Jeffrey & Adele Scholl

172 Lidstrom Rd.

Whitefish, MT 59937

c: 406-253-9048

f: 866-333-4157

adele@gravityshots.com

5/20/2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir or Madam:

This Addendum to our first submission includes additional information marked in red from the original 

document.

I. GravityShots.com, Inc. seeks exemption from the following sections of 14 C.F.R.:

• 14 C.F.R. Part 21- Airworthiness and Certificate

• 14 C.F.R. Part 45.23 (b) - Identification and Registration Marking

• 14 C.F.R. Part 91.7 (a) - Airworthiness

• 14 C.F.R Part 91.9 (b)(2) - Flight Manual

• 14 C.F.R. Part 91.103 - Preflight Action

• 14 C.F. R Part 91.109 (a) - Flight Instruction

• 14 C.F.R. Part 91.119 - Minimum Safe Altitudes

• 14 C.F.R. Part 91.121 - Altimeter Settings

• 14 C.F.R. Part 91.151 (a) - Fuel Requirements in VFR Conditions

• 14 C.F.R. Part 91.203 (a) & (b) - Certifications and Registration

• 14 C.F.R. Part 91.405 (a), 407 (a)(1), 409 (a)(1) & (2), 417 (a) & (b) - Maintenance 

Inspections

GravityShots.com, Inc. seeks relief on the above sections of 14 C.F.R. for use of their sUAVs in the film 

industry, TV productions, real estate photography & video, surveying for development, agriculture 

inspection, aerial mapping.
II. Granting GravityShots.com, Inc. an exemption will greatly benefit the public for a number of 

reasons: 

• Advocating safety as a top priority and share safety concerns when flying. 

1. Learn to fly on hobby grade equipment first. Putting many hours into learning 

the orientations and performance of the equipment.

2. Once you have gained hours you can advance to a smaller UAV. 

3. Always create a pre-flight check list and follow the FAA regulations set in place, 

do not fly above 400 feet, do not fly in restricted air space, within 5 miles of an 

airport

4. Always have an observer with your pilot, to help create a safe environment for 

the sUAV and pilot. As the observer you can help educate the public. By asking 

them to stay back from the sUAV, do not allow the public to talk to the pilot 

while they are flying, making sure there is a safe take off and landing place free 

and clear of obstacles.

5. Always keep your sUAV in visual line of sight.

6. Always perform maintenance on your sUAV and check the validity. Make sure 

all equipment has been charged before each flight.

7. Respect and maintain public privacy. 

8. Never fly over people or crowds.

9. Never fly under the influence of alcohol or other substances.

10. Never fly near or around power lines.

11. Never fly in high winds or bad weather.

• Litigation of risk - GravityShots.com, Inc., has an operational check list that is followed 

each time of flight. Jeffrey Sholl, the chief pilot follows these procedures and checks 

each sUAV before use.

• Provide professional education to the public.

• Use of sUAVs verses full scale helicopters provide a safer environment for filming. 

• Provide economic growth for the public by allowing the public to hire GravityShots.com, 

Inc. 

• Create a positive environment for sUAVs as whole. By creating breathtaking aerial 

imagery the public is drawn to our content. 

III. The exemption would not adversely affect safety, in fact it would create a safe environment and 

example of a professional operation adhering to the FAA standards that are currently set in place.

Pilot & Company Background with years of experience and hours in full scale aircrafts & sUAVs:

Jeffrey Scholl started flying remote controlled aircrafts at an early age. He continued his passion for 

flying and received his full scale pilot's license at the age of 17. He attended University of North Dakota 
and obtained a degree in Aerospace and Computer Science, as well as a commercial instrument rating . 

(See Appendix 1. for a digital copy)

In 1999, Jeffrey Scholl created GravityShots.com and was registered with the state of Montana. (See 

Apendix 2.) In early 2000, Jeffrey started building and flying RC helicopters, single rotor. He built and 

mastered gas and electric machines. He would compete on the national level in 3D flying with the gas 

powered helicopters. Around this same time, he started GravityShots.com, Inc. and started taking 

photographs from the air. Attached is one of his first systems that he designed and a photo of him flying 

it.
This photo shows Jeffrey Scholl with a gas powered helicopter in 2002.

