MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEWJERSEY AVE., SE WASHINGTON, DC 20590

**IN THE M AT** **TER OF THE PETITION FOR EXEMPTION OF:**



## MVTPRO INC.

**FOR A N EXEMPTION SEEKING RELIEF FROM**  **THE REQUIREMENTS OF THE FAA**  **REFORM A CT AND**  **PA RT 11 OF THE FEDER**  **AL A**  **VIA TION REGULA** 

**TI ONS FROM**  **TI TLE 14 OF THE CODE OF FEDERA** **L REGUL AT**  **IONS SECTIONS C.F.R.**  **§21, subpart H; C.F.R. §45.23 (b); §§ 61.113(a) & (b); 61.133(a); 91.7(a);**  **91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b)**  **CONCERNING COMMERCIA L OPERA**  **TION OF UNM AN**  **NED AIR** **CRA FT SYSTEMS**  **PURSUA NT TO SECTION 333 OF**  **THE F AA M**  **ODERNIZ AT** **ION AN**  **D REFORM A CT OF 2012 (PUBLIC L** **AW 112** **- 95)** 

Submitted	on February 15,	2016
MVT	PRO	INC. 3847	S.	Main	St. Santa	Ana,	CA	92707 George@mvtpro.comMVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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## I **NTRODUCTION AND INTERESTS OF THE APPLICANT** 

Dear	Sir	or	Madam:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, MVT Pro Inc., (“MVT”) Operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for the	commercial video industry	and offer	on

- demand	commercial	UAS operations	for a host of industries, hereby applies for an exemption from the listed Federal Aviation	Regulations (“FARs”)	to	allow	commercial	operation	of	its	sUASs,	so	long	as such operations are conducted within and under the conditions outlined herein or as	may	be	established	by	the	FAA	in	an	exemption	granted	under	either	Section	333

. As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUASs under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in the aerial filming and monitoring industry presently using conventional aircraft. Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace system.”	Section	333(c)	of	the	Reform	Act. 1

**Description of Type, Make and Models of sUAS s**  **Requeste d:**  The applicant is seeking an exemption to commercially operate sUASs make and modes	as	follows: DJI

- Phantom 3,	DJI

- Inspire	1
Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment. Equipment operation manuals for each sUASs are included for your reference	and	are	affixed	separately	in	these	documents labeled	Appendix.

1 MVT	relies	upon	the	following	exemptions	where	specific	reference	to	an	exemption	is	not	provided: Exemptions	11062	thru	11067,	11080,	11109	through	11112,	11114,	11213,	11062	and	as	recent	as	11857.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 3 **Commercial (Operation) Purpose:** This	exemption	request, once	granted	would	allow	the applicant to	operate	a	small unmanned	aerial	system	(UAS)	to	conduct,	photography	and	videography	of residential	and	commercial real	estate,	weddings,	filmmaking,	cinematography,	and aerial	video	and	photography	for	public	and	private	use	including	television,	public events,	and	cinematography	live	feed	and	live	newsgathering,	training	to	persons individually	or	belonging	to	both	private	and	public	organizations	to	increase awareness	and	improve	safety	for	current	and	future	UAS	operations	within	the NAS,	special	events:	including	high	schools,	colleges,	professional	sports,	open	air events	and	fairs,	disaster	and	catastrophe	events.

The	name	and	address	of	the	applicant	is:
MVTPro	Inc. George	Aurouth Phone :	714

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-9974 Email: George@mvtpro.com Address:	3847	S.	Main	St.,	Santa	Ana,	CA	92707



### Background The	applicant,	MVTPRO is	under	George	Aurouth’s	direction.	George	Aurouth	is known	as	an	experienced,	capable	and	trusted	professional	among the local	society. MVT	Pro	Inc.	(MVT)	is	award	winning,	professional	film,	video,	multimedia	and event Production	Company in	Orange	County,	CA	since	1984.	Company	has	served not	only local	community but	also	nation’s	leading	corporates	and	government	for last	30	years.	MVT	offers	a	wide	range	of	film,	video, multimedia	and	event production	services	such	as	video	production, postproduction,	live	show production, and corporate	event	productions.		As	demands of	clients	have	been increased	regarding	aerial	photography,	video	and film	recording,	in	order	to fulfill the	demands, applicant carefully planed	and decided	to operate	sUASs in upcoming	productions.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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### Regulations from which the exemption relief is requested:

