Pictures From The Sky, LLC

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September 2nd , 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12

- 140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS)

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam:

On b ehalf of Pictures From The Sky, LLC

. , and Pursu ant to Section 333 of the FAA Modernization and

Reform Act of 2012 and 14 C.F.R. Part 11, I Louise Michaud, Owner am seeking an exemption from Part

21 Subpart H ; and Sections 91.203 (a) (1)

, 45.23 (b) , 91.7 (a), 91.9, 61.113, 61.133, 91.109, 91.119,

91.1 21 , 91.151, and (91.401

- 91.417 ) Subpart E, of Title 14, Code of Federal Regulations (14 CFR). This

proposed exemption would allow for the operation of our unmanned aircraft (UA) : The DJI Inspire 1

, and

Freefly Alta

.

THE UNMANNED AIRCRAFT (UA):

 The UA’s are lightweight (under 55l b. gross weight), battery operated multi Rotor copter s that

take off and land vertically and have the ability to hover in one location during flight.

THE UA INCLUDES:

 An on

- board flight computer with GPS navigation and location ability that receives signals for

flight controls from a ground

- based transmitter/controller;

 An on

- board camera capable of capturing imagery in the form of full color, high definition still

photos and video

 An on

- board telemetry system that d elivers flight data from the on

- board flight computer to the

on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass

direction of flight and direction back to its launch site

 On

- board radio transmitter that transmits live video from the on

- board camera plus all the flight

data from the telemetry system described above

THE GROUND STATION PART OF THE SYSTEM:

 A Pilot in Command (PIC) I n operati onal control of a mission from beginning to end, and who

controls the UA while in t he air

 A radio transmitter/controller operated by the PIC to control the UA while in flight

 Ground Station (computer, tablet for smart phone based app) which receives and displays video

and system telemetry real time from the UA

 A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA

while in flight.Pictures From The Sky, LLC

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PILOT IN COMMAND (PIC) AND VISUAL OBSERVER:

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel

Qualifications. Additionally, the PIC and VO will per form maintenance on the system and will complete a

course of maintenance instruction as part of their initial training.

I submit that the combination of the UA’s light weight, flight performance and ability, fully qualified

flight c rew and strict operation under the guidelines established in 8900.227, and under all of the

Restrictions listed above, the FAA can have full confidence that the operation wil l have an equivalent or

greater level of safety than manned aircraft performing th e same mission.

INTENDED USE :

The requested exemption would allow us to use the UA for aerial image acquisition to support various

mapping and surveying applications as well as video documentation for the public good. Typical

applications would include, b ut are not limited to:

 Inspection Services

 Aerial Photography

 Real Estate Photography

 Videography

 Aerial Mapping

 Volumetric Surveys

 Agricultural Inspection

 Closed Set film making *

PUBLIC INTEREST :

The inherent ability of the UA to capture imagery from a low altitude including oblique photos and video

from several angles is far more effective than ground

- based imagery for displaying the characteristics of

buildings, sites and properties or areas wher e consistent monitoring is needed. In addition the ability to

provide these services at a much lower cost than chartering a fixed wing aircraft or helicopters make this

service much more affordable to my client base. The reduced cost and higher quality da ta from the UA

is beneficial to the public in many applications including: real estate photography, accident or crime

scene investigation, search and rescue, terrain mapping to delineate flood prone areas, and the

preservation of historic buildings or arch eological sites where access is limited due to the sensitive

nature of the site

PUBLIC SAFETY :

UA’s, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel; they operate at lower altitud es (under 400’) with no people on board

thereby reducing current risk levels and enhancing public safety. With a small payload and maximum

flight time of approximately 30 minutes , UA’s offer little or no risk to national security.Pictures From The Sky, LLC

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SUMMARY GRANT REQUEST :

This request follows many others using similar systems and process tha t have been granted previously. I

am requesting the FAA issue a summary grant of exemption, as this request would not set a precedent

.

 The requested relief is identical to exemptions recently granted by the FAA; Exemption Nos.

11624, 12026, 12366 and 12369

 The requested relief (specific to Closed Set film making) is identical to exemptions granted

previously, specifically, Exemption(s) Nos. 11062 (Astraeus Aerial), 11066 (Aerial MOB), 11065

(Helivideo), and others.

 A grant of exemption would be in the public interest.