2005 GravityShots.com, Inc. acquired Commercial Liability Insurance, with Evanston Insurance 

Company. (See Appendix 3. for a digital copy) No claims have been made with 10 years of liability 

coverage. Currently in 2015, their policy is held with Seneca Insurance Liability Insurance: Aerial PakTM 

Insurance Policy 2015. (See Appendix 4. for a digital copy)

This policy offers Comprehensive General Liability Coverage:

Protects you from claims arising out of bodily injuries to the general public, or from 

damage to the property of others.

Protection extends up to your policy limits. Included is coverage for premises-operations 

and products-completed operations.

Limits of $500,000 per occurrence/ $1,000,000 aggregate are standard; $1,000,000 per 

occurrence / $2,000,000 aggregate is also available.
Standard General Liability policies will exclude damage arising from the operation of 

aircraft; Aerial PakTM includes coverage for Remote Controlled Aerial Photography 

equipment provided the maximum payload does not exceed 25 pounds and the aircrafts 

engine delivers under eight (8) horsepower. 

Note: Aerial PakTM is intended to provide coverage for bodily injury and property damage 

claims arising from the operation of approved equipment. The policy contains an 

exclusion "personal injury" and "advertising injury" coverage. This coverage may be 

available for an additional premium, through a separate policy.

In November of 2010, Jeffrey started flying and building multi-rotor platforms. Together with his wife, 

Adele as the observer, they gathered hours of safely flying these platforms. 

Jeffrey's skills as a full scale and RC pilot are unique with many years of experience. From the first time 

that he took the sticks with his single rotor RC helicopters, he has learned to fly all crafts in manual 

mode. Not relying on GPS guidance or way point flying. He believes that you must learn to master the 

craft, before you can use these automated features, as they are not always reliable. 

Through constant research and development Jeffrey Scholl stays on top of updates and advancements in 

technology.

IV. GravityShots.com operates sUAVs, that are qualified under an FAA issued exemption. 

• sUAVs weigh under 55 pounds.

• All operations are conducted in line of sight

• sUAVs will not travel above 400 feet in elevation

• Flight times are under 15 minutes, using a voice telemetry system to relay battery levels 

of the sUAV and transmitter back to Pilot In Command

• Always operating with a Pilot In Command and Observer

• Pilot In Command holds a private pilot license

• The sUAV when filming on a closed set will operate in a designated area

• Before the sUAV is in flight a pre-flight briefing will occur with everyone on set

• All operations will be documented with a monthly COA.

• Pilot and Observer have years of training and experience flying these systems.

• Pilot and Observer operate in close proximity to each other, verbal communication is a 

must.

• Operations as never conducted over private property without consent of the land 

owner. GravityShots.com, Inc. respects land owners privacy.

• GravityShots.com keeps safety as a first priority, allowing for aborted missions if the 

environment is not completely secure and safe.

• All operations are conducted outside of a 5 mile radius from any restricted air space.

• Flight operations will not be above 50 mph 
Current sUAV Aircraft Systems that GravityShots.com, Inc. operates, qualify for approval:

1. FreeFly CineStar 8

(See Attached Appendix 5. CineStar 8 Manual & Appedix 7. for The Flight Electronics Manuals)

First Flight 3/28/2014 - Total Flight Time: 61182 secs / 1019.42 min / 16:59:42 (132 files/flights)

The CineStar is the next evolution in professional heavy lift multi-rotor helicopters. Drawing on vast 

experience in the areas of professional aerial cinematography, engineering and manufacturing, 

Quadrocopter and FreeFly Systems have collaborated to create the ultimate aerial platform. Extensive 

R&D has been invested in the CineStar to create a reliable and robust system for aerial video and photo 

professionals, allowing for longer flight times, heavier payloads and smoother footage.