14	C.F.R.	Part	21 14	C.F.R.	§	45.23(b) 14	C.F.R.	§	61.11 3	(a)	&	(b) 14	C.F.R.	§	61.133(a) 14	C.F.R.	§	91.7(a) 14	C.F.R.	§	91.9(b)	(2) 14	C.F.R.	§	91.103 14	C.F.R.	§	91.109 14	C.F.R.	§	91.119 14	C.F.R.	§	91.121 14	C.F.R.	§	91.151	(a) 14	C.F.R.	§	91.203	(a)	&	(b) 14	C.F.R.	§	91.405	(a) 14	C.F.R.	§	407	(a)	(1) 14 C.F.R.	§	409	(a)	(2) 14	C.F.R.	§	417	(a)	&	(b)

This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the National Airspace System (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national	security in	light	of	the	following:

 The	UAS’	size,	weight,	speed,	and	operational	capability;
 Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and
 Operation	of	the	UAS	within	visual	line	of	sight	of	the	Operator. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements	for	the	safe operation	of	such	aircraft	in	the	national	airspace	system.” Id.	§333(c)	(emphasis	added). 2 The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act that includes sUASs, from the

2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions	under	section333,	but	for	the	Administrator	to	craft	conditions	for	the	safe	operation	of	the	sUASs,	if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 5 requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1)

. This authority to grant exemptions reaches such issues as authorization of commercial operation of aircraft without an FAA issued pilot’s license.
MVT Pro Inc.’s sUASs are rotorcraft, weighting less than 55 lb. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate only in **line of**  **sight** and will operate only within the **sterile area**  described in the flight safety manual, attached as Appendix A (hereinafter “the Manual”). Such operations will insure that the sUASs will “not create	a	hazard	to	users	of	the	national	airspace	system	or	the	public.” 3
In addition, given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles of the geographic center of an airport as denoted on a current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained, MVT requests that operations over congested or densely populated	areas	be	allowed.	The	new	sUASs	do	have	GPS	geo

-fencing; it	will operate at a very low altitude, within confined areas. Such operations will only be under

-taken with the approval of the land or home owner, as set forth herein, and will comply with the requirements that operations be no closer than 500 feet to the adjacent building unless the land owner has provided permission, and the Operator has	made	a	safety	assessment	of	the	risk	from	such	operations.


### Operator Requirements
Given the sUASs proposed by MVT, Operators should not be required to hold a private pilot license. MVT believes that 1) the operator, instead of understanding how to operate a passenger carrying aircraft, should have knowledge and experience	that	enables	the	safe	operation	of	a small,	remotely	piloted	sUASs should understand airspace restrictions and know how to ensure separation from other aircraft	as	well	as	non

-participants	and	property;	2)	the	sUAS has	built

-in technical

______________________________________________
3 Reform	Act	Section	333	(b)MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 6 capabilities	that	limit	the	potential	for	unsafe	operation	and	3)	there	are	other security	screening	mechanisms	already	in	existence	that MVT will	utilize	to	ensure the	operators	are	acting	consistently	with	national	security	interests. Given the sUAS safety features outlined below, MVT proposes that its operations under this Exemption request should not be required to hold a commercial or private pilot certification. Instead, Operators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA

-recognized equivalents; have completed MVT’s training program by flight instructor for operation of the sUASs. MVT notes that 1) the FAA has found that safety factors permitted operation of sUASs by Operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present; and 2) that the Notice of Proposed Rulemaking entitled Operation and Certification	of	Small	Unmanned	Aircraft	Systems,	80	F.R.	9544	(February 23, 2015) (“NPRM”), does not require the operator to hold a private pilot license or a third class	medical.
See Federal Aviation Administration, Notice N

-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013); As the FAA has determined in	Exemptions	11062	thru	11067,11080	and	11110	(the “Exemptions”), in comparing the requirements for private pilot knowledge and the knowledge required for a commercial pilot, that knowledge associated with a private pilot license, and therefore private pilot ground school, was sufficient to allow private pilots	to	operate	sUASs	under	those	exemptions. Based upon that analysis, MVT believes successful completion of FAA private pilot ground school is a suitable predicate to operating the sUASs under this exemption. DPS proposes that the Operator accumulate required sUASs flight training hours through the operation of sUASs rather than flight hours in conventional aircraft. Those	hours	are	more	relevant	to	the	operations	proposed	herein	than	hours	gained in obtaining a private pilot’s certificate in conventional or rotor aircraft. Those aircraft are orders of magnitude heavier than the sUASs and carry not only the pilot himself, but also passengers and fuel, none of which is carried in the sUASs. These conventional aircraft fly over all sorts of airspace without the permission or knowledge	of	the	landowner.
A handheld radio controller controls the sUASs and the vehicle is operated within the line of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to the extent they are relevant to UAS operations, can be taught in the training proposed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 55 pound aircraft, operating at less than 30 mph during filming operations are those taught in ground school and in flight training with theMVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 7 particular UAS and not gained from accumulating flight hours in a fixed wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take offs	and	landings	at	controlled	and	uncontrolled	airports.
As to national security review of pilots, each of MVT’ pilots/operators will obtain internally provided certified training (Ground and Practical) from MVT to operate the sUASs

