# MSPhotography Professional Photographic andMedia Services

33 Sea Ave, Quincy, MA Docket Management System U.S. Dept. ofTransportation 1200 NewJersey Ave., SE Washington, D.C. 20590 

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MSPhotography, December 31, 2014 Re: Exemption Request PursuantTo Section333

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Dear Sir orMadam, Pursuant to §333 ofthe FAA Modernization and Refvrrn Act of2012 (the Reform Act) and 14 C.P.R. Part 11, MSPhotographyDBA MSAerial,operatorofSmall UnmannedAircraft Systems (sUASs) equippedto conduct aerial photography for the media and advertising indestries for pre-planned, controlled area, photographic and surveying services, hereby applies for an

**exerr1p~.ion** from the listed Federal Aviation Regulations (PARs) to allow commercial operation ofits sUASs, ::;o long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as requiredby§333. MSAerial's currentoperationofs UASs for commercialpurposeshasbeenhalted to comply with recently enacted federal aviation regulations pertaining to sUASs.

As described more fully below, the requested exemption would permit the operation ofsmall, unmanned and relatively inexpensive multirotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on-site safetypersonnel controlling access, and 4) would provide increased safety and enhancements to clients' business operations.

The name and address ofthe applicant is: MSPhotography dba MSAerial Attn:Melinda Sokoloski Ph:+1- (857)-204-2448 Email:mindi@msaerial.com Address: 33 Sea Ave, Quincy, MA 02169

MSAerial respectfullyrequests a grant ofan exemption ofthe following sections ofTitle 14 ofthe Code of Federal Regulations:
• 14 CFR 21;
• 14 CFR 91, et seq.; • 14 CFR 45.23 (b);Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformAct of2012

o 14 CPR 61.113 (a) & (b);

o 14 CPR407 (a)(1);

o 14 CPR 409 (a)(2);

o 14 CPR417 (a) & (b). MSAerial also respectfullyrequests an Exemption from Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

o 14 CPR45.23(b);

o 14 CPRPart 21;

o 14CFR61.113(a)&(b);

o 91.7 (a);

0 91.9 (b) (2);

0 91.103(b);

0 91.109;

0 91.119;

0 91.121;

o 91.151(a);

o 91.203(a) & (b);

o 91.405 (a);

o 91.407 (a) (1);

o 91.409 (a) (2);

o 91.417 (a) & (b).
I. The Extent of Relief MSAerial Seeks and the Reason It Seeks Such Relief: MSAerial submits this application in accordance with the Reform Act, 112 P.L. 95 §§331-334, seeking relief from any currently applicable federal aviation regulations PARs pertaining to UASs (unmanned aircraft systems) and operating to prevent MSAerial contemplated commercial photographic, mapping, and other flight operations within the U.S. national airspace system.

The Reform Act in §332 provides for such integration ofcivil UASs into our national airspace system as it is in the public's interest to do so. MSAerial's lightweight UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combinedwith a sterling safetyrecord in similar industries, MSAerial's light duty UASs are ideal recipients ofexemption bythe intent ofthe Reform Act.

Considerations for reliefinclude a combination ofsUAS physical characteristics, safety features, and safe practices identiied in §333:

o sUAS weight,

o sUAS overall size,

o sUAS speed over ground,

o sUAS flight zone characteristecs,

- Non-operation near airports (civilian or military),

- Tightly controlled operation in populated areas, 33 SEA AVE, QUINCY, MA 02169-3135 MINDI@MSAERIAL.COM + 1- (8 57)- 204-2448Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformActof 2012

• Operation ofthe UAS byVLOS.
• Coordinationbya minimumof4persons, three staffmembers ofMSAerial andone safetyofficial from

the client. Specific consideration is outlinebelow.
14 C.P.R. Part 21, Subpart H: Airworthiness Certificates 14 C.P.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and §333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and §333 oftheReformActbothauthorizetheFAA to exemptaircraftfromtherequirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular sUAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed.

The sUAS to be operated by MSAerial is less than 11kg. with maximal payload consisting of remote sensing instrumentation, carries neither no persons, carries no explosive or flammable materials including combustiblefuels, andoperates exclusivelywithin a secured area. Unlike othercivil aircraft, operationsunder this exemption will be tightly controlled and monitored byboth the pilot (PIC), 'spotter' role designated to act as both the remote sensing controller and secondary monitor for safety issues, and a technician, which assists in matters related to maintaining the sUAS and also monitors for safety concerns and liasons to the on-site safety officials. These enhancements to current safety practices and regulations, which already applyto civil aircraft, provide a greater degree ofsafetyto the public and propertyowners than conventional aircraft operationsconductedwithairworthinesscertificates issuedunder 14 C.P.R. Part21, SubpartH. Lastly, application ofthese same criteria demonstrates that there is no intrinsic credible threat to national security posedbytheUAS, duetoits size, speedofoperation,locationofoperation,lackofintrinsicexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load.
14 C.P.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed onlimited, restricted orlight-sportcategoryaircraft orexperimentalorprovisionallycertificated aircraft, theoperatormustalso displayonthataircraftneareachentrancetothe cabin, cockpit, orpilotstation, in letters not less than 2 inches nor more than 6 inches high, the words "limited;' "restricted;' "light-sport:' "experimental:' or "provisional;' as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit orpilot station on which the word "Experimental" can be placed. Given the size ofthe sUAS, two-inchletteringwill be impossible. The word "Experimental"will be placed on the frame in compliance with §45.29 (f) at a size suitable for the available space.

