~~ --:::::;;;;P 

~61 Flying Media 

May28, 2015 

U.S. Department ofTransportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

Aviation Regulations from 14 C.P.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 

91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) &(b);91.405 

(a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the ReformAct) 

and 14 C.P.R. Part 11, Flying Media, developer and operator of Small Unmanned Aircraft Systems 

("sUASs") equipped to conduct aerial photography for the motion picture and television industry for 

scripted closed set filming, hereby applies for an exemption from the listed Federal Aviation Regulations 

("F ARs") 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 as required by Section 

333.! 

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) lirnited2) 

predetem1ined 3) controlled as to access and 4) would provide safety enhancements to the already safe 

operations in the film and television 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) ofthe ReformAct. 

The name and address of the applicant is: 

Flying Media 

Attention: Craig Peck 

Phone: 717 475 2482 

Email: cpeck@flyingmedia.net 

Address: 837 Willow Road, Lancaster PA 17601 

1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of 

Waiver for Motion Picture and Television Filming. 
Regulations from which the exemption is requested: 

14 CPR Part 21 

14 C.P.R. 45.23(b) 

14 CPR 61.113 (a) & (b) 

14 C.P.R. 91.7 (a) 

14 CPR 91.9 (b) (2) 

14 C.P.R. 91.103 

14 C.P.R. 91.109 

14 C.F. R. 91.119 

14 C.P.R. 91.121 

14 CPR 91.151 (a) 

14 CPR 91.203 (a) & (b) 

14 CPR 91.405 (a) 

14 CFR407 (a) (1) 

14 CPR 409 (a) (2) 

14 CPR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

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 ofUASs 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 VAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visua1line 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." !d. §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 §40 101 of the Act, 

that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under 

section 333, but for the Administrator to craft conditions for the safe operation ofthe UAS, if it should be determined that the 

conditions set forth herein do not fulfill the statutory requirements for approval. 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(±) See also 49 USC §44711(a); 49 USC §44704; 14 

CFR §91.203 (a) (1). 

Flying Media's sUASs are rotorcraft, weighting 55 or fewer lbs. 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 Aerial Camera Platforms OPERATIONS 

MANUAL, attached as Exhibit 1 (hereinafter "the Manual")3. Such operations will insure that the sUAS 

will "not create a hazard to users of the national airspace system or the public."4 

Given the small size of the sUASs involved and the restricted sterile environment within which 

they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations ofUASs to 

commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant 

sUASs will operate, approval of the application presents no national security issue. 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 UASs for movie and television operations, the grant of the requested 

exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant 

the requested exemption without delay. 

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 movie and television filming 

operations conducted with conventional aircraft. 

3 Applicant submits this manual as a Confidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary 

information that the applicant has not and will not share with others. The manual contains operating conditions and procedures 

that are not available to the public and are protected from release under the Freedom oflnformation Act 5 USC 552 et.seq. 

4 Reform Act Section 3 3 3 (b). 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
These limitations and conditions to which Flying Media agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will 

be terminated at 25% battery power reserve should that occur prior to the 30 minute 

limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 

feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and 

the Camera Operator. 

6. sUAS pilot will be an FAA licensed airman with at least a private pilot's certificate and/or 

third class medical, or US Driver's License. The observer will hold at least a third class 

medical. 

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS 

Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial 

Coordinator), that person can also be designated as PIC. 

8. The UAS will only operate within a confined "Sterile Area" as defined in the Manual. The 

Manual requires the establishment of a "Security Perimeter" for the flight operations area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

production activities. It will be mandatory that all personnel who will be performing 

duties within the boundaries of the safety perimeter be present for this briefing. 

10. The operator 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. 

11. The operator will obtain the consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation, and this 

radius may be reduced to 30 feet based upon an equivalent level of safety determination, 

as required by the Manual. With the advanced permission of the relevantFSDO, 

operations at closer range can be approved. 