. This review and certification could reasonably vet the Operators against any	known	terrorist	or	no	fly	listings	that	are	relevant	and	publically	available.
MVT additionally asks that the exemption be issued without the requirement for a visual observer. As set forth herein, an equivalent level of safety is provided by the size, speed and control capabilities of the aircraft, as well as the operational procedures that	will	be	applicable	to	all	flight	hereunder.	These	obviate	the	need	for the	visual	observer. The Operator will be operating the aircraft, always within line of sight. He or she will walk and follow the aircraft around the inspection area so that while it is flying its pre-programed and at times, manual flight path, the UAS will always be directly in	his	or	her	line	of	sight.	The	Operator	will	not	be	distracted	by	viewing	the	pictures that taken during the flight. Rather, once the sUAS is launched, the Operator’s only duty will be to watch the flight of the UAS over the structure and intervene to address flight path deviations or other issues that arise during the flight. The functions that an observer performs where the aircraft is flown at long distances from the launch area will not be necessary as the Operator will always have the aircraft in his or her direct sight. The observer also will not be necessary because the Operator will conduct a pre-flight inspection of the area, will and if needed, cordon off the area and will perform frequent visual scans of the area while the vehicle	is	operating.
MVT again	notes	that	the	NPRM	does	not	require	the	use	of	a	visual	observer.	Given the clear direction in Section 333 of the Reform Act; the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered sUASs for these functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots having at least a private pilot license,	the	grant	of	the	requested	exemptions	is	in	the	public	interest. 4

4 Should the FAA determine that it cannot grant such an exemption for operations without a FAA licensed private pilot, despite the showing made herein, under the statutory authority the FAA already has, DPS will operate its aircraft with pilots holding at least a private pilot certificate issued by the FAA. In that event, DPS requests that the exemption be granted with conditions similar to those contained in numbered paragraphs 14

- 15	in	Exemption	11136MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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### Aircraft and Equivalent Level of Safety

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe commercial video filming operations conducted with conventional aircraft or with humans climbing up and around	structures. These	limitations	and	conditions	to	which	MVT	(referred	to	as	“Operator”)	agrees	to be bound when conducting commercial operations under an FAA issued exemption include:

1) Operations authorized by this grant of exemption are limited to

the	aircraft described in	the	Operator’s manual,	which	is	a	multi

rotor weighing less than 55 pounds: Proposed operations of any other aircraft will require a new application or a application to amend	this	grant. 2) Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve	should	that	occur	prior	to	the	20	minute	limit. 3) The sUASs may not be flown at an indicated airspeed exceeding 30	mph	(10	mph	during inspections). 4) The sUASs must be operated at an altitude of no more than 400 feet above ground level (AGL), or not more than 200 feet above an elevated platform from which filming is planned

. All altitudes reported	to	ATC	must	be	in	feet	AGL. 5) Minimum crew for each operation will be consisted of the sUAS pilot,	the	visual	observer,	and	the	camera	operator. 6) Pilot and observer will have been trained in operation of sUASs generally and received latest information on the particular sUASs	to	be	operated	as	required. 7) Pilot and observer will be able to communicate by voice during the	operation	of	sUAS.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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8) The sUASs must be operated within visual line of sight (VLOS) of the Aircraft Operator at all times. This requires the Aircraft Operator to be able to use human vision unaided by any device other	than	corrective	lenses. 9) The	Exemption	Holder’s	Manuals	must	be	amended	to	include	all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon	request.	If	a discrepancy	exists	between	the	conditions	and limitations in the exemption and the procedures outlined in the Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Operator must follow the procedures as outlined in its Aircraft’s manual. The Exemption Holder may update or revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The Exemption Holder must also present updated and revised documents if it petitions for an extension or amendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder must petition	for	amendment	to	its	exemption. 10) Prior to each flight, the Aircraft Operator must inspect	the sUASs to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft is prohibited from operating until the necessary maintenance has	been	performed, and the sUAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations	must	be	properly	documented	in	the	aircraft	records. 11) Any sUASs that has undergone maintenance or alterations that affect the sUASs operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight in accordance with the Exemption holder’s Manuals. The Aircraft Operator who conducts the functional test flight must make an entry in the sUASs aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Exemption Holder’s	Operator’s	manual. 12) The Exemption Holder must follow the manufacturer’s sUASs aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attentionMVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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to flight critical components that may not be addressed in the manufacturer’s	manuals. 13) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours,	description	of	work	accomplished,	and	the	signature of	the	authorized	technician	returning	the	UAS	to	service. 14) The authorized technicians must receive and document training referenced	in	the	Exemption	Holder’s	Manuals. 15) Each UAS operated under this exemption must comply with all manufacturer	System	and	Safety	Bulletins. 16) The Exemption Holder’s maintenance personnel must make a record	entry	in the sUASs logbook or	equivalent	document	of	the corrective action taken against discrepancies discovered between	inspections. 17) Prior	to	commencing	operations,	the	Aircraft	Operator	shall	have logged at least 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a sUASs pilot with a similar sUASs type	and	5	hours	in	the	make	and	model. 18) If the sUASs lose communications or lose its GPS signal, the sUASs must return to a pre-determined location within the private or controlled