The equivalent level ofsafety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) wherethepilot, observerandothersworkingwiththe sUAV will see theidentification oftheUAS as "Experimental:' The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

Further markings include the use offlashing green LED illumination on the underside ofthe sUAS frame which stands at contrast against a blue orwhite sky.

33 SEA AvE, QuiNCY, MA 02169-3135 MINDI@MSAERIAL.COM 

### + 1- (8 57)- 204-2448Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformAct of2012

14 C.P.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilotin Command. §61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring a ground crew member to have a private pilot's license rather than a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present level ofsafety achieved by 14 C.P.R. §61.113 (a) & (b). 14 C.P.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a subsetofwhich areprovidedin enclosed Supplementalmaterial, an equivalentlevel ofsafetywill beprovided. 14 C.P.R. §91.9 (b) (2): Civil Aircraft FlightManualinthe Aircraft. §91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft
... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configurationhasno abilityto carryaphysical flight manualonthe aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual at the ground control pointwhere the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,32827, and 10700. 14 C.P.R. §91.103: Preflight action This regulation requires each PIC to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraftflight manuals will notbe provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation of flight. Further, we have proprietary manuals created with the help ofsUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered to. 14 C.P.R. §91.109: Flightinstruction §91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instructionunless that aircrafthas fully functioning dual controls. sUASs andremotelypiloted aircraft, bytheir design do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and
33 SEA AvE, QurNcY, MA 02169-3135 MINDI@MSAERIAL.COM 

### + 1- ( 8 57)- 204-2448Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformActof2012 speed ofthe aircraft. Enhancingthis safety is the technologyinherent in the remote controls utiziling digital communicationswhich is paired to the sUAS makingit nearly impossible to unintentionally or intentionally have the control communications interrupted.
14 C.P.R. §91.119: Minimum safe altitudes §91.119 establishes safe altitudes for operation ofcivil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that closely mimics the behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption maybe neededto allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided visual line ofsight, whichever is closer. It will however be operated in a restricted area with securityofficials tasked with ensuring public safety, and where buildings and people will notbe exposed to operations without theirpre-obtained consent and training.

The equivalentlevel ofsafetywillbe achievedgiven the size, weight, speed ofthe UAS as well as thelocation where it is operated. No flight operation 

### will be taken without the permission ofthe property owner in the case ofprivate propertyorlocal officials i the case ofpublicpropertyorprivatepropertywithpublic interests. Because of the advance notice to the property owner and participants in the remote sensing activity, all affected individualswill be aware oftheplannedflight operations. Comparedto flight operationswithaircraft or rotorcraftweighting far more than the maximum llkgofMSAerial's sUASs proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small- UAS operations and the operations ofconventional aircraft that must complywith §91.119.
14 C.P.R. §91.121 Altimeter Settings §91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "
...to the elevation of the departure airport or an appropriate altimeter setting available before departure:' As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, confirming the altitude ofthelaunch site shown onthe GPS altitudeindicatorbefore flight. The PIC andTechnician will also ensure effective pairing with multiple GPS sources to guarantee accurate detection ofheight.
14 C.P.R. §91.151(a): FuelRequirements for FlightinVFR Conditions §91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly after thatfor at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The batterypowering the sUAS provides approximately 15 minutes ofpowered flight in hover mode with outpayload. MSAerial's sUAS will notbe able to meet the 30 minute reserve requirement in 14 CPR §91.151. Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve power, does not engender the type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. MSAerial believes that an equivalentlevel of safety can be achieved bylimiting flights to» 10 minutes or 25% ofbatterypower whichever happens first. This restriction wouldbe more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, includingExemptions 2689F, 5745, 10673, and
33 SEA AVE, QUINCY, MA 02169-3135 MINDI@MSAERIAL.COM 

### +1- (8 57)- 204-2448Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformAct of 2012 10808.

14 C.F.R. §91.203 (a) & (b): CarryingCivil Aircraft Certification and Registration The regulation provides in pertinentpart: (a) Except as providedin §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate
... (b) Nopersonmayoperateacivil aircraftunless the airworthinesscertificate requiredbyparagraph (a) ofthis section ora special flight authorization issued under §91.715 is displayed at the cabin orcockpit entrance so thatit is legible to passengers or crew. The sUAS fully loaded weighs no more than 11kg and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the s UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 ofthis chapter
...;' and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplishedbythe operator pursuantto the flight manual. An equivalent level ofsafetywill be achieved because these small UASs are verylimited in size andwill carrya smallpayload and operate onlyin restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operatingfrom nohigherthan400 feet AGL. The operatorwillensurethatthe UAS is inworkingorderpriorto initiatingflight, performrequiredmaintenance, andkeep alog ofany maintenanceperformed. Moreover, the operatoris the person mostfamiliar with the aircraft andbest suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety.

