US Department of Transportation Exemption Request Pursuant to Section 333 of
the FAA

Reform Act and Part 11 of the Federal Aviation

December 30 , 2015

Ricky Williams 169 Clancy Cir. Cary, NC 27511 Ric.engineer@ gmail.com

U.S Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part
11 of the Federal Aviation Regulations from: 14 CFR 21 subpar t H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and ( 2); 14 CFR 91.417(a) and (b)

The exemption is in the public interest. Pursuant to the authority contained in 49
U .S.C. 106(f), 40113, and 44701.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the
"Reform Act ") and 14 CFR Part 11 of Unmanned Aircraft Systems (UAS ), Ricky

Williams hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of Designated UAS, provided such operations are conducted within an d under the conditions outlined herein or as may be established by the FAA as required by Section 333.Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide profes sional services in the following

areas:

1. Real Estate
2. Aerial Videography / Photography
3. Weddings
4. Bridge Inspections / Flare Stack Inspections
5. Law Enforcement / Fire Rescue
6. Utility Inspections not to limit, Pipelines / Cell Tower’s
7. Cinematography / Photography
8. Public / Private Events
9. Construction Sites
10. Search and Rescue
11. News Gathering
12. Public and Private Awareness to improve safety for currant & future UAS operations within the N AS.
13. Special Events
14. Disaster and Catastrophe Events.

On or about Sept 25, 2014 the FAA granted exemptions to six UAS operators, including Astraeus Aerial. As set forth in Top Shot’s Flight Operations and Procedures Manual (the “FOMP”) and Motion Picture T elevision Operations Manual (both submitted separately under 14 CFR 11. 35 (b), Ricky Williams will Adhere to the terms of the Astraeus Exemption.

Ricky Williams requested exemption would permit the operation of small,
unmanned UAS under c ontrolled And “sterile” conditions in the “outdoor television filming” airspace that is: (1) limited, (2) predetermined, (3) subject to controlled access, and (4) provide greater safety in connection with aircraft operations in the Outdoor film and televis ion industry. As established by the exemptions already granted by the FAA, approval of Ricky Williams exemption would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to establish requirements for the safe operation of such aircraft systems in the national airspace

.

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

The following is a statement from Neil Fried, Senior Vice President, Gover nment and Regulatory Affairs for the Motion Picture Association of America, Inc.,

“Unmanned aerial systems (UAS) offer the motion picture and television industry an innovative and safer option for filming. This new tool for storytellers will allow
for cre ative and exciting aerial shots, and is the latest in a myriad of newtechnologies being used by our industry to further enhance the viewer experience. We welcome the FAA’s leadership and support their guidance to safely authorize the use of UASs for the m otion picture and television industry.”

This application is submitted by:

Ricky Williams 169 Clancy Cir. Cary, NC 27511 Ric.engineer@ gmail.com

Regulation s from which the exemption is requested :

From which the exemption is requested : 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)
14 CFR 91.103
14 CFR 91.109 14 CFR 91.119 (c)
14 CFR 91.121
14 CFR 91.1 51 (a) 14 CFR 91.203 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a) 14 CFR 91.409 (a) 14 CFR 91.417 (a)

As in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No.

FAA

− 2014

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

− 2014

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

− 2014

− 0382), 11213 to Aeryon Labs, Inc. (see Docket No. FAA

− 2014

− 0642), and 12645 to Allied Drones (see
Docket No. FAA

- 2014

- 0804), There is enhanced safety achieved using an unmanned aircraft (UA) with the specifications descri bed 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.

Ricky Williams Will operate one or more of the Following model UASDJI Inspire 1 , 3DR Solo 8X, DYS D800 with the A2 C ontroller

Safety requirements. The approval of this application presents no national security issues. Regarding the level of safety sur rounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the applicant graciously req uests that the FAA grant the requested exemption.

AIRCRAF T AND EQUIVALENT LEVEL OF SAFET EY

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property
usi ng conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM)
include:

1. The UAS will weigh si gnificantly less than 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

4. Ma ximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one
Visual Observe r (V O).7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have logged a minimum of 20 hours on the designated UAS.

8. A safety briefing will be performed prior to each day's flights consisting of all the days' Production activit ies.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Cla ss G airspace no closer than a mile radius of the geographic center/Airport Referen ce Point (ARP) of a tower controlled or uncontrolled airport.

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport.

13. The operator will do a pre check of aircraft prior to each flight. And log each flight.

14. The operat or will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent leve l of safety determination, as U.S. Department of Transportation required under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive up to
d ate information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all
times.

17. The PIC will abide by all rules

18. If the UAS loses communications with the remote controller or loses GPS sig nal, the UAS will have the capability to return to a predetermined location within a designated location and land autonomously.19. The UAS will have the capability to abort a flight in case of emergencies with

an automated "Return Home and Land" function

.

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies such as low battery.

21. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operationa l 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.g ov

.

The operating limitations proposed Ricky Williams provide for a higher level of safety because operations further enhance safety of movie and television filming operations using conventional aircraft.

As set forth in the FOPM, the limitations and conditions include: The UASs will weigh less than 55 pounds

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

Maximum flight time for each flight will be 30 minutes or at 25% of battery power
reserve whichever comes first.

Fl ights will be operated at an altitude of no more than 400 feet AGL as indicated by onboard GPS system.

Minimum crew for each operation will consist of the UAS pilot, the observer.

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

A UAS pilot will be an FAA licensed airman with at least a private pilot’s
certificate and third class Medical

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

.

The FOPM requires the establishment of a “Security Perimeter” for the flight operations area.

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

. All personnelPerforming duties within the boundaries of the safety perimeter are required to
attend.

The operator will file a FAA Form 7711

- 1 or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office.