-access property and land or be recovered in	accordance	with	the	Exemption	Holder’s	Manuals. 19) The Aircraft Operator must abort the flight in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption	Holder’s	Manuals. 20) The	Aircraft	Operator	is	prohibited	from	beginning	a sUASs flight unless	(considering	wind	and	forecast	weather conditions)	there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. 21) All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large	as	practicable.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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22) Before conducting operations, the radio frequency spectrum used for operation and control of the sUASs must comply with the Federal Communications Commission (FCC) or other appropriate	government	oversight	agency	requirements. 23) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator at the Ground Control Station of the sUASs any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official	upon	request. 24) The sUASs must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultra

-light vehicles, parachute activities, parasailing	activities,	hang	gliders,	etc.). 25) The Operator who is in any moving device or vehicle may not operate	the	sUASs

. 26) sUASs operations may not be conducted during night, as defined in	14	CFR	1.1. 27) All operations must be conducted under visual meteorological conditions (VMC). The sUASs may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when	visibility	is	less	than 2 statute	miles	from	the	Operator. 28) During operations the sUASs may not operate within 5 nautical miles of the geographic center of an airport as denoted on a current FAA

-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required	by	the	Operator’s	COA.	The	letter	of	agreement	with	the airport management must be made available to the Administrator	upon	request. 29) The sUASs may not be operated over congested or densely populated	areas	unless	the	conditions	set	for	in	# 30 are	satisfied. These populated areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). H owever, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d) (1).MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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30) Flight operations must be conducted at least 200 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. The Aircraft Operator must ensure that nonparticipating	persons	remain	under	such	protection.	If	a situation arises where nonparticipating persons leave such protection and are within 30 feet of the sUASs, flight operations	must	cease	immediately	and/or; b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of	the	risk	of	operating	closer	to	those	objects	and;

c. Operations near the Aircraft Operator do not present an undue	hazard	to	the	Operator	per	§	91.119(a). 31) All operations shall be conducted over private or controlled

access	property	with	permission	from	the	land	owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for	each	flight	to	be	conducted. 32) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS

-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per	instructions	contained	on	the	NTSB	Web	site: www.ntsb.gov

.

**14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F. R**  **§91.203 (a)	(1)**  Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safely under part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of theMVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 13 particular sUASs. In all cases, an analysis of these criteria demonstrates that the sUASs operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate	without	the	restrictions	and	conditions	proposed. The sUASs to	be	operated	hereunder	is	less	than	55	lbs.	fully	loaded,	carries	neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operation under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already	apply	to civil	aircraft	operated	in	connection	with	motion	picture	and television production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUASs, due to its size, speed of operation, location of operation, lack of explosive materials	or	flammable	liquid	fuels,	and	inability	to	carry	a	substantial	external	load.

**14	C.F.R.	§	45.23	(b) :**  **Marking	of	the	Aircraft**
The	regulation	requires: When	marks	include	only	the	Roman	capital	letter	“N”	and	the	registration number	is	displayed on	limited,	restricted	or	light

-sport	category	aircraft	or experimental	or	provisionally	certificated	aircraft,	the	operator	must	also	display on	that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters not	less	than	2	inches	no	more	than	6	inches	high,	the	words	“limited,” “restricted,”	“light

-sport,”	“experimental,”	or	“provisional,”	as	applicable. Even	though	the	sUASs	will	have	no	airworthiness	certificate,	an	exemption	may	be needed	as	the	sUASs	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on which the word “Experimental”	can	be	placed.	Given	the	size	of	the	sUASs,	two