12. The operator will submit a written Plan of Activities to the FSDO three days before 

the proposed shoot as required by the Exemption. 

13. Pilot and observer will have been trained in operation ofUAS generally and received upto- date information on the particular UAS to be operated as required the Manual. 

14. Observer and pilot will at all times be able to communicate verbally. 

15. Written and/or oral permission from the relevant property holders will be obtained. 

16. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

17. If the sUAS loses communications or loses its GPS signal, the UAS will have capability 

to return to a pre-determined location within the Security Perimeter and land. 

18. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles 

or emergencies. 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
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 Part21 

Subpart H meets the requirements of an equivalent level of safety 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 the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated 

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

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The sUAS 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, operations 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 UAS, 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 nor more 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the sUAV, 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 sUA V marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAV will seethe 

identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the PIC operating the aircraft to have a private pilot's license rather thana 

commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot 

and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. 

The level of safety provided by the requirements included in the Manual exceeds that provided by a single 

individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated 

with the operation of the sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with 

a private pilot as the PIC exceeds the present level of safety achieved by 14 C.P.R. §61.113 (a) &(b). 

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 determining airworthiness. Given the size of the 

aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior 

to each flight, as set forth in Sections I and J, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft. 

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 pilot flying the sUAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, 32827, and 10700. 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
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 instruction: 

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. 

sVASs 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. 

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 sVAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may 

be needed to allow such operations. As set forth herein, except for the limited conditions stated in the 

Manual, the VAS will never operate at higher than 400 AGL. It will however be operated in a restricted 

area with security perimeter, where buildings and people will not be exposed to operations withouttheir 

pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the VAS as well 

as the location where it is operated. No flight will be taken without the permission of the propertyowner 

or local officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations as set forth in Section Hof 

the Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft operating at or below 500 

AGL in the movie industry. In addition, the low-altitude operations of the sVAS will ensure separation 

between these small-VAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
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 sUAS may not have a barometric altimeter, but instead aGPS 

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFRConditions 

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, assuming 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 40 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 

10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits 

proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR 

conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (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 ofreserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 10minutes 

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 30 

minutes or 25% ofbattery power whichever happens first. This restriction would be more than adequate 

to return the sUAS to its planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808. 

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 .... 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
(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 UAS fully loaded weighs 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. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. The P AA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797 A, 9816A, and 

10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenancelnspections 

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 Part43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the 

flight and operating handbook as referenced in the Manual. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. As provided in the 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. Moreover, the operator is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

********* 

Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.P.R. §21, subpart H; 14 C.P.R 45.23(b);14 C.P.R.§§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) 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 unmanned 

vehicle (55lbs or less) in motion picture and television operations. 

Approval of exemptions allowing commercial operations of sUASs in the film industry will 

enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, operate 

at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and 

structures; and present the risks associated with vehicles that weigh in the neighborhood of4,000lbs., 

carrying large amounts of jet A or other fuel (140 gallons for jet helicopters shown below). Suchaircraft 

must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by 

batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried Q'\ 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 

§ln 

C1l 

0.. 
on board. The sUAS is carried to the film set and not flown. The sUAS will carry no passengers or crew 

and, therefore, will not expose them to the risks associated with manned aircraft flights. 

The operation of small UASs, weighting less than 55lbs., 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 ina 

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. 

Privacy 

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise 

have agreed to be in the area where filming will take place. 

Set forth below are pictures of aerial filming conducted in both day and night environment, as 

flown today in highly populated and/or urban areas, with turbine powered helicopters. The grant ofthis 

exemption request will provide improved safety in both day and night operations. 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
Night operations will also be conducted by sUASs and as shown in the photographs below, such 

operations are fully lighted so that visibility is as though filming was conducted during daylight hours. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 20 12--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 UAS in the motion picture and television 

industry pursuant to the Manual appended hereto. 