An exemption granted to MSAerial would permit its operation of lightweight, unmanned, remotely controlled, sUASs in a tightly controlled environmentwith limited airspace. MSAerial utilizes local business' safety officers in specifically determined areas (designed flight zone) to mitigate injury and propertydamage while fulfilling clients' goals. Technical enhancements to current safety controls will allow MSAerial to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being implemented by the FAA and Department ofTransportation. Further, MSAerial conducts its operations in compliance with protocols described herein or as otherwise established bythe FAA.
II. Commercial and Public Benefits We at MSAerial believe that granting this exemption request furthers the public interest by providing safe (by way ofan unmanned system) and efficient means to meet technical problems solvable by elevated data collection instruments. MSAerial's client base are typically small to medium sized business' looking to increase their awareness of structures or landscape on their respective properties through data collection 33 SEA AVE, QUINCY, MA 02169-3135 MINDI@MSAERIAL. COM + 1- ( 8 57)- 204-2448

### Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformAct of2012 by photographic, videographic or lidar based surveying. By moving these functions onto sUAS based aircraft, the potential for loss oflife or property is diminished due to the greater control in a smaller and safer aircraft that holds no persons. Second, there are no reactive or combustible materials on board the sUAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability ofMSAerials UASs allow the PIC to avoid hazards. Lastly, due to the nature ofthe remote sensing instrumentation onboard, the sUAS can maintain quite a safe distance between the aircraft and the object(s) undergoing scrutiny. Accordingly, MSAerial's UASs have operated and will continue to operate at and above current safetylevels.
A. The costs and benefits ofyour proposed action to society in general and specific groups within society As described above, MSAerial's pastcustomershave been small to mediumbusiness seeking aremote sensing solution to specific issues before a larger effort on their part would come underway. Examples include construction efforts that sought elevated photographic imagery of specific landforms to minimize cost of efforts to develop, a regional park service thatwanted to quantifythe changinglifecycle ofit's flora byway of measuring leafhealth through gradual chlorophyll depletion, and a local cities' Dept. ofPublic Works that sought to collect images and 3D structural data by way ofLidar sensing 

### en masse ofit's bridges to serve as a supplementto it's routine repair and planning documentation.

The impactto society, financial andotherwise, wouldbe extremelyminimal. Indeed, it's been demonstrated that s UASs have the ability to drasticially increase the information availible to policymakers at a fraction of the cost ofmeasuring this data by terrestrial means. One such impact would be inconvenience to directly proximal andnon-essential personnel thatwouldbe displaced from publicorbusiness ownedpropertyifit is deemedto be unsafe. Inthis case we relay ourneeds for aflight zone with the requirement that itbe safe from casual intrusions and allow the business time to shift operations in order to minimize potential safetyissues. This is best performed with the aid ofsafety personnel that actively steer non-essential persons around the flight zone. 1. The effect ofan exemption for MSAerial on the quality ofthe natural and social environments Utilizing sUASs minimizes the requirementfor conventional aircraft. This eliminatesthe needfor anon board pilot, time consuming adherance to regulations surrounding bookeeping and submission of flight paths to local civiliar or military airports, and detrimental effects to the environment caused by operating a combustiblefuel based, large scale aircraft, with restrictions ontheproximityto the targetfor remote sensing.
Ill. Flight Capabilities and Characteristics of MSAerial's UASs Persuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and characteristics ofthe sUAS. 1

MSAerial UASs utilizes eight (8) counter-rotating propellers paired oppositely to each other for balance, control and stability. The total span ofthe sUAS is ""1.2m allowing for stable flight or landing even with the sudden onset ofdetrimental environmental conditions. The sUAS's have a maximal unit+ payload mass of 11kg, including cinematic/photographic or other surveying equipment. MSAerial's sUAS is designed to primarilyhoverinplace to capturephotographicdata andthen operate atless than a 35 knotmaximumspeed to the nextpointofinterest. Theyare capable ofvertical andhorizontal operationsbut, in practice, is operated onlywithin unaided VLOS ofthe PIC. In addition to the PIC, MSAerial employs a spotter (VOS role) and a technician (secondary VOS and on-site personnelliason) which are within unaided verbal communication range. Thesepersonnel are supplementedbysafetyoffcialsprovidedbytheclientwho are instructedto cordon

1More characteristics have been outlined in the enclosed supplemental materials. 33 SEA AvE, QurNcY, MA 02169-3135 MINDI@MSAERIAL.COM + 1- (8 57)- 204-2448

### Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformAct of2012 offand otherwise minimize pedestrian access in the flight zone ofthe client's grounds. In the event ofloss of visual ofthe UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r,o:,h) based controls which allows the PIC to utilize one controller axis to recall the UAS to the PIC's position without concern to the current heading ofthe sUAS. In the event ofloss of sight ofthe sUAS into an area containinghazards orpossible hazards, the spotterhas aheads-up-displaycontainingalive video feed which can be used to locate the UAS while it maintains it's position in hover mode. The sUAS has demonstrated it's ability to maintain it's position by GPS coordinates in hover mode in rv25kph wind gusts at ,..,_,25 feet representing an extreme environmental conditionbeyond the range ofconditions within the scope for s UAS operation.