THE REGULATIONS FROM WHICH THE EXEMPTION S ARE BEING REQUESTED

Beside each regulation number is the page of the attached Adde ndum upon which each may be found

together with a proposed equivalent level of safety for each regulation:

- 14 CFR Part 21 Subpart H Addendum Page 1

- 14 CFR 91.203 (a) (1) Addendum Page 1

- 14 C F R 45.23 (b) Addendum Page 1

- 14 CFR 91.7 (a) Addendum Page 2

- 14 CFR 91.9 Addendum Page 2

- 14 CFR 61.113, 61.133 Addendum Page 2

- 14 C F R 91.109, 91.119, 91.12 1 Addendum Page 3

- 14 CFR 91.151 Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417) Addendum Page 4

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4

I am p r e p a r e d to m odi f y o r a mend a n y p a rt of t his r e qu e st t o satis f y t h e n ee d for a n e quival e nt lev e l of

s a f e t y

. P le a se c onta c t us a t a n y t i me if y ou r e quire a ddi t ional info r mation or c la r ifi c a t i on. I am the

primary point of contact for this request and look fo r w a rd to w o r ki n g with y o ur o f f ic e

.

S inc e r e l y

,

Louise Michaud, Owner

Pictures From The Sky, LLC

. 222 Derby Street

Salem, MA 01970

Phone: 978

- 375

- 5507

Email: louise @picturesfromthesky.com

Add e ndum C ont a in i n g Ex e mp t ion R e qu e sts a nd Equiv a lent L e v e l of S a f e t y

App e ndix A

– F l i g ht Operations/Procedures

App e ndix B

– User ’ s Man ua l sPictures From The Sky, LLC

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EXE M P TION RE Q UE S TS A N D EQUI V AL E NT L EVEL OF S A F ETY

I

, Louise Michaud, Owner of Pictures From The Sky, LLC

. , r e qu e st a n e x e mp t ion f r om t he f ol l owing

re g u l a t i ons a s w e ll a s a n y a ddi t ional r e g ulations that m a y t e c hnic a l l y a pp l y t o the op e r a t i on s of the

DJI Inspire 1, and Freefly Alta

.

14 C.F.R. Part 21, Subpart H: Airwo rthiness Certificates 14 C.F.R. 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedura l requirements for the issuance

of airworthiness certific ates as required by FAR 91.203( a) (1).

Given the size and limited operating area associated with the UA to be utilized by the Petitioner, an

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part

11 and Secti on 333 of the FMRA. The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of the

FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate,

upon consideration of the size, weight, speed, operational capabi lity, and proximity to airports and

populated areas of the particular UA. In all cases, an analysis of these criteria demonstrates that the UA

operated without an airworthiness certificate, in the restricted environment and under the conditions

proposed wi ll 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 UA to

be operated hereunder is less than 55 lbs. fully loaded, is by definition unmanned and carries neither a

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a limited flight area. Unlike other civil aircraft, operations under this exemption will be tightly

co ntrolled and monitored by the Operator and will also remain within the requirements of, and in

compliance with, local public safety requirements. These safety enhancements, which already apply to

civil aircraft provide a greater degree of safety to the pub lic 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 UA 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 on ly the Roman capital letter "N" and the registration

number is displayed on limited, res tricted or light

- sport category aircraft or experimental or

provisionally certificated a ircraft, the operator must also display on that aircraft near ea ch entrance to

the cabin, cockpit, or pilot stat ion, in letters not less than 2 inches nor more than 6 in ches high, the

words "limited," "restricted," "light

- sport," "experimental," o r "provisional," as applicable.

Even though the UA will have no airwort hiness certificate, an exemption may be needed as the UA will

have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed.

Given the size of the UA, two

- inch lettering will be impossible. The word "Experimental" w ill be placed

on the fuselage in compliance with 45.29 (f). The equivalent level of safety will be provided by havingPictures From The Sky, LLC

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the UA marked on its fuselage as required by 45.29 (f) where the pilot, observer and others working

with the UA will see the identificatio n of the UA as "Experimental."

The FAA has issued the following e xemptions to this regulation to Exemptions Nos. 10700, 8738, 10167

and 10167 A.

14 C.F.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 de termining airworthiness. Given the size of the aircraft and the

requirements contained herein for the use of safety check lists prior to each flight, an equivalent level of

safety will be provided.