Sincerely, 

C,:-/O;J ~ 

Craig Peck 

Flying Media 

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.net 
GENERAL 

[135.21 and 23] 

This manual sets forth Flying Media procedures and policies that are acceptable to the Administrator of 

the Federal Aviation Administration. This manual will be kept current with revisions as necessary. One 

copy of this manual will be maintained in current form at the principal operations base. A copy of this 

manual will be issued (including all changes and additions) to all flight operators, observers, maintenance 

personnel, and ground operations personneL A!! Flying Media flight, ground, and maintenance personnel 

must use this manual in conducting ail sUAS maintenance and flight operations. As required by FAR 

135.293(a)(i ), a!! personnel will be tested annually on their knowledge of this manuaL 

Flying Media has furnished the Federal Aviation Administration with a current and complete copy of this 

manual. The Director of Operations wi!! furnish the FAA with a!! changes and additions to this manual in a 

timely manner. 

Flying Media keeps a current and complete copy of this manual with each sUAS. This manual is not 

contrary to any applicable Federal regulations, applicable foreign regulations, Flying Media operating 

certificate, or Flying Media operations specifications. If you find a conflict between the Federal Aviation 

Regulations, certificate, or operations manual specification, the Federal Aviation Regulations will take 

precedence. You are required to bring any such conflict to the attention of the Director of Operations for 

correction. 

Version May 2015 
MANAGEMENT PERSONNEL 

[135.23(a)] 

FLYING MEDIA has appointed the following persons to the management positions listed: 

Director of Operations ....................................................... Craig Peck 

Chief Pilot ..................................................................... Andrew Wargo 

Director of Maintenance ................................................ Craig Peck 

OPERATIONAL CONTROL 

i. Operational Control is defined in FAR 1 as "the exercise of authority over initiating, 

conducting, and terminating a flight". Operational Control is exercised through both active and 

passive means. Passive control consists of developing and publishing policies and procedures 

for operational control personnel and flight operators to follow in the performance of their duties 

and assuring adequate information and facilities are available to conduct the planned mission. 

Active control consists of making those decisions and performing those actions necessary to 

operate a specific flight such as crew scheduling, accepting commercial engagement from the 

public or governmental entities, reviewing weather, NOTAMs, and flight planning. 

Flying Media is responsible for ensuring that night operations personnel and operational control 

employees comply with published policies and procedures. 

2. Operational Control systems vary with the type of operation authorized. In accordance with company 

policy, the major responsibility for operational control is with the Director of Operations. The Director 

of Operations may delegate the active control of flight to the pHot-in-command, but always retains full 

responsibility. 

DUTiES AND RESPONSIBILITIES 

Each of these people has the authority to act for FLYING MED!Aand, in his respective sphere, exercises 

operational control under FAR Part 135.77. Their specific duties and responsibilities are: 

Director of Operations 

1. Supervises the Chief Pilot and other employees as directed by the President. 

2. Ensures that all flight operations are conducted safely and in compliance with all Federal Aviation 

Regulations, Operations Specifications, and Company policies. 

3. Holds the FAA certificate authorization and signs all FAA correspondence and R&M Aerial 

Imagery operations specifications. 

4. Communicates with the FAA Flight Standards District Office (FSDO) and the National 

Transportation Safety Board (NTSB). Files all required reports and documents. 

5. Coordinates all revisions to this manual. Submits the proposed revisions to the FSDO, receives 

confirmation from the FSDO that the revisions are acceptable, and then distributes those 

revisions to all Flying Media manual holders. 

6. Schedules aircraft flight availability and maintenance actions (required inspections) in concert 

with the Director of Maintenance. 

Version 2015 
7. Coordinates with the Director of Maintenance the timely correction of mechanical irregularities 

and discrepancies. 

8. Hires and fires personnel. 

Chief Pilot 

1. Reports to the Director of Operations. 

2. Supervises flight operations personneL 

3. Conducts or supervises aH training activities of flight operations personneL 

4. Advises the Director of Operations regarding the training of flight operations personnel. 

5. Assists the Director of Operations in formulating operations policies, coordinates those policies, 

and coordinates operations and training. 

