribes special conditions and amendments thereto for
the product. The special conditions are issued in accord ance with Part 11 of this
chapter and contain such safety standards for the aircraft, aircraft engine or
propeller as the FAA finds necessary to establish a level of safety equivalent to
that established in the regulations.
See 14 C.F.R. § 21.16.

Therefore , in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the
FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI44

Phantom 2 Vision+ UAS, which contain such safety standards that the Administrator
finds necessary to esta blish a level of safety equivalent to that established by 14 C.F.R.
Part 21,
Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
F. A Summary That Can Be Published In The Federal Register, stating: The

Rules From Which KM Video Productions, LLC Seeks Exemption:
KM Video Productions, LLC seeks exemption from the requirements of 14 C.F.R Sections
61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1)
& (a)(2), and 91.417(a) & (b).
A Brief Description Of The Nature Of The Exemption KM Video Productions, LLC Seeks:
This exemption will permit KM Video Productions, LLC to commercially operate an Unmanned
Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support KM Video Productions, LLC Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, KM Video Productions, LLC request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.45

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without

airworthiness certification. As discussed in detail above, KM Video Productions, LLC will operate the DJI Phantom 2 Vision+ UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security

.46 

### Conclusion and Summary As set forth herein, KM Video Productions, LLC seeks an exemption pursuant to 14 C.F.R. 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit the safe operation of the DJI Phantom 2 Vision+ UAS commercially, without an airworthiness certificate, for limited use conducting aerial video and photography in Camden South Carolina and the Central South Carolina area. By granting this petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012 , while advancing the interests of the public, by allowing KM Video Productions, LLC to safely, efficiently and economically operat e the DJI Phantom 2 Vision + UAS commercially within the National Air Space. Wherefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, S ection 333, KM Video Productions, LLC r espectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R. Sections 61.113(a)& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)&(a)(2), and 91.417(a)&(b), and permit KM Video Productions , LLC to operate the DJI Phantom 2 Vision + UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: June 19, 2015 Respectfully submitted, KM Video Productions , LLC

____________________________________ KM Video Productions , LLC Kirk Mays 1110 A Broad Street Camden, SC 29020 Email: kirk@kmvideoproductions.com47

Exhibits:

A

– DJI Phantom 2 Vision+ Specif ications Data Sheet

B

– DJI Phantom 2 Vision+ Manufacturer’s User Manual

C

– Letters of support for granting the petition

D

– KM Video Productions, LLC On

- Site Safety Checklist

EXHIBIT

– A

DJI PHANTOM 2 VISION+ TECHNICAL

SPECIFICATIONS
KM Video Productions, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user
to set parameters which will not allow flight into controlled airspace. Parameters can also

be set to limit flight to no higher than a predetermined and set altitude as well as limit
flight to a predetermined and set distance. In addition, DJI software provides real

- time
altitude and location information to the PIC via the linked monitor (smart pho ne/tablet
devices)

Aircraft
Supported Battery: DJI 5200mAh LiPo Battery
Weight (Battery & Propellers included): 1242g
Hover Accuracy (Ready to Fly): Vertical: 0.8m; Horizontal: 2.5m
Max Yaw Angular Velocity; 200°/s48

Max Tiltable Angle: 35°

Max Ascent / Desc ent Speed: Ascent: 6m/s; Descent: 2m/s
Max Flight Speed: 15m/s (Not Recommended)
Diagonal motor

- motor distance: 350mm

Remote Control Operating Frequency: 5.728 GHz

- 5.85 GHz
Communication Distance (open area): CE Compliance: 400m; FCC
Compliance: 800m
Receiver Sensitivity (1%PER):

- 93dBm
Transmitter Power: CE Compliance: 25mW; FCC Compliance: 100mW
Working Voltage: 120 mA@3.7V

Built

- in LiPo Battery Working Current/Capacity: 3.7V, 2000mAh
Range Extender Operating Frequency: 2412

- 2462MHz

Communication Dis tance (open area): 500

- 700m

Transmitter Power: 20dBm
Power Consumption: 2W

EX HIBIT

– B

DJI Phantom 2 Vision+ Manufacturer’s User Manual
See Separate document attached to the Docket49

EXHIBIT

– C
Documentation from local business and government leaders supporting the exemption request.

EXHIBIT

– D

See attached KM Video Productions, LLC Checklist that we have been following over the last several
years, to ensure what we have learned is applied beyond your safety requirements.
See Separate document attach ed to the Docket