-inch lettering	will	be impossible.	The	word	“Experimental”	will	be	placed	on	the	fuselage in	compliance	with §45.29	(f). The	equivalent	level	of	safety	will	be	provided	by	having	the	sUASs	marked	on	its fuselage	as	required	by §45.29	(f)	where	the	pilot,	observer	and	others	working with	the	sUASs	will	see	the	identification	of	the	sUASs	as	“Experimental.”	The	FAA has	issued	the	following	exemptions	to	this	regulation	to	Exemptions	Nos.	10700, 8738,	10167	and	10167A.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 14 **14	C.F.R.	§	61.113(a)	&	(b):	Private	Pilot	Privileges	and	Limitations :**  **Pilot	in Command** 
**.** Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the MVT’ sUASs are remotely controlled with no passengers or property of others on board. Section 61.1 3 3(a) requires an individual with a commercial pilot’s license to be pilot in command	of	an	aircraft	for	compensation	or	hire.
MVT respectfully proposes	that	Operator	requirements	should	take	into	account	the characteristics of the particular sUAS. MVT’s sUASs have a high degree of preprogrammed control and various built
-in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application. The MVT’s sUASs has navigation and control system comprised of a Ground Control Station (GCS) and auto
-pilot system that can be preprogrammed to set operational boundaries. All flights are pre-programmed with precision GPS guidance. In the case of unplanned events, the Operator may input pre-programmed evasive maneuvers from the control unit, and the onboard autopilot executes those maneuvers. Pre

-programmed Operator interventions include initiation of holding at present position; suspension of mission; fly back to launch	point;	abort	mission	and	land	immediately;	and	emergency	power	cut	off	and land	(Flight Termination	System).

Additional automated safety functions and safety enhancing features of the MVT’s sUASs	may	include	the	following:
1.1. Autopilot detection of lost GPS or of insufficient satellites initiates an immediate	landing. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%	levels.	Low	power	below	10%	triggers	an	immediate	landing. 1.3. If the autopilot detects a lost

-link to the ground controller, the UAS will hold position	at	its	current	location	for	5	seconds	and if the	signal	is	not restored,	execute	a	return	to	home	and	land. 1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un-commanded deviation	from	the	flight	path. 1.5.	The	aircraft,	weighs	less	than	55	lbs.,	fully	loaded. 1.6. The motors are driven by pulse width modulated signals, not analog signals. 1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) and no more than above 200 feet above the structure (imaging	altitude)	or	a	maximum	of	400	AGL.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 15 Given these safety features, MVT proposes that Operators of the MVT’s sUASs should	not	be	required	to	hold	a	commercial	or	private	pilot	certification. Instead, Operators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA

-recognized equivalents; have completed the manufacturer’s	or MVT’s training	program	for operation	of	the	UAS.
MVT notes that the FAA has found that safety factors permitted operation of UASs by Operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above were present. See, Federal Aviation Administration, Notice N

-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013). Likewise, MVT notes that the NPRM does not require that the Operator hold a private pilot license issued by the FAA.
Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the DPS’ sUAS without a private pilot’s certificate or	a	commercial	pilot’s	certificate,	under	the	conditions	set	forth	herein. The risks associated with the operation of the MVT’s sUASs (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUASs as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level	of	requiring	a	commercial	pilot	to	operate	the	aircraft	under	§	61.133(a).

**14 C.F.R. § 91.7(a): Civil aircraft airworthiness.**
This 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 that the	Operator	has	agreed	to	as	it	relates	to	airworthiness,	as	contained	in	the	manual, an equivalent level of safety will be achieved by insuring compliance with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations	in	Exemptions	11062	through	11067,	11080	and	11110.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 16 **14	C.F.R. §	91.** **9 (** **b )**  **(2) :	Civil**  **Aircraft	Flight	Manual	in	the	Aircraft.** Section	91.9	(b)	(2)	provides: No	person	may	operate	a	U.S.