The operator will obtain consent of all persons involved in the filming and ensure that only Consenting persons will be allowed within 100 feet of the flight operation.

The operator will submit a written Plan of Activities to the FSDO three days before the proposed shoot as required in the FOPM.

The Pilot and observer must be trained in UAS operations and received current information on the particular UAS to be operated as required by 3 the FOPM.

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

Written and/or oral permission from the relevant property holders will be
obtained.

All required permissions and permits will be obta ined from territorial, state, county, or city Jurisdictions, including local law enforcement, fire or other managing governmental agencies.

If the UAS loses communications or loses its GPS signal, the UAS will and does have the capability to return to a p re

- determined location within the Security Perimeter and land safely.

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

14 C.F.R. 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in
Com mand Sections 61. 113 (a) and (b) limit private pilots to non

- commercial operations. Because the UAS Will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of Safety of current operations by requiring the PIC operati ng the aircraft to have a private pilot’s license Rather than a commercial pilot’s license to operate a small UAS. Unlike a conventional manned aircraft,

A UAS is remotely controlled by a ground

- based operator. The operational area
is controlled and restr icted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft for hire. The risks
associated with the use of a UAS are so diminished from the level of riskassociated with commercial operations contemplated by part 61 allowing UAS use by a private pilot as PIC exceeds the present level of safety sought by 14 C.F.R. 61.113 (a) ab (b).

14 C.F.R. 91.103: Prefight Action

Section 91.103 requires each Pilot to preflight an aircraft before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided.
The P IC will take actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before each flight.

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

Section 91. 119 establish es safe altitudes for operation of civil aircraft. Section 91.119 provides, in Pertinent part, that:

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

( c ) Over other than congested areas. An altitude of 5 00 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, or structure. “

Because Ricky Williams requests authority to operate at alt itudes only up to 400 feet AGL, an exemption is needed to allow such operations. Except for the limited conditions stated in the FOPM, the UAS will never operate higher than 400 feet AGL. It will, however, be operated in a restricted area within a security perimeter, where buildings and people will not be exposed to operations without their pre

obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flig ht will be taken without the permission of property owners or local officials. Because of the advance notice to the property owners and participants in the filming activity, all affected individuals will be informed of the planned flight operations. Compar ed to the flight operations for manned aircraft and the lack of flammable fuel, any risk associated with the proposed UAS operations is far less than conventional aircraft operating at or below 500 feet AGL.

In addition, the low

- altitude operations of the UAS will ensure separation between
a UAS and conventional aircraft.14 C.F.R 91.121 Altimeter Settings

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “... to an elevation of the departure airport or an appropriate altimeter setting available before departure.” As a UAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant to the FOPM and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

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

Section 91.151 (a) prohibits an individual fro m beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

- (1) During the day, to fly after th at for at least 30 minutes

......”

The battery powering the Ricky Williams UASs provides approximately 20 minutes of powered flight. To meet the 30

- minute reserve requirement in 14 CFR 91.151, UAS flights will be limited to approximately 10 minute s in length. Given the limitations on the UAS’s proposed flight ar ea and its proposed flight area and proposed operations within a predetermined location, a longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, operating the U ASs in a tightly controlled area where only people, property owners, or official representatives who have signed waivers will be allowed, less than 30 minutes of reserve fuel does not engender the type of risk that 91.151 was intended to
address. The owner /operator of Ricky Williams believes that safety can be achieved by limiting flights to end with a 25% battery reserve as indicated on the PIC’s controller mounted monitor. This restriction would be more than adequate to return the UAS to its prede termined landing area.

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

Maintenance Inspections

These regulations require that an aircraft operator or owner shall “have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.....,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given th at these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections. Maintenance will be accomplished by the operator. Anequivalent level of safety will be achieved because the UASs are limited in size, will carry a smal l payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL.

As provided in the FOPM, the operator will ensure that the UAS is in working order prior to flight, perform any required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the UAS and best suited to maintain it in an airworthy condition.

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

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as provided for in § 47.31(c). Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraf t unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or

crew.

A UAS has no certificate nor does it have a cockpit door, Jonathan Ru ssell Sorli is requesting an exemption from 91.203 (a) and (b) also 91.715

.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Ricky
Williams seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b); 91.203 (a) and (b); 91.715 to operate commercially a small unmanned vehicle (55 pounds or less) in motion picture and television operations.

As established by the UAS exemptions already granted by the FAA, allowing commercial operations of UASs in the film industry will enhance safety by reducing risk. Conventional film operation s, using turbine aircraft, operate at low altitudes and present the risks associated with aircraft that weigh around 4,000 pounds, and which carry large amoun ts of Jet A fuel. Such aircraft must also fly to and from the film location. In contrast, a UAS we ighing fewer than 55 pounds
and powered by batteries eliminates virtually all of that risk given the sma ll size
and lack of combustible fuel. The UAS is carried, and not flown, to a film set. Inthis regard, the UAS carries no passengers o r crew and, there fore, will not expose them to the risks associated with manned flights.

The operation of UASs conducted in the strict conditions outlined in the FOPM will provide an equivalent level of safety supporting the grant of the exemption requested herein. The UA Ss operate at slow speeds, close to the ground, and in a sterile environment. UAS’s also have far less impact on the environment compared to normal filming practices it replaces. As a result, they are far safer
than conventional operations conducted with t urbine helicopters flying near the ground and people.

Privacy

All flights will occur over private or controlled access areas with the property owner’s prior consent and knowledge. Filming will be only of people who have given their consent or otherwise have agreed to be in the area where filming will take place.

Satisfaction of the criter ia provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Ricky Williams requested exemption.

If you have any questions or need any additional information,

Ricky Williams 169 Clancy Cir. Cary, NC 27511 Ric.engineer@ gmail.com

Sincerely yours,

Ricky Williams