14 C F R 91.9 Civil air c r a f t f l ig h t m a nu al, m a r k i n g, a n d p laca r d re qu ir e m e n ts.

This r e g u l a t i on p r ovides that no p e rson m a y op e ra te a n a ir c r a ft unless a c u r r e nt, app r o v e d fli g h t

manu a l i s in t he a ir c r a ft. We a ssu m e that the intent of this r e quir e ment is to ensu r e that fl i g ht manu a l

i n f o r mation i s a v a i l a ble to the a ir c r e w while op e r a t i n g the a i r c r a ft. We re qu e st an e x e mp t ion t o th i s

r e quir e ment sin c e the a i r c r a ft is not on l y too small t o ca r r y do c u m e ntation; t he do c ument a t i on would

not be a v a i l a ble to the c rew during f l i g ht ope r a t i on s

.

To obtain a n e quival e nt l e v e l of s a f e t y a nd m e e t t he in t e nt of 91.9, we pr o pose that a c u r r e nt,

a ppro ve d U

A F l i g ht Operations/Procedures ( App e ndix A) must be a v a i l a ble to the c rew a t the g rou n d

station a n y t i me the a ir c r a ft is i n, or p re p a ring fo r

, f l i g ht.

T he FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738,

9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C F R 61.113 P r iva t e p i l ot p r iv i leg e s a n d l i m ita t io n s: P i l ot in C o m m a n d a n d 61.133 C o m m e rc ial p i l ot

p r iv i l e g e s a n d l i m ita t io n s.

The r e g ulation provid e s t h a t no pe r son th a t ho l ds a p riv a te pilot ce rtif i ca te m a y ac t as pilot i n

c om m a nd of a n a i r c r a ft f or c ompens a t i on or h i r e

. S ubp a ra g r a ph (b) a l l ows a priv a te pilot to a c t a s pilot

in command of a n a ir c r a ft in c onn e c t i on with a n y busin e ss or e m p l o y ment if: (1) T h e fli g ht i s on l y

inci d e ntal to t h a t bus i n e ss or e mp l o y ment; and ( 2) The a ir c r a f t does not c a r r y p a sse n g e rs o r p r op e r t y

f o r c ompens a t i on or hi r e

.

Our pro p osed o p e r a t i ons r e quire that the P I C must e i t h e r

1. Hold a Private or Sport Pilot C e rtifi ca te is s u e d b y the F AA, a nd h a ve l o g g e d 10 hou r s of f l i g ht

e x p e ri e n c e in t his t y

p e of U A , or

2. M ee t t he re qui r e ments of 8900.227 p a ra 16 ( c ) ( 2 ) ( c ) " Op e r a t i ons without a pi l ot c e rtifi ca t e " in

which the P I C is r e qu i r e d to complete " F AA p r ivate pi l ot g round ins t ruct i on" a nd p a ss " the

F AA P riv a te P i lot w ritten e x a m i n a t i on." S ince the r e a r e c u r r e nt l y no me a ns a va i l a ble for the

pilot of a U

A to g a in t he e

x p e ri e n c e in a n e quival e nt c a t e g o r y a nd c lass in ord e r to a pp l y f o r a

private p i l ot '

s l i ce nse, we pro p ose to g e n e r a te a n e quiva l e n t l e v e l of s a f e t y b y r e quiri n g ourPictures From The Sky, LLC

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p i l ots t o c omp l e te, a t a min i mu m

, F AA private pi l ot ground ins t ru c t i on a nd p a ss t he F AA

Private P i l ot w r i t ten e x a m i n a t i on in add i t i on to c omp l e t i ng the p r i v a te p i lot re quir e ments.

S ince t he a ir c r a

ft c a nnot c a r r y p a sse n g e rs o r p r op e r t y , we f e e l that we me e t t he in t e nt of

61.113 S ubp a ra g r a ph ( b ) e v e n tho u gh the intent of th i s ap p l i ca t i on is to c ondu c t a business.

14 C F R 91.109 F l i g h t I n st r u c tion; S i m u lat e d i n st r u me n t f l i g h t and c e r tain f l i g h t te sts

The r e g ulation stat e s that " No p e rson m a y op e r a te a c iv i l air c r a ft th a t i s be i ng used for f l i g ht

instru c t i on unless that a ir c r a ft h a s ful l y fun c t i oning du a l c ontrols."