-registered	civil	aircraft	... (2)	For	which	an	Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by §21.5	of this	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 configuration	has	no	ability	or	place	to	carry	such	a flight	manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft. The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	manual	at	the ground	control	point	where	the	operator 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,	1 0167,	10167A,	10602,	32827, and	10700.
**14	C.F.R. §	91** **.103:	Preflight	action** This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight to	insure	the	safety	of	flight.	As	FAA	approved	rotorcraft	flight	manuals	will	not	be provided	for	the	aircraft	an	exemption	will	be	needed.	An	equivalent	level	of	safety will	be	provided	as	set	forth	in	the	Manual.	The	PIC	will	take	all	actions	including reviewing	weather,	flight	battery	requirements,	landing	and	takeoff	distances	and aircraft	performance	data	before	initiation	of	flight.
**14	C.F.R. §	91** **.109:	Flight	instr uction:**  Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has fully	functioning	dual	controls.

sUASs	and	remotely	piloted	aircraft,	by	their design	do	not	have	fully	functional dual	controls.	Flight	control	is	accomplished	through	the	use	of	a	control	box	that communicates	with	the	aircraft	via	radio	communications.	The	FAA	has	approved exemptions	for	flight	training	without fully	functional	dual	controls	for	a	number	of aircraft	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	speed	of	the	aircraft. Safe	simulation	and	practice	flight	will	be	carried	out	in	controlled	environments. All	simulations	will	be	carried	out	on	a	computer	using	the	drone	controls.	Any practice	flying	will	take	place	in	a	safe	environment,	with	no	risk	to	human	lifeMVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 17 below.
**14 C.F.R. §91.119: Minimum safe altitudes**
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein the sUASs	will	never	operate	at	higher	than	400 AGL. The equivalent level of safety will be achieved given the size, weight, and speed of the	sUASs	as	well	as	the	location	where	it	is	operated.	No flight	will	be	taken	without the permission of the property owner, facility owner, and/or local officials. Because of	the	advance	notice	to	the	property	owner	and	participants,	all	affected	individuals will be	aware	of	the	planned	flight operations	as	set forth	in	the	Manuals.	Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low

-altitude operations of the sUASs will ensure separation	between these small

-UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062	through	11067,	11080	and	11110.
**14 C.F.R. §91.121 Altimeter Settings**
This regulation 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	MVT’s sUASs, in manual or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of safety. The FAA has granted exemptions to conduct similar	operations	in	Exemptions	11062	through	11067,	11080	and	11110.
**14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**
Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assumingMVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 18 normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or	(2)	At	night,	to	fly	after	that	for	at	least	45	minutes.” The battery powering the sUAS provides approximately 25 minutes of powered flight. To meet the 30

-minute reserve requirement in 14 CFR §91.151, sUAS flights would	be	limited	to	approximately 20 minutes	in	length.	Given	the	limitations	on	the UAS’ proposed flight area and the location of its proposed operations within a predetermined	area,	a	longer	time	frame	for	flight	is	reasonable. Applicant believes that an	exemption	from	14 CFR	§91.151(a) falls within	the	scope of prior exemptions. See Exemption 1 0673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). 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 of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the sUASs. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the exemption will	be	granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 2 0 minutes or 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUASs to its planned landing	zone	from	anywhere	in	its	limited	operating	area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, through11067, 11080 and 11110.

**14	C.F.R. §	91** **.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and Registration**  The	regulation	provides	in	pertinent	part: (a) Except	as	provided	in §91.715,	no	person	may	operate	a	civil	aircraft unless	it	has	within	it	the	following: (1) An	appropriate	and	current	airworthiness	certificate... (b) No	person	may	operate	a	civil	aircraft	unless	the	airworthiness certificate	required	by	paragraph	(a)	of	this	section	or	a	special	flight authorization	issued	under §91.715	is	displayed	at	the	cabin	or	cockpit entrance	so	that	it	is	legible	to	passengers	or	crew. The	sUAS	fully	loaded	weights	no	more	than	55	lbs.	and	is	operated	without	an onboard	pilot.	As	such,	there	is	no	ability	or	place	to	carry	certification and registration	documents	or	to	display	them	on	the	sUAS.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 19 As	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the ground	control	point	where	the	operator	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	of	other	exceptions	includes Exemption	Nos.	9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.
**14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections**  These regulations require that an aircraft Operator or owner “shall have that aircraft inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain	the	aircraft	in	compliance	with	Part	43.
Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating handbook as referenced in the Manuals attached as confidential Exhibits An equivalent level of safety will be achieved because these sUASs are very limited in size and will carry a small payload and operate only in defined areas for limited periods of time. If mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed

. In addition, the Operator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for	similar	operations	in	Exemptions	11062	through	11067,	11080	and	11110.

