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

October 15, 2015

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R., Part 11, Terrance Miller dba Unmanned Risk Management, operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial vi deography of alpine snow sport competitions and alpine snow sport training facilities, reques ts a limited exemption from the below-listed regulations to allow commercial operation of its sUASs, provided that the proposed sUAS operations comply with the conditions outlined below or as established by the Federal Aviation Administration (“FAA”) under Section 333.

The name and address of the applicant is: Terrance Miller dba Unmanned Risk Management 12424 Big Timber Drive, #5 Conifer, CO 80433

720-208-0844 AlpineSkier@Rocketmail.com

Terrance Miller dba Unmanned Risk Management makes this request under the “summary grant” process that the FAA announced in April 2015. (1) This request is similar in all material respects to a number of recent grants of exemption, including NFL Productions LLC dba NFL Films Grant of Exemption No. 12911 (Regulatory Docket No. FAA–2015–2139). (2)

Regulations from which the exemption is requested:

14 C.F.R. part 21 14 C.F.R. § 45.23 (b) 14 C.F.R. §§ 61.113 (a) & (b)

1 See FAA Summary Grants Speed UAS Exemptions, available at https://www.faa.gov/news/updates/?newsId=82485.

2 The use limitations and arguments in this applica tion are nearly identical to those contained in

NFL Productions LLC dba NFL Films May 20, 2015 application and the FAA’s September 17,

2015 approval of that application.U.S. Department of Transportation October 15, 2015 Page 2

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)

Terrance Miller dba Unmanned Risk Management proposes that it receive an exemption to use sUAS to gather footage from closed-set locations in and around alpine snow sport venues and alpine snow sport training facilities. Terrance Miller dba Unmanned Risk Management would use the footage for the production of training aids and marketing materials. Terrance Miller dba Unmanned Risk Management would obtain the consent of all official representatives of teams, sanctioning body and group personnel at the venues and training facilities in the vicinity in which the sUAS may operate.

The proposed sUAS operation will be conducted safely to minimize risk to the national airspace system (“NAS”) or to persons and property on the ground. Terrance Miller dba Unmanned Risk Management proposes that the exemption apply to civil aircraft that operate within the limitations listed below. These limitations were established in the FAA’s grant of NFL Productions LLC dba NFL Films request for an exemption:

1. The sUAS will weigh less than 55 pounds, including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set marketing video, alpine snow sport training video, motion picture and television filming are permitted.

3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per hour). Terrance Miller dba Unmanned Risk Management may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.U.S. Department of Transportation October 15, 2015 Page 3

4. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge (PIC) at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S.

driver’s license.

6. All operations will utilize a visual observer (VO). The UA will be operated within the VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as

the PIC always maintains the VLOS capability. The VO and PIC will be able to communicate verbally at all times; electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the sUAS and conduct its operations in accordance with the conditions and limitations stated in the grant of exemption, are hereinafter referred to as the operating documents. The operating documents will be accessible during sUAS operations 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 operating documents, the conditions and limitations herein take precedence and will be followed. Otherwise, Terrance Miller dba Unmanned Risk Management will follow the procedures as outlined in its operating documents. Terrance Miller dba Unmanned Risk Management may update or revise its operating documents. It is Terrance Miller dba Unmanned Risk Management’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. Terrance Miller dba Unmanned Risk Management will also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If Terrance Miller dba Unmanned Risk Management determines that any update or revision would affect the basis upon which the FAA granted this exemption, then Terrance Miller dba Unmanned Risk Management must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.U.S. Department of Transportation October 15, 2015 Page 4

9. Terrance Miller dba Unmanned Risk Management is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the sUAS is in a condition for safe flight. The pre-flight inspection will account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft will be prohibited form operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight.

11. Terrance Miller dba Unmanned Risk Management will follow the sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each sUAS operated under this exemption will co mply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The PIC also will meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. Terrance Miller dba Unmanned Risk Management w ill not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the sUAS in a manner consistent with how the sUAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the sUAS in a

manner consistent with how the sUAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR §

91.119.

15. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Terrance Miller dba Unmanned Risk Management will not operate flights under special visual flight rules (SVFR).U.S. Department of Transportation October 15, 2015 Page 5

16. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Director (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on

the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management w ill be made available to the Administrator or any law enforcement official upon request.

17. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the sUAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property.

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least three minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations will be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the

terms of the attached COA.

22. All aircraft operated in accordance with this exemption will 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 will be as large as practicable.

23. Documents used by Terrance Miller dba Unmanned Risk Management to ensure the safe operation and flight of the sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the sUAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

24. The UA will remain clear and give way to all manned aviation operations and activities at all

times.U.S. Department of Transportation October 15, 2015 Page 6

25. All Flight operations will be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures, unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. NFL Films will ensure that nonparticipating persons remain

under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees, essential persons, or individuals who have signed consent forms are not considered nonparticipating persons under this exemption.

26. All operations will be conducted over privat e or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply:

28. Terrance Miller dba Unmanned Risk Management w ill have a motion picture and television operations manual (MPTOM) as document ed in this grant of exemption.

29. At least 3 days before aerial filming, Terrance Miller dba Unmanned Risk Management will submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;U.S. Department of Transportation October 15, 2015 Page 7

b. Name and phone number of the operator for the sUAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of the sUAS;

d. Make, model, and serial or N-Number of the sUAS to be used;

e. Name and certificate number of sUAS PICs involved in the aerial filming;

f. 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 will be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including m aps 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.

30. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified, the sUAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. Terrance Miller dba Unmanned Risk Management incorporates all arguments in support of the petition made in NFL Films application for exemption May 20, 2015.

Federal Register Notice

As stated above, publication in the Federal Register is unnecessary because this application meets the FAA’s criteria for summary approval. To the extent that the FAA determines that publication is necessary, the following summary is provided:

Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) and 91.417 (a) & (b) to operate commercially a small unman ned vehicle (55 lbs or less) in videography operations.U.S. Department of Transportation October 10, 2015 Page 8

The Exemption is in the Public Interest

As demonstrated above, the proposed sUAS operations would minimize the risk of harm to individual safety or damage to the NAS and property. The operations proposed by Terrance Miller dba Unmanned Risk Management would prov ide tremendous public benefits by enabling thousands of alpine snow sports fans, coaches, athletes and sanctioning bodies to view footage that could not be captured via any other tec hnology. The sUAS operations as described in this application will be far safer and more efficient than use of helicopters, hand-held poles and devices or other aircraft to capture the required footage.

The conditions outlined in this petition clearly sa tisfy Section 333’s exemption criteria regarding

“size, weight, speed, operational capability, proximity to airports and populated areas, and

operation within visual line of sight,” and therefore the proposed operations would not.

“create a hazard to users of the national airspace system or the public or pose a threat to national security.” As discussed above, Terrance Miller dba Unmanned Risk Management agrees to use limitations that are substantially identical to those contained in the FAA’s recent grant of exemption for Advanced Aerial Cinematography. Accordingly, the proposed UAS operations of Terrance Miller dba Unmanned Risk Management should not raise safety or national security concerns, and should receive summary approval. Please do not hesitate to contact the undersigned if you need additional information. Respectfully submitted,

Terrance Miller dba Unmanned Risk Management

## Appendix A

Terrance Miller dba Unmanned Risk Management

Permission to Conduct Operations Form

In signing this form, I am giving Terrance Miller dba Unmanned Risk Management permission to operate its aircraft at less than 500 feet from property, or, in some jurisdiction in which I am responsible for or affiliated with, for the purpose of film or television production.

Name: ____________________________

Title: ____________________________

Location: ____________________________

Date of Operation: ____________________________

Basis of Authority to Grant Permission:

______________________________________________________________________

Signature: ____________________________

Date: ____________________________

Terrance Miller dba Unmanned Risk Management Representative Receiving Permission:

________________________________________

## Appendix B

Terrance Miller dba Unmanned Risk Management

List of Approved Aircraft

Make and Model Type Weight

1 DJI Innovations

Phantom 2 Quad-rotor 3 lbs. (inclusive of camera and battery)

2 DJI Innovations

Phantom 3 Quad-rotor 3 lbs. (inclusive of camera and battery)

3

4 DJI Innovations Inspire

AirDog Quad-rotor

Quad-rotor 6 lbs. (inclusive of camera and battery

3 lbs. (inclusive of cameral and batter)