All ofMSAerial's sUASs utilize LiPo (lithium polymer) batterybasedpower sources, decreasing safetyrisks from more easily combustible, fuel based, power sources. Flight times generallylast between eight (8) to ten (10) minutes allowing the staffto work with small flight areas per phase. The maximum flight time without payload is 15 minutes, however practical safe operation limits this to 10 to give ample time to control the sUAS to a safe landing zone. MSAerial further restricts flight time by not operating its sUASs with less than twenty five percent battery capacity. Further safety management systems in place include a GPS mode that allows MSAerial sUASs to hover in place ifcommunication with the PIC is lost and optionally follow a set of waypoints at a set speed and height to a 'home base' predesignated safe landing zone. In the event of unforseen motor(s) failure, the system will enter into a controlled descent while allowing full use ofall UAS flight controls by the PIC. All commands sentvia remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's realtime 3 dimensional positionandcompensaterotors controlthe sUAS regardlessofspinvelocity. Landinggearis also programmed to deploy based on sensing ofrange to ground from non-GPS based sources. This assures that ifone system is compensated a safe and successful landing can still occur.
IV. Reasons Why an Exemption to MSAerial Will Not Adversely Affect Safety Standards MSAerial's contends that operation ofit's sUASs will not "create a hazard to users of the national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the diminuative size and weight ofMSAerial's sUASs, combined with their operation in cordoned off and well-controlled areas, MSAerial's sUASs falls within Congress's contemplated safety zone. MSAerial sUASs have an established safety record bolstered by multi-point preflight checklist, awareness oftheir surroundings and intimate knowlege ofthe behaviour ofthe s UAS platform in manyweather conditions. This safety record and implemented operational practices demonstrate an awareness ofpublic safety.

MSAerial operations routinely provide a level ofsafety at least equal to existing rules, and in nearly every instance, exceeds existing rules. MSAerial has worked verycloselywith the regional vendors and supportfor this unit to create a tightly integrated and highly fault tolerant platform that has been tested throughly by a vendor with aproven record for safety and solid designs.

Though it does not mitigate safety it is of note that as of Nov 2014 there are few companies that will insure s UAS operations and s UAS based companies. The sUAS ofuse at MSAerial is one oftwo models (by current awareness) that qualify for protection against damages or injury. MSAerial attained the maximal level ofinsurance to rectify accidental damage or injury. MSAerial also continues to work closely with this organization to identify and mitigate sUAS platform risk due to their expertise in several industries closely related to the aviation and transportation.

MSAerial does not operate its UASs on or near airports and generallyhas onlyoperated its fleet on private grounds with cordoned offareas or areas under the control ofthe propertyowner 

### I client with assistance by safety officials employed by the business. MSAerial determines the areas needed to fulfill the clients' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initiallybythe RC UAS trade andhobbygroups and recently codified by relevant PARs. 33 SEA AvE, QuiNCY, MA 02169-3135 MINDI@MSAERIAL.COM 

### + 1- ( 8 57)- 204-2448

### Re: Exemption RequestPursuant To Section 333 ofthe FAA Reform Act of 2012 MSAerial standardized on the following practices to ensure safe operation ofit's UASs:

• Workwith on-site personnel to plan the flight goals,
• Workwith on-site personnel to restrict access to non-essential persons, • Operation by unaided VLOS operation only,
• Operation in phases 10 minutes in length,
• Operation to minimal25% batterypower, • Operation ofdevice to GPS aided readout to 300ft at maximum,
• Numerous pre-programmed fail-safes that ensure specificbehaviorperissue,
• Three main roles supplementedbyon-site safety personnel,
• Employ controlled lifecycle management ofcomponents to guard against multiple failures,
• Preform a site check day(s) before flight to identifypotential issues,
• Subscribe to relevant local weather and safety alerts,



### • Expertly choose data collection instruments and accessories to minimize flight requirements or

expertise,

MSAerial has experience in similar fields and has adapted this experience in it's use ofUASs to increase safety. In combination to the ever expanding knowlege repositories from hobbyists and experts alike, MSAerial is constantly evolving it's practices when there is a clear benefit to operations or increased safety element. A. Summary Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

MSAerial (applicant) seeks an exemption from the following rules: 14 C.P.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (11kg or less) in elevated photographic and remote sensing operations.

Approval ofexemptions allowing commercial operations ofsUASs in the the media industrywill enhance safety by reducing risk associated with conventional aircraft operations and other means ofelevated remote sensing involving persons. The public benefit served by approval of this petition is increased awareness of characteristics of difficult imaging targets. A sUAS weighing fewer than 11kg and powered by sealed batteries eliminatesvirtually all associated risk inherentin operating conventional aircraft in close proximity to buildings orpersons orotherwise elevatingpersons to aposition theywouldbe able to collect needed data.

The operation ofsmall UASs, weightingless than 55lbs., conductedin the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations.
33 SEA AvE, QuiNCY, MA 02169-3135 MINDI@MSAERIAL.COM 

### + 1- (857)- 204-2448Re: Exemption RequestPursuant To Section 333 ofthe FAA ReformActof2012 As identified and described herein, Melinda Sokoloski, and her companyMSPhotography DBA MSAerial, is an experienced, recognized media services professional in the various photographic industries. Mrs. Sokoloski andhercompanieshavebeenproducinganddeliveringmedia andtechnical solutionsfor themedia service industryfor ten (10) years with a spotless safety record.