6. Ensures that all aircraft are properly equipped for applicable operations. 

7. Disseminates information to a!! flight operations personnel pertaining to airports, NOTAMS, 

company policies, and regulations. 

8. Maintains proficiency as Pilot-in-Command. 

9. Schedules flight operations personnel, including assigning Pl!ot-in-Command duties. 

10. Prepares and maintains proficiency records, pilot files, flight schedules, duty time records, 

reports, and correspondence pertaining to flight operations activities. 

11. Submits a!! reports regarding flight personnel to the Director of Operations. 

12. Keeps the aircraft copies of this Operations Manual current. 

13. Ensures that all flight crew personnel are certified and supervised according to the requirements 

specified in the Federal Aviation Regulations. 

Director of Maintenance 

1. Reports to the Director of Operations. 

2. Responsible for ail maintenance and inspection personnel. 

3. Ensures that company aircraft are maintained in an airworthy condition. 

4. Ensures that all inspections, repairs, and component changes are accomplished in accordance 

with manufacturer's specifications. 

5. Ensures compliance with maintenance procedures, service bulletins, service letters, and 

applicable Federal Aviation Regulations. 

6. Coordinates with maintenance contracting agencies when maintenance activities are being 

performed on company aircraft. 

7. Provides the Director of Operations with the current airworthiness status of the aircraft and the 

forecast down times to facilitate maintenance scheduling and insure timely deferral or correction 

of aircraft discrepancies. 

8. Maintains a close liaison with manufacturer's representatives, parts supply houses, and repair 

facilities. 

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9. Makes available to maintenance personnel the necessary overhaul manuals, service bulletins, 

service letters, airworthiness directives, applicable sections of this manual, and any other 

required technical data. 

10. Maintains aH necessary work records and logbooks, including aircraft permanent maintenance 

records, including records of aircraft repair and return to service. 

11. Maintains the total weight records for all aircraft, batteries and accessories. 

PIC AND Observer 

1. Keep his or her assigned navigation charts current and up to date. 

2. Keep his or her assigned copy of this Operations Manual up to date. 

3. Report for duty 60 minutes prior to dispatch time. This is for the accomplishment of preflight 

planning, airframe inspection and documentation. 

4. Notify the Director of Operations whenever the pilot may violate any rule due to being dispatched 

on a mission. 

5. Notify the Director of Operations whenever a medical deficiency exists that would affect the safety 

of flight. 

6. Notify the Director of Maintenance whenever an aircraft material deficiency exists that would 

affect the safety of flight. 

7. The Observer will assist the PIC with all flight planning. During flight operations; maintain a 

constant lookout for other aircraft or hazards, communicate with the PIC as needed, and respond 

to PIC safety of flight commands. 

WEIGHT AND BALANCE CONTROL 

[135.23(b)] 

Weight and Balance Procedures 

Not applicable (NA) to sUAS operations. sUAS will always be conducted with no passengers and there 

are no changes to airframe total weight, from fuel consumption. Flights will never exceed manufactures 

stated maximum take-off weight 

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ACCIDENT NOTIFICATIONS REQUIREMENTS 

[135.23( d)] 

1. The occurrence of any of the following requires Flying Media to notify the National Transportation 

Safety Board: 

a. An aircraft accident, as defined in NTSB Part 830 

b. A flight control system malfunction or failure. 

c. The inability of any required flight PIC to perform his normal flight duties as a result of 

injury or illness. 

d. Aircraft collide in flight 

e. Damage to property (other than an aircraft) if the cost of repair is estimated to exceed 

$25,000. If the property is considered a total loss, then notification is required if the 

lesser of the estimated repair cost or its fair market value exceeds $25,000. 

2. Flying Media personnel wli! notify the NTSB in the most expeditious means available as follows 

a. The Pilot-in-Command (PIC) shall notify the Director of Operations, who will immediately 

notify the NTSB. This notification may be through the FAA (ATC or FSDO), if possible; or 

may be direct