The UA’s g roun d

- b a s e d c ontrol station c o nsi s ts of a small h a nd

- h e l d r a dio t r a nsm i t t e r a nd while it does

not of f e r a se c ond s e t of " c ontro l s " , both t he student a nd i nstru c tor ca n, a nd wil l , op e r a te the si n g le s e t

of c ontrols si m ul t a n e ous l y

. W i t h both student a nd instru c tor h a ving " h a nds

- o n " the c ontrols d u r ing

f l i g ht, we f

e e l t h a t t his t ec hnique m ee ts t he i ntent 91.109 a nd p r ovides a n e quiva l e nt le v e l of s a f e t y

.

14 C F R 91.119 M i n i m u m sa f e altitu d e s: G e ner al.

The re g ulation stat e s that ov e r sp a r s e l y popu l a ted a r e a s t h e a ir c r a ft ca nnot be op e r a t e d c loser than

500 fee t t o a n y p e r s on, v e ssel, v e hicl e , or st r u c tur e

. S ince the a ir c r a ft will be op e r a t i n g a t a ma x i m um

of 4 00 fee t A G L

, we c a nnot comp l y w i t h th i s r e quir e m e nt.

I n o rd e r to pr o vi d e a n e q uival e nt l e v e l of s a f e t y The UA ’s will not be op e r a ted ov e r c ong e sted a r e a s o r

ov e r a n y o p e n a ir a ssemb l y o f p e rsons with out prior approval. Any property owner affected w i l l be

b r i e f e d on the e x

p ec ted r oute of flight a nd the a ssoci a ted risks to p e rsons a n d p r op e r t y on the g roun d

. The a ir c r a ft will be o p e rated a t a low a l t i t ude a l l o win g , if a pow e r unit f

a i l s, an e me r g e n c y land i ng

without undue h a z a rd to pe r sons or p r op e r t y on the su r f a c e . Th e r e

f o re we maintain t h a t due to the

sm a ll si z e of the UA, the h a z a rd to p e rsons, v e hicl e s and stru c tur e s is m i ni m a l comp a r e d to mann e d

a ir c ra ft, whi c h should be c ons i d e r e d in g r a nt i ng the e x e mp t ion.

14 C F R 91.121 A lt i m e ter S e t ting s

.

The r e g ulation r e quir e s t h a t air c r a ft sh a ll mainta i n c ruising a l t i t ud e s b y r e f e r e n c e to an a l t i m e ter

s e t t ing a v a i l a b l e with i n 100 NM of the a i r c raft.

The UA will a lw a y

s f l y b e low 4 00 fee t A G L a nd will n o t ne e d to m a in t a in c r uis i ng a l t i t ud e s in o r d e r to

p re v e nt c onfli c t with other a ir c r a ft. An A bove G r ound L e v e l a l t i m e ter me a s u r e ment a bove the t a k e o f f

point is t r a nsm i t t e d via ra dio f r o m t he UA’S on

- bo a rd c o m puter to t he disp la y s c r e e n h e ld b y the P I C,

p rovi d ing a c onst a n t l y up d a ted A G L r ea dout.

14 C F R 91.151 F u e l r e q u ir eme n ts f or f l i g h t in VFR c o nd itio n s.

The r e g ulation provid e s t h a t no pe r son m a y b e g in a f l i g ht i n a n a irpl a ne u n d e r d a y

- V F R c ondi t ions

unless the r e is enou g h fu e l t o f l y to t he fi r st po i nt of in t e nd e d la n ding a nd to f l y a ft e r that f or a t l ea st

30 m i nutes.

The in t e nt i on of th i

s pa r a g r a ph is to provi d e a n e n e r g y r e s e r v e a s a s a f e t y buf f e r f o r d e l a y s to l a ndi n g

. Each U A is batt e r y op e r a ted a nd the m a x i m um dur a t i on o

f f l i g ht f rom a sin g l e b a t t e r y c h ar g e is 18

m i nutes with a 20% re s e rv e

. S ince the a i r c raft will n e v e r f l y mo r e than 3/4NM f

r om t he point ofPictures From The Sky, LLC

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intend e d landi n g

, a f ull b a t t e r y c h ar g e a t l a un c h will e nsure that w e me e t the re s e r v e e n e r g y

r e qui r e ment of th i

s pa r a g ra ph. W

e re qu e st a n e x e mp t ion t o the w o r d "fu e l " a nd a sk for a n e quival e nt

in t e rp re tation wi t h the w o r d "en e r g y ".