The FAA has been given the authority to issue the exemption to MSPhotography DBA MSAerial pursuant to the Federal Aviation Act, 85 

### P.L. 726 (1958), and as such, we humbly seekyour consideration and approval ofthis petition.

PIC VLOS Best,

end: Supplement A: Physical characteristics ofUAS end: SupplementB: Flight Operation and Procedures Manual (FOPM) related to operation end: Supplement C: Flight maps in MSAerial regional base

33 SEA AvE, QuiNCY, MA 02169-3135 MINDI@MSAERIAL.COM 

### + 1- (8 57)- 204-2448

### SupplementB :Summary Sections of Flight Operations andProcedure Manual (FOPM)

• All regular and irregular operations are noted with timestamps, relevant UAS metrics and corrective

action procedures (CAP) that are performed.

- Note: All irregularbehaviorhave rootcause analysisperformedbefore UAS operationis resumed. VI. Emergency Procedures
• Loss ofRemote Signal

- The flightpackage features an optionalenhancedfail-safe whichreturns the UAS to thehomebase waypointvia the same path taken to point oflost signal.

- The UAS will then preform a hover over this waypoint and then a controlled landing. • Loss ofGPS signal

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

- At loss of three (3) GPS satellites, manual mode can be activated or the flight package can be programmed to preform a controlled landing to the home base waypoint.

- Groundbasedheightrangingis preformedbya seperate system and so loss ofGPS will notimpact controlled landing in a safe manner. • Loss ofEngine Power

- In the event ofone (1) (or to two oppositely positioned) rotor or motor failure the system will enter into controlled spin where all controls are translated based on current orientation and will behave as normal operation to the PIC to ensure a safe landing,

- In the event ofmultiple rotor or motor failures the flight package can be configured to preform a safe landing or attempt operation to home base waypoint.

- Note : Behavior of the landing location is highly dependant on the position and number of rotors/motors that are affected. • Loss ofGround Control Software

- This will not affect operation ofthe flight. The unitwill be piloted to a safe landing area and then landed so that examination ofthe link can be made.

Norfolk, SS. Commonwealth of Massachusetts December 3:1;, 2014 On this 31st day of December, 2014, before me, the undersigned Notary Public, personally appeared Melinda Sokoloski, provide to me through satisfactory evidence of identification, which was her Mass. Driver's License, to**----~b~e~~~he** person whose name is signed on the preceding document, and acknowledged to me that she signed it voluntarily as her free act and deed and for its stated purpose.

MINDI @MSAERIAL. COM

# MSPhotography Professional Photographic and Media Services

33 Sea Ave, Quincy, MA Docket Management System U.S. Dept. ofTransportation 1200 New Jersey Ave., SE Washington, D.C. 20590 1 ..1.II1 ....1.1.1.1..II....1 ..II

Supplement A : Physical Characteristics ofMSAerial'& UAS

Dear Sir or Madam, Addr: 33 Sea Ave Quincy, MA, 02169-3135 Ph: +1-(857)-204-2448 Email: mindi @ms aerial. com



### VVeb: msaerial.com

MSPhotography, December 31, 2014

Please find in this document specifications related to the UAS subject to consideration for Exemption. All specifications given by the manufacturer. It is ofnote that these specifications in some instances constitute the maximal values discovered by the manufacturer and averaged over several test units. MSAerial utilizes these metricswhen forming safe and sustainable flight operations and in noway do the specification extrema contained herein constitute normal MSAerial flight parameters. I. General Manufacturer Details

Specification Manufacturer Model Website Contact (Ph) Contact (Em) Value DJI S1000 (SpreadingWings) www.dji.com us.support@dji.com

+1 (818) 235-0789

### SupplementA :Physical Characteristics of MSAerial's UAS
II. Physical Characteristics Frame Specification Value Diagonal Wheelbase Frame Arm Length Frame Arm Weight(with Motor, ESC, Propeller) Center Frame Diameter Center Frame Weight Landing Gear Size 1045mm 386mm 325g 337.5mm 1330g 460mm(L)x511mm(W)x305mm(H)

Specification Motor Specification Stator Size KV Max Power Weight Value 41x 14mm 400rpm/V 500W

158g

Electronic Speed Controller Specification Value Stator Size 41 x 14mm Working Current 40A Working Voltage 6S LiPo Signal Frequency 30Hz 450Hz Drive PWM Frequency 8KHz Weight (with Radiators) 35g

Specification Material Size Weight Propeller Value Performance engineered plastic 15x5.2inch 13g
Flight Parameters Value TakeoffWeight (with payload) Total Weight (system only) Power 6.0Kg c-v 11.0Kg 4.2Kg BatteryLiPo (6S,10Ah 20Ah,15C(Min)) 4000W 1500W (@9.5Kg total load) 15min (@15Ah @9.5Kg total load) -10 "'-J +40 °C MaxInst. Power Hovering Power HoveringTime Working Temp

33 SEA AVE, QUINCY, MA 02169-3135 MINDI@MSAERIAL.COM + 1- (8 57)- 204-244833 Sea Ave, Quincy, MA Docket Management System U.S. Dept. ofTransportation 1200 New Jersey Ave., SE Washington, D.C. 20590 1 ••1.111••••1.1.1.1••11••••1 ••11 Addr: 33 Sea Ave Quincy, MA, 02169-3135 Ph: +1-(857)-204-2448 Email: mindi@msaerial.com

Web: msaeri al. com

MSPhotography, December 31, 2014 SupplementB : SummarySections ofFlight Operations and Procedure Manual (FOPM)
Dear Sir orMadam, I. Introduction This manualdescribes the notable roles, tasks, and operationsperformedbyMS photography/MS Aerial. The aim is to document everything that is needed to be done during a mission, so it can act as a reference point for team members. II. Roles and Responsibilities As much as is possible, MSAerial staff attempt to have redundancy in expertise and skillsets related to operations ofthe UAS.