**Privacy	and	National	Security** All	flights	will	occur	over	private	or	controlled	access	property	with	the	property owner’s	prior	consent	and	knowledge.	Inspection	will	be	of	inanimate	objects	in areas	where	the	owners	will	have	consented	to	the	inspections	or	otherwise	have agreed	to	allow	the	sUASs	and	the	Operator	to	be	in	the	area	where	operations	will take	place. The	size	of	the	sUASs,	its	speed	and	restricted	area	of	operation	do	not	raise national	security	issues.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 20 **Federal	Register	Publication** Pursuant to 14 C.F.R. Part 1 1, the following summary is provided for publication in the	Federal	Register,	should	it	be	determined	that	publication	is	needed: Applicant seeks	an	exemption	from	the	following	rules:
14 C.F.R. §21, subpart H; 14 C.F.R. §45.23 (b); §§ 61.113(a) & (b); 61.133(a); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a)(1);	91.409(a)(2)	and	91.417	(a)	&	(b)	to	operate	commercially a small unmanned aircraft system (55 lbs. or less) for aerial video and photography for public and private use including television, public events, cinematography, live feed	and	live	newsgathering

. Approval	of	exemptions	allowing	commercial	operations	of	sUASs	in	the	Film	and TV	production	industry	will	enhance	safety	by	reducing	risk.	Conventional operations,	using	jet	or	piston	powered	aircraft,	ladders	or	placing	people	on	roofs or	tall,	hazardous	structures,	exposes	them	to	higher	risk	than	those	created	by	use of	a	sUASs.	Instead	of	carrying	large	amounts	of	jet A, other fuel	or	heavy	load	of equipment in	the	neighborhood,	sUAS	is	less	than	55	lbs.	and	powered	by	batteries which	eliminates	virtually	all	of	that	risk	given	the	conventional operation to producing	media. The	operation	of	small	sUASs conducted	in	the	strict conditions	outlined	above,	will provide	an	equivalent	level	of	safety	supporting	the	grant	of	the	exemptions requested	herein,	including	exempting	the	applicant	from	the	requirements	of	Part 21	and	allowing	commercial	operations.	These	lightweight	aircraft operate	at	slow speeds,	close	to	the	ground,	and	in	a	sterile	environment	and,	as	a	result,	are	far safer	than	conventional	operations	conducted	with	turbine	helicopters	operating	in close	proximity	to	the	ground	and	people. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

–size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUASs in the commercial video production industry	pursuant	to	the	Manual	appended	hereto

. Sincerely, George	Ayrouth MVT	Pro	Inc. 3847	S.	Main	St. Santa	Ana,	CA	92707 2/ 15/2016MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 21 **Appendix: A:	No	Fly	Zone**  **B:	Safety	Manual C:**  **Make	and	Models	of sUASs**  **D:	Flight	Log/	10hour	Maintenance	and	repair	Log E**  **:	User	Manual	of	sUASs**



## Appendix	A:	No
**- Fly	Zone** 
**Operator s**  **of	MVT	Pro	Inc. will	not	operat** **e sUASs**  **within	5	nautical	miles	of any**  **airport s** **.** As a safety precaution, pilots of MVT Pro Inc. will not operate within 5 nautical miles of any airports similar to the permission granted in Exemption No. 11153

- Regulatory Docket No. FAA20140519, page 25, “20.	The	UA	may	not	operate	within	5 nautical miles of an airport reference point as denoted on a current FAA

-published aeronautical chart unless a letter of agreement with that airports management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operators COA. The letter of agreement with the airport management must be made	available	to	the	Administrator	upon	request. ” As	well	as	in	Exemption	No.	11195

– Regulatory	Docket	No.	FAA20140884,	page	12,

“19. The UA may not operate within 5 nautical miles o f an airport reference point as denoted on a current FAA

-published aeronautical chart unless a letter of agreement with that airport management is obtained, and the operation is conducted in accordance	with	a	Notice	to	Airmen	(NOTAM),	as	required	by	the operators	Certificate of Waiver or Authorization (COA). The letter of agreement with the airport management	must	be	made	available	to	the	Administrator	upon	request. ”
MVT Pro Inc. requests the same flexibility as exemptions 11153 and 11195 for acquiring agreement with the airports’ management should operations fall within 5 nautical	miles	of	an	airport.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 22



## Appendix	B:	Safety	Manual

a) Maintenance 1) A	factory

-trained	technician	must	inspect	the	sUASs	every 10	hours flight

. All maintenance records will be maintained for inspection as set forth in Section	B. 2) If any maintenance is undergone, the sUASs must pass a flight test with both	a	pilot	and	manufacturer	trained	technician	before	flight. b) Recording	Keeping 1) A digital record will be kept for all flights, flight times, and maintenance records. c) Securing	Flight	Site 1) FSDO	Submissions The sUASs operators 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. 2) Safety	Parameter Before filming occurs, a 100