14 C F R S ubp a r t E ( 9 1.401

- 91.417)

- M ai n t e n a n ce , P re v e n tive M ai nt e n a n ce , Alt e r a t io n s

The r e g ulation provid e s t h a t t he op e r a t o r is p r i m a r i l y re spons i ble f o r maintaining the a ir c r a ft in a n

a irwo r t h y c ondi t ion, i n c lud i ng c omp l ia n c e wi t h p a rt 39 a nd 43. P a ra g r a phs 91.407 a nd

91.409 re quire that the a i r c raft be " a ppro v e d for return to se r vice b y a p e rs o n a uthori z e d und e r

43.7" a ft e r m a in t e n a n c e a nd insp ec t i on.

I t i s our intention t h a t t he P I C p e r fo r m m a in t e n a n c e a nd inspe c t i on of the a i r c raft a nd " be a uthori z e d to

app r ove the a i r c r a

ft f or r e turn to se r v ic e ." As p r ovided in the P r e

- F l i g ht C h ec kl i st in App e ndix A, the P I C

will e nsure that the a i r c raft is i n a n a irwo r t h y c on d i t ion prior to e v e r y fli g ht and in addit i on c o n du c t

det a i l e d insp ec t i ons a

ft e r e v e r y two ho u rs of f l i g ht. Mainten a n c e p e r

f o r med b y t h e P I C is l i m i t e d to

r e p a iring small c r a c ks, r e pl a c ing a p r o p e l l e r, c h ec ki n g e le c tri c a l conn e c t i ons a nd upd a t i ng soft w a re a nd

f irmw a re f

o r the on

- b o a rd c ompu t e r. All o t h e r mainten a n c e will be p e r f o r med b y t h e m a nu

f ac tu r e r or

their d e si g n a ted r e p a ir f

a c i l i t y . The P I C will do c ument wo r k p e r f o r med in acc o rd a n c e wi t h 91.417. We

fee l t h a t d ue to t he si

z e

, c onstru c t i on, a nd simp l ici t y of the a i r c r a ft, the P IC ca n e nsure a n e quiva l e nt

l e v e l of sa fe t y

.

8900.227 P a r ag r a p h 16( c ) ( 4) P I C Me d ical. And P a r a g r a p h 16( e ) ( 1 ) Ob s er v e r Me d ical.

This po l i c y pro v ides that both t he P I C a nd VO m u st have a v a l i d F AA s e c o n d

- c lass medi ca l ce rtifi c a te

issued und e r p a rt 67 in ord e r to pe r f o r m a s a pilot or o b s e rver.

The UA’s ma x i m um g ross w e i g ht are each less than 8l bs., are constru c ted primarily of, plastic and

carbon fiber. T

he P I C is not on boa r d. B oth t he P I C a nd the V O a re r e quir e d to be in V LO S . Giv e n t h e

unl i k e l y e v e nt t h a t bo t h the P I C a nd VO b ec ome m e dic a l l y in c a p ac i t a ted while the a ir c r a ft is i n fli g ht,

t he UA will re turn a utono m o us l y to t he si t e of laun c h i ng a nd l a nd without c r e w in t e rv e nt i on. Th e r e f o r e

,

r e quiri n g the P I C a nd VO to me e t t he s a me m e d i ca l r e quir e m e nts a s commercial pilot carrying

passengers in a l a r g e a i r c r a ft is a n u nn ece ss a r y burd e n.

W e pro p ose th a t t he m i ni m um m e dic a l r e quir e m e nts for the P I C a nd VO b e vis i on c o r re c ted to

20/20 and a v a l i d, st a te i s sued d r ive r '

s l i ce n s e . The 20/20 v i

sion r e quir e me n t wi l l ensu r e that the P I C

and VO ca n see and avoid air traffic; a licensed driver is medically qualified to operate a much larger

vehicle.Pictures From The Sky, LLC

. – APPENDIX A

– FLIGHT OPERATIONS AN D PROCEDURES AP P E N DIX A

– F LIG H T OPERATIONS/PROCEDURES

The UA ’s will be operated under th e following flight restrictions.