Pilotin Command (PIC)

• Piloting the UA V. This will include:

- Takeoff,

- Normal Flight,

- Flight during emergencyprocedures,

- Landing, • Assembling the UAV • Performs pre-flight checks ofthe firmware,

### SupplementB :Summary Sections of Flight Operations andProcedure Manual (FOPM)

• Performs pre-flight checks ofthe hardware, • Preforms pre-flight checks ofthe software. Spotter

• Relays notable flight parameters such as flight times, battery strength, metrics from the UAS. • Primary communication linkbetween pilot and on-site safety personnel, • Will hold physical documents related to current flight, • Preforms pre-flight checks ofthe data collection equipment, • Monitors ground and greater above-ground environment for safety concerns Technician

• Assembling the UA V, • Preforms pre-flight checks ofthe hardware, • Performs pre-flight checks ofthe software, • Secondarycommunication linkbetween pilot and on-site safety personnel, • Relays to the Spotter and records notable flight parameters metrics from the UAS, • Monitors ground and greater above-ground environment for safety concerns Ill. Pre-Flight Checklist A. Before Power Applied • Check for physical damage and any missinghardware, • Check all electronics present and connected/ check coord connections are tight. • Confirm all batteries charged, • Check all rotors and moving parts for debris that would preventproper operation. • Checkweather patterns the night beforehand. SlOOO should be raised above the ground when testing

landing gear orrecalibrating servo travel. • Check data collection equipment for proper operation. • Check data collection equipment for issues that would impact safe operation offlight package. B. After Power Source Applied • Confirm properpowerreading ofbattery, • Run hardware based systems check, • Run software based systems check, • Check flight LED array, • Confirm proper radio link to flight controller, • Confirm proper radio link to data collection device controller, • Confirm secondarycontroller connection to UAS onboard flight controller, • Confirm waypoints and geofences are accurate to currentflight, • Confirm desired behavior ofemergency i[ifailsafes, • Checkwith on-site safety personnel for any changes in goals 

### I flightpath.

33 SEA AvE, QurNcY, MA 02169-3135 MINDI@MSAERIAL.COM + 1- (8 57)- 204-2448

### SupplementB :Summary Sections of Flight Operations andProcedure Manual (FOPM)
IV. Flight-time Checklist
• Check with on-site safety personnel for a safe flight area for first flight, • Record relevant metrics in flight log, • Check for groundhazards at home-base and rectify, • Confirm 

### >8 satellite GPS lock, • Confirm initial state ofcontrollers, • Initialize rotors and check for proper operation, • Perform controlled flight to hover mode approximately 5m above ground, • Checklanding gear flight mode (up) operation, • Perform controlled multi-axis roll procedure to check for proper orchestrated rotor operation, • Perform controlled multi-axis (ifapplicable) control procedure ofdata collection package, • Switch controller mode to radial based, check proper operation to maximum 5m distance to PIC and

return to initial position, • Return UAS to normal orientation, • Perform controlled flight to hover mode approximately lm above ground, • Checklanding gear landing mode (down) operation, • Land the UAS and check for proper de-initialization ofrotors, • Perform controlled flight to hover mode approximately 5m above ground, • Checklanding gear flight mode (up) operation, • Operate UAS to each waypoint 

### I position until maximum flight time is achieved, • Return UAS to normal orientation, • Perform controlled flight to hover mode approximately lm above ground, • Checklanding gear landing mode (down) operation, • Land the UAS and check for proper de-initialization ofrotors, • Remove power to the flight package, • Remove power to the data collection package, • Remove power to controllers, • Complete flight log.
V. Standing Procedures
• The Pilot, Spotter, and Technician will be the only MSAerial staffmembers in the forward flight area.

On-site personnel will be within verbal range and behind MSAerial staff. • The maximum power used to control the device is soft limited to 75% in order to maintain power in

reserve for unforeseen conditions, • Flighttime is limitedto 15 minutes and goals will be planned in phases to be accomplished duringthis

time. • Flight time is limited to reserving 25% batterypower, • Flight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 300ft,

whichever is less. • Flight time is limited to operation in safe environmental conditions, • Flight staffwill maintain proximity so as to be in clear and unaided verbal range, • The PIC will announce all movements to MSAerial and on-site staffso thatnon-PIC staffmembers can

identifypossible safety concerns before operation ofthe UAS to the next waypoint or position,

33 SEA AvE, QuiNCY, MA 02169-3135 MINDI@MSAERIAL.COM 

### + 1- ( 8 57)- 204-2448

### MS Photography/MS Aerial

Operations Area (Attached VFR Chart with Coordinates) 