-yard perimeter from the planned flight path will be identified in order to set a “Sterile” environment for the operation of	sUASs. i)	MVT	Pro	Inc.	must	obtain	written	or	oral	permission	from	all landowners	in	sterile	environment. ii)	48	hours	before	filming,	all	residents	or	businesses	within	100	yards of	the	filming	will	be	notified	with	printed	flyers	that	contain	date	of flight,	time	of	flight,	and	contact	information. iii)	Streets	and	sidewalks	that	cross	into	the	sterile	environment	will	be marked	with	“Warning

-Low	Flying	Aircraft

-Stay	Back	200ft” 3) Identify	Potential	Obstacles Before each flight, an inventory will be taken for all potential hazardous obstacles that must be avoided while in flight which are: Nearest Airport or helipad which must be at least 5 nautical miles far from flight site, Power lines, Cell phone tower, Trees, Birds, Heavily traveled roadways, Utility	wires,	Elevated	Structures.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 23 d) Pre

-Flight	Checklist 1) Precision	Calibration	of onboard GPS	System The sUASs have onboard GPS systems that are required to be calibrated satellites	signals	to	pinpoint	its	exact	location before	every	flight. 2) Take	Off	Location/	Home	Point The sUASs will mark its take off location as “Home point” that a safe area to return when the sUAS lose signal with the control or if the pilot signals the	sUASs	to	return	to	its	“Home	point”	location. i) Take off location will be in an area with a 25ft radius with no obstructions,	maintaining	safe	radius	vertically	200ft. ii) The	sUASs	will	take	off	and	land	in	the	same	location. iii) GPS	Altimeter	will	be	marked	as	0’	elevation. 3) Flight	Canceling	Events All Flights will be cancelled for minimum of 2 hours if any of the below occurs: i) Police	activity	in	the	area ii) Medical/News	Helicopters	active	in	the	area iii) Wind	exceeding	10	mph iv) Low	flying	aircraft	in	the	area v) Any emergency requiring emergency services occurs within the	sterile	environment vi) PIC is unable to complete flight without losing visual of the sUASs vii) Heavy	bird	presence	in	the	area	that	could	cause	bird	strike viii) Any	defects	or	damage	found	during	preflight exam 4) Physical	Inspection Before each flight the sUASs will be checked to ensure that it is safe for flight. i) Battery voltage will be checked to ensure it is more than

85% ii) Blades will be inspected to ensure they are tightened and free	of	damages iii) Camera gimbal will be inspected to ensure it is fully attached	and	operating iv) sUASs will be checked for any Damage that may have taken place	in	transit v) The sUASs will be tested at a low altitude to ensure all controls	are	responding	correctly If any party of the inspecting shows a damaged part or parts, the sUAS is grounded and deemed non-usable and must be inspected by a factory trained	technician.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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-9974 Page 24 5) Post	Flight	Inspections/	Checklist After each flight, the sUASs will be thoroughly inspected fro any damages that may	occur	in	flight. i) Body	inspected	for	any	damage ii) Blades	visually	checked	for	any	damages iii) Battery	checked	for	damage e) Flight	Safety	Protocol 1) Max	Speed

i) Accent:	10m/s ii) Decent:			4m/s iii) Flight	Speed:	Never	exceed	10m/s 2) Altitude The	sUASs	are	never	exceeding	350ft 3) Emergency If it appears that the sUASs, any property or humans are at risk, the sUASs	will	be	grounded	immediately	to	a	safe	location. 4) Sight The	operator	must	keep	the	sUASs	within	eyesight	at	all	times
f) Participation	by	non

-pilot	staff All staff	involved	in	the	production or filming	using	the	sUASs	will	consent	to maintain	a	safe	distance	of	at	least	30ft	during	the	filming. g) Pilot/	Observer	Training Before flight, both the operator and observer will receive updated information	on	the	sUASs and	its	firmware. 1) The controller allows for a simulation of flight, both the operator and observer are allowed	to	run	through	the	simulator	training.MVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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## Appendix	C:	Make	and	Model	of	sUASs

sUAS	#1:	DJI Model: Phantom	III	Professional

See	Appendix	D	for	User	Manual

sUAS	#2:	DJI M odel:	Inspire	1

See	Appendix	D	for	User	ManualMVT	Pro	Inc.	3847	S.	Main	St.	Santa	Ana,	CA	92707

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### Appendix	D:	Flight	Log/	10	Hour	Maintenance	and	Repair	log Applicant submits the Appendix marked “CONFIDENTIAL,” as they contain proprietary confidential business inf ormation that is not released to the public and is protected under the	Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section	333	(b).

Summited Copy	of	Log Separately