OPERATIONAL F L I G HT RE S TRI C T I ONS

The UA will be operated in the field with both a PIC and a VO in accordance with and with the following

Restrictions:

 All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of

no more than 25 knots and no further than 3/4 NM from the PIC;

 All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate

by voice at all times during a flig ht operation;

 The PIC must have accumulated and logged, in a manner consistent with 14 CFR §

 61.51 (b), 10 hours of total time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot

with a similar UA type;

 The UA will not be operated over dense ly populate d areas; without prior approval

 The UA will not be operated over any open

- air assembly of people; without prior approval

 The UA will not be operated within 5 NM of an airport or h eliport; without prior approval

 Operations will be restricted to day only and weathe r conditions equivalent to VFR

 The PIC will brief the VO and property owner about the operation and risk before operation

 No flight will be made without a Pre

- Flight Inspection by the PIC before each operation to

ascertain that the UA i s in a condition safe for flight

P RE

- F L I G HT CHECKLI S T

Prior to operation preflight checklists provided by the manufacturer of the UA’s will be followed. Below

is such an example.

1. Remote Controller, battery, Range Extender and Viewing device are fully charged.

2. Propellers are mounted correctly.

3. Damping absorbers are in good condition, not broken or worn.

4. Camera lens cap has been removed.

5. Micro

- SD card has been inserted if necessary.

6. Gimbal is functioning as normal.

7. Motors can start and are functioning as normal.

8. Sensor connection is established

.Pictures From The Sky, LLC

. – APPENDIX A

– FLIGHT OPERATIONS AN D PROCEDURES

TAKE OFF/LANDING PROCEDURES

Manufacturer recommended Takeoff and Landi ng procedures will be followed.

Place the UA on ground with the battery level indicator facing you.

1. Power on the remote controller.

2. Power on the range extender.

3. Power on or connect sensor.

4. Power on the aircraft by turning on the battery

5. Connect the mobile device (Ground Station) to the UA

.

6. Wait until the LED flight indicator lights indicate good GPS connectivity and Ready to Fly

.

7. Push the throttle stick up slowly to lift the aircraft off the ground.

8. When landing, hovering over a level surface, p ull down on the throttle stick gently to

descend and land.

9. After landing the aircraft on the ground, keep the throttle stick down while th e motors

come to a complete stop.

FAILSAFE FUNCTION

The UA will enter Failsafe mode when the connection from the remote controller is lost. The flight

control system will automatically control the aircraft to return to home and land to reduce injuries or

damage. The following situations would make the aircraft fail to receive a signal from the remote

controller and enter Failsafe mode:

1. The remote controller is powered off.

2. The aircraft has flown out of the effective communication range of the remote cont roller.

3. There is an obstacle obstructing the signal between t he remote controller and the aircraft,

essentially reducing the distance the signal can travel.

4. There is interference causing a signal problem with the remote controller.

OPERATIONS RELATED TO MOTION PICTURE AND CLOSED SET FILM MAKING

T he following additional procedures will apply when operating for Motion Picture or Closed Set Film

Making.

The team will carry and have on hand a motion picture and television operations manual (MPTOM) At

least 3 days before aerial filming, the operator of the UAS will submit a written Plan of Activities to the

local Flight Standards District Office (FSDO) with jurisdiction over the area of propose d filming.

The plan of activities will include the following:

 Dates and times for all flights

 Name and phone number of the operator (PIC)

 Name and phone number of the person responsible for the on

- scene operation of the UAS

 Make, model, and serial or N −Number of UAS to be used

 Name and certificate number of UAS PICs involved in the aerial filming;Pictures From The Sky, LLC

. – APPENDIX A

– FLIGHT OPERATIONS AN D PROCEDURES

 A statement that the operator has obtained permission from property owners and/or local

officials to conduct the filming production event; the list of those who gave permission must be

made available to the inspector upon request

 Signature of exemption holder or representative

 A description of the flight activity, including maps or diagrams of any area, city, town, county,

and/or state over which filming will be conducted and the altitudes essential to accomplish the

operation.Pictures From The Sky, LLC

. – APPENDIX B

– User’s Manuals AP P E N DIX B

– USER’S MANUAL S

Users Manuals for each of these systems can be downloaded here

.

Pictures From The Sky, LLC

. , keeps a copy with each UA.

DJI Inspire 1 User Manual

Freefly Alta User Manual

Upon request these will be provided