## 41° 59' 13" N 

# I 70° 57' 54"

# wACORD® 

## CERTIFICATE OF AIRCRAFT INSURANCE 

# I DATE (MMIDDIYYYY)**~** 10/6/2014 THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATiVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER. IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATION IS WAIVED, subject to the terms and conditions ofthe policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu ofsuch endorsement(s). PRODUCER CONTACT Transport Risk NAME: Tranlfort Risk 1242**B~** Timber Drive, Suite 5**rA~gN~To.** Extl: 720.208.0844 

## IFAX (AIC No): 720.208.0845 E-MAIL Conifer, 0 80433 ADDRESS: PRODUCER 10 #:INSURER(S)**AFFORDit~G** COVERAGE % NAIC# INSURED INSURER A: StarNet Insurance Company 100 40045 MS Aerial and MS Photography 33 Sea Avenue INSURER B: Quincy MA 02169 INSURERC: INSURER D: INSURER E: INSURER F: THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. POLICY INFORMATION POLICY TYPE PLEASURE & BUS / AIRCRAFT INFORMATION

YEAR IMAKE 2014 DJI TERRITORY: AIRCRAFT COVERAGES CERTIFICATE NUMBER: 21910614

I MODEL ls1ooo AIRPLANE LIABILITY ONLY HELICOPTER HULL & LIABILITY

I SERIAL NUMBER TRM767 REVISION NUMBER:
QUOTA SHARE

I REGISTRATION NUMBER

N/A

INSURER LETTER I POLICY NUMBER A BA-14-05-0021 0 I EFFECTIVE DATE 

## I EXPIRATION DATE 5/21/2014 5/21/2015 ADDITIONAL INSURED? (YIN) 

## I SUBROGATION WAIVED? (YIN) y N COVERAGE OPTIONS LIMIT APPLIES TO LIMIT APPLIES TO $ $ AIRCRAFT HULL )- - $ 

### rL $ 1,000,000 EAOCC $ EA PER AIRCRAFT LIABILITY - $ EXCLUDED EA PASS $ AGGR INCLUDING CREW MEDICAL PAYMENTS 

# 7 EXCLUDING CREW $ 5,000 EAPER COVERAGE CODE DESCRIPTION OPTIONS LIMIT APPLIES TO LIMIT APPLIES TO $ $

- - $ $ $ $

- - $ $ $ $

- - $ $ DESCRIPTION OF OPERATIONS I REMARKS (Attach ACORD 101 Additional Remarks Schedule if more space is required) It is agreed that the Certificate Holder is included as an Additional Insured underthe Aircraft Liability Coverages, but only to the extent of liability vicariously imposed upon the Certificate Holder solely as the result ofan act or omission ofthe Named Insured or its employees in connection with the Named Insured's Aircraft operations, subject to all policy terms, conditions and exclusions. The Company has made the provision to give the Certificate Holder prompt notice ofcancellation of any policy above. But, the company assumes no responsibility for failure to provide such notice. This Certificate does not chanQe in any way the actual coverage provided by the policy. CERTIFICATE HOLDER CANCELLATION SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE**Brid~ewater** State University THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN 131 ummer Street ACCORDANCE WITH THE POLICY PROVISIONS. Bridgewater MA 02325 AUTHORIZED REPRESENTATIVE

Diane Beane

# ~- © 2009 ACORD CORPORATION. All nghts reserved. ACORD 21 (2009/12) The ACORD name and logo are registered marks of ACORD CERT NO.: 21910614 Diane Beane 10/6/2014 3:20:59 PM (PDT) Page 1 of 1EL-i t:.,T **~~~~~-,~-JMS** Photography

: !Melinda Sogoloski

**y--~-,--~----,** »= "w I 33 Sea Ave

. Quincy, 02169

**L-~--·-··-,··-~-~....;....~~·1**

DJl S1000 PREMIUM, A2 AND ZENMUSE 50

MKIII COMBO SN # 0200020888 ·······-·· ... ; .• , ......... ,

FUTABA 10JH 2.4G Heli R3008SB S/FHSS IFUTK9201

Mode 2 SN # 840313003 PLU15-160006 PULSE LIPO 16000mAh 6S1PIPLU15-160006

22.2V 15C $349.98 $0.00 SubTotal:

l '

" .•.••• +··· **····~~,··-··** .•. ) •... $349.98 $0.00

······ sz, **~~~~6** i ..

.. **~29?:??~-·-······** ..

# I Any information Is provided is bound by the Freedo.m of Information Act (FOIA) and may be releasable. This requires compliance to FOIA and consentto the release ofyour**infprmatio~.** l.f you do not consent to the release of your information, you must contact us for further guidance. For more Information,please visit http:f/www.foia.gov/.