Technical Properties:

• Weight Including Motors: ~3050g (6.72 lbs)

• Dimensions: 1000 x 900 x 350mm

• Max Payload: ~5445g (12 lbs)

• Construction: Gen 2 Carbon Fiber

• Propeller: Tiger Carbon 15x5 MR

• Tiger 4012 Brushless Motors

• MikroKopter GPS way point flying electronics

• Quadrocopter Edition of Dual Sky XM5010 

• QuadroPower 10,000mAh (6s) Lipo w/ EC5 Connector Battery (Allowing 10 minute flights)

• CineStar Build Guide DVD 

2. FreeFly CineStar 6

(See Attached Appendix 6. CineStar 6 Manual & Appedix 7. for The Flight Electronics Manuals)

First flight 1/8/14 -Total Flight Time: 132329 secs / 2205.29 min / 1.12:45:29 (333 files/flights)
The CineStar 6 is the smaller version of the CineStar 8 with 6 motors.

Technical Properties:

• Weight Including Motors: ~2595g (5.72 lbs)

• Dimensions: 1000 x 900 x 350mm

• Max Payload: ~3628g (8 lbs)

• Construction: Gen 2 Carbon Fiber

• Propeller: Dual Sky Propeller Set & Motors

• MikroKopter GPS way point flying electronics

• Quadrocopter Edition of Dual Sky XM5010 

• QuadroPower 10,000mAh (6s) Lipo w/ EC5 Connector Battery (Allowing 10 minute flights)

• CineStar Build Guide DVD 

3. DJI Inspire 1 (See Attached Appendix 8. & 9. Manual and Safety Guidelines)

DJI’s most advanced technology comes together in the Inspire 1, an easy to use, all-in-one flying 

platform that empowers you to create the unforgettable. Never before has such power been put into a 

ready-to-fly system that anyone can fly.

Technical Properties:

• Professional DJI flight control system

• 3-axis gimbal stabilized 4K camera

• HD wireless video transmission
• Full remote camera control capability

• App controlled manual camera settings

• GPS-free indoor stabilization

• Allowing 10 minute flights

V. GravityShots.com, Inc. Safety Policies in place, that insure the litigation of risk are as follows:

Before starting

• Check the reliability of the Multi-Rotor.

• The flight battery and transmitter battery must be fully charged.

• Always turn on the transmitter first and then the Multi-Rotor.

• Watch for visible damage such as loose screws, broken, unbalanced or damaged propellers, 

faulty connectors or solder joints, broken pipes, etc.

• The propeller must be in a good condition and securely mounted. The rotors must spin 

smoothly. Please ensure that there are no objects are in the rotational plane of the propellers or 

within a distance that poses a risk of obstruction. Rotating propeller ends are dangerous to 

touch - never touch a rotating propeller with fingers or other body parts.

• Ensure the appropriate to the audible beeps when auto lipo-detection is enabled. 6 * beep 

means 6s Lipo

• Ensure that the selected channel on the remote control is free and that you're within range of 

the transmitter.
• Ensure the sensors are calibrated (when the motors are off move yaw and gas stick into upper 

left corner until it beeps).

• Different settings can result in fundamentally different flight characteristics and occupation of 

the Channel functions. Make sure that you are familiar with the setting and its features.

• After starting the motors, check that all motors are running and rotate evenly. Please fly 

carefully at a low altitude until you know that everything is working fine.

• Perform a pre-flight check (see checklist below).

• Start manually - switch off altitude control and GPS.

Checklist (pre-flight check)

• Weather conditions are suitable.

• Frame and all screws are tight.

• Propeller not damaged and tightly fixed.

• Battery fully charged and securely mounted.

• Transmitter battery charged and the antennas are free.

• Channel of the transmitter is not busy. If 35/40/70MHz or other MHz-RC-controls are in 

operation simultaneously, the used channels must be checked with the other pilots (not 

necessary for 2.4 GHz systems).

• Check RC(TX/RX) operation range (on the ground!) from time to time (and before 1st flight).

• Ensure there is nothing in the danger zone of the propeller.

• Ensure enough space for launch and flight.

• Ensure the GPS module (if any) has GPS fix. If CH or PH is active it will beep every second. Check 

that when you switch to GPS mode, there will be an audible beep.

• For manual start ensure GPS and altitude controls are turned off.

• Ensure sensors are calibrated and that the right setting is loaded.

• Ensure the trim of the remote control is in neutral position.

During the flight

• Do not take risks! Your own safety and that of your environment depend on the good behavior 

of the pilot. Always maintain a safe distance from people, animals and objects. Improper 

operation can cause serious injury and property damage! Never fly towards viewers and avoid 

flying over spectators.

• Keep in mind that viewers could get close to the Multi-Rotor, without being aware of potential 

dangers.

• Always turn off the Multi-Rotor first and disconnect the flight battery before turning off the 

transmitter.

• Only fly in line of sight. In the case of manual control, you must be able to see the position and 

altitude. Never fly over 500 feet.

• Never rely 100% on functions such as GPS, compass, or altitude control. You must always be 

able to take manual control of the Multi-Rotor.

• Reduce the throttle or switch off the motors in case of a crash or failure.

• Do not fly in restricted air space, such as in the vicinity of airports, etc.

• Pay attention to under-voltage warning -flying on an empty battery can cause damage to the 

Lipos.

• If a defect or malfunction has occurred, it must be corrected before the next start.

• When using GPS, take note that the position of the Multi-Rotor can change suddenly.
After the flight

• Disconnect the battery and check all over for damage. Make sure that there is no damage to the 

propellers.

• Provide safe handling and safety precautions of Lipo batteries.

• If the Multi-Rotor is involved in a crash or hard landing , everything must be checked before the 

next flight.

Policies set in place for closed set filming. Creating a safer environment in the film industry than the 

use of full scale helicopters in filming. 

• Pre-flight plan - Discussion with all members on the closed filming set a flight path and plan of 

all members involved in filming. Discussion of safety and making sure everyone on set follows 

the proposed plan. 

• Keeping safe distances from all the talent and crew.

• Having an emergency plan set in place.

• Always taking the time to run through the above checklists.

VI. Similar granted petitions are as follows: 

• 2/18/2015 Picture Factory, Inc. (Docket ID:FAA-2014-0794), 

• 2/13/2015 Capital Aerial Video, LLC. (Docket ID:FAA-2014-0844), 

• 2/10/2015 Blue-Chip UAS (Docket ID:FAA-2014-0787), 

• 2/3/2015 Helinet Aviation Services, LLC. (Docket ID:FAA-2014-0785), 

• 2/3/2015 Alan D. Purwin, 1/29/2015 Slugwear, bda Likeona Tree (Docket ID:FAA-2014-

0786), 

• 1/29/2015 Team 5 (Docket ID:FAA-2014-0783), 

• 1/29/2015 Shotover (Docket ID:FAA-2014-0784), 

• 1/23/2015 AeroCine (Docket ID:FAA-2014-0400), 

• 1/23/2015 Burnz Eye View (Docket ID:FAA-2014-0519), 

• 1/6/2015 Douglas Trudeau (Docket ID:FAA-2014-0481),

• 12/10/2014 Clayco (Docket ID:FAA-2014-0507), 

• 10/10/2014 Flying Cam (Docket ID:FAA-2014-0355), 

• 9/25/2014 Astraeus Aerial (Docket ID:FAA-2014-0352), 

• 9/25/2014 Aerial MOB (Docket ID:FAA-2014-0353), 

• 9/25/2014 Pictorvision (Docket ID:FAA-2014-0357), 

• 9/25/2014 HeliVideo Productions (Docket ID:FAA-2014-0354),

• 9/25/2014 Snaproll Media (Docket ID:FAA-2014-0358),

• 9/25/2014 RC Pro Productions Consulting, dba Vortex Aerial (Docket ID:FAA-2014-0356).

VII. In Summary, GravityShots.com, Inc. with its pilot and observer seek exemption from the following 

regulations: 14 C.F.R. Part 21, 14 C.F.R. Part 45.23 (b), 14 C.F.R. Part 91.7 (a), 14 C.F.R Part 91.9 (b)(2), 

14 C.F.R. Part 91.103, 14 C.F. R Part 91.109 (a), 14 C.F.R. Part 91.119, 14 C.F.R. Part 91.121, 14 C.F.R., 

Part 91.151 (a), 14 C.F.R. Part 91.203 (a) & (b) , 14 C.F.R. Part 91.405 (a), 407 (a)(1), 409 (a)(1) & (2), 
417 (a) & (b), to commercially operate their sUAVs, weighing under 55 pounds, in a safe manor, away 

from populated areas, or restricted airspace, keeping the sUAV in visual line of sight, providing public 

awareness and safety. GravityShots.com, Inc. experience with full scale aircraft operations, guides 

their operations with sUAVs following awareness of airspace, as well as respecting privacy and will 

not operate without consent of private land owners. 

If granted the exemption from the FAA Gravityshots.com, Inc. will continue to abide by the FAA 

regulations and policies set in place. If granted the exemption GravityShots.com will submit a Certificate 

of Waiver or Authorization (COA) on a monthly basis for commercial jobs are performed . Commercial 

operations would include but are not limited to, aerial footage for the film industry, TV productions, real 

estate, surveying for development, agriculture inspection, aerial mapping.

Sincerely,

Adele Scholl

Jeffrey Scholl

GravityShots.com, Inc.

172 Lidstrom Rd.

Whitefish, MT 59937

adele@gravityshots.com

Appendix Table of Contents:

1. United State of America - FAA Commercial Pilot License - Attachment1_JeffPilotLicense.jpg

2. June 16, 1999 GravityShots.com business registration with the state of Montana - Attachment2_

GravityShotsBusiness.jpg

3. 2005 GravityShots.com Proof of Liability Insurance - Evanston Insurance Company -

Attachment3_CommercialLiability2005.pdf

4. 2015 GravityShots.com Proof of Liability Insurance - Seneca Specialty Insurance Company: 

Attachment4a_GRAVI-1 PROOF.pdf, Attachment4b_GravityShotsPolicy.pdf

5. FreeFly CineStar 8 Manual - Attachment5_cinestar8Manual-v3.pdf

6. FreeFly CineStar 6 Manual - Attachment6_cinestar6Manual-v8.pdf

7. Mikrokopter Electronics Manual - See Link http://www.mkmanual.com/
8. DJI Inspire 1 User Manual V1.0 - Attachment8_Inspire_1_User_Manual_v1.0_en.pdf

9. DJI Inspire 1 Safety Guidelines v1.0 - Attachment9_Inspire_1_Safety_Guidelines_en.pdf

10. Copy of NNumbers from the FAA - Attachment10_NNumbers.jpg

11. Copy of FAA Aircraft registration documentation: AC Form 8050-1 -

Attachment11a_8050-1_Inspire1.jpg

Attachment11b_8050-1_Cinestar6.jpg

Attachment11c_8050-1_Cinestar8.jpg

12. Copy of Affidavit of Ownership For Amateur-Built Aircraft: AC Form 8050-88 -

Attachment12a_8050-88_Inspire1.jpg

Attachment12b_8050-88_Cinestar6.jpg

Attachment12c_8050-88_Cinestar8.jpg

13. Copy of Aircraft Bill of Sale: AC Form 8050-2 -

Attachment13a_8050-2_Inspire1.jpg

Attachment13b_8050-2_Cinestar6.jpg

Attachment13c_8050-2_Cinstar8.jpg

14. Copy of the USPS receipt of the mailed FAA Aircraft registration docuements on 3/11/2015 -

Attachment14_USPSFAA.jpg