## Information Contact Name 

### !Melinda Sokoloski Company**N~m~** 

### IMS Photography DBA MS Aerial StreetAddress 1 

### 133 Sea Ave StreetAddress 

### 2 City 

### louincy IMA Zip Code 

### ._10_2_16_9
_____ __. Phone Number 

### .1857-204-2448 E-mail Address 

### lmindi@msaerial.com 

## Ai Aircraft Type 

### IUAV Aircraft Registration 

### lsN 

### # o2ooo2o888 Characteristics Climb (Feet/Minute) 

### 1350 feet per minute Descent Rate (Feet/Minute) 

### 1250/350 per minute

# lao introversive and a 3°

### ~ Approach Speed 

# I maximum thrust of 2.!ij (Degrees/Second) Max 130-45 mph Min !Hover Speed Gross Launch/Recovery !Automated Return to 

# bJ

Location

Altitude Description of Operation Bridgewater State University ( 131 Summer Street, Bridgewater, MA 02324) Possibly other privately owned locations within the New England !200 Feet Distance from Town/City Melinda Sokoloski along with a pilot and an observer have been asked to film a few moments of B roll in a tightly controlled enviroment. On the Campus of Bridgewater State university. There will be a few days offilming. Projected filming for other companies would take place in similar conditions, meaning saftey and education would be on the forefront. This includes knowijng regulations and weather conditions. (Attach VFR Chart with Coordinates) 

# DA D 

# DD IZJ Airspace
Mode C Veil

Flight Conditions 

## IZJ VFR 

### DIFR 

## Air u Transmitter 

### DVHF 

# 0 0 No 

# D 8 (Requires FAA HQ approval) 

# oc DE D G (With an operational ATC Tower)

Receiver 

# 0 Yes 

## 0 No Guard (Emergency Frequency) 

## 0 Yes 

## 0 No D

# IZJ UHF



## ures

1. to (!) 

## 0 No Receiver (!)Yes 

### ONo

lmmeditely after line of sight may be compromised. There are 2 spotters at all times G 

### 3. link f I tell it to or the signal is dropped it will fly back to where it is told. I preprogram the altitude it ill Termination Never beyond line of sight and below 450'
Communication Procedures and Air Control Frequency) (!) 

# 0 No

LLAititude 

# 1450 feet


### 4. lost link Point Beyond line of sight. We do not fly beyond line of sight.

The MSPhotography/MS Aerial team would never be within in the range of airfields or restricted airspace. The coordinates are: 41 o 59' 25" N 

### I 70° 58' 32" W

and Observer Procedurally we would not allow an observer to be any farther than speaking distance. It can be said that fundamentally, the primary role ofthe observer is to maintain communication with the pilot as a first directive

..

### Line of Sight of 

# lZI D

Time Day 

### !Close enough to be within speaking distance. 

## ijj ® ® 

## 0 No 

## 0 N/A 

# 0 Night 

# 0 Both Mode


## .. D.

### CERTIFICATE OF LIABILITY INSURANCE 

# I DATE (MM/DDIYYYY) 1/20/2014 THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER. IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s). PRODUCER CONTACT Lockton Affinity, LLC NAME: P.O. Box 410679 PHONE 

# I 888-202-1526 liAX Kansas City, MO 64141-0679 (AIC No.Ext): (A/C,No):: E-MAIL ADDRESS: INSURER(S) AFFORDING COVERAGE NAIC INSURER·A: Certain Underwriters at Lloyd's, London INSURED INSURER-8: MS Photography INSURER·C: 33 Sea Ave INSURER-D: Quincy MA 02169 INSURER·E: INSURER·F: COVERAGES CERTIFICATE NUMBER: REVISION NUMBER: THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE SEEN REDUCED BY PAID CLAIMS. INSR TYPE OF INSURANCE ADDL SUBR POLICY NUMBER POLICY EFF POLICY EXP LIMITS LTR INSR WVD (MM/DD/YY) (MM/DD/YY) A GENERAL LIABILITY PP4003590 1/21/2014 1/21/2015 EACH OCCURRENCE $1,000,000 X COMMERCIAL GENERAL LIABILITY DAMAGE TO RENTED PREMISES $100,000 IXJoccuR (Ea occurrence) CLAIMS MADE MED EXP (Any one person) $5,000 PERSONAL & ADV INJURY $1,000,000 GENERALAGGREGATE $2,000,000 GEN'LAGGREGATE LIMIT APPLIES PER: PRODUCTS
- COMP/OP AGG $2,000,000

X POLICY 

# n PROJECT

# n LOC $ AUTOMOBILE LIABILITY COMBINED SINGLE LIMIT $ (Ea accident) ANY AUTO BODILY INJURY (Per person) $

- ALL OWNED AUTOS SCHEDULED AUTOS BODILY INJURY (Per accident) $



## - PROPERTY DAMAGE $ HIRED AUTOS NON-OWNED AUTOS (Per accident) 

# - UMBRELLA LIAS OCCUR EACH OCCURRENCE $



## - EXCESS LIAB CLAIMS MADE AGGREGATE $ OED 

## I I RETENTION $ WORKERS COMPENSATION**~~cmru-** 

# ;I OTHER AND EMPLOYERS' LIABILITY TORY LIMITS ANY PROPRIETOR/PARTNER/EXECUTIVE Y/N OFFICER/MEMBER EXCLUDED? E.L. EACH ACCIDENT $ (MANDATORY IN NH) E.L. DISEASE
- EA EMPLOYEE $ Ifyes, describe under DESCRIPTION OF OPERATIONS below E.L. DISEASE
- POLICY LIMIT $ Hired & Non-owned Auto Liability is included CERTIFICATE HOLDER CANCELLATION Proofof Coverage SHOULD ANY OFTHE ABOVE DESCRIBED POLIOES BE CANCELLED BEFORE THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS AUTHORIZED REPRESENTATIVE 

# ! B ;1**fk~-** ACORD 25 (2010/05) The ACORD name and logo are registered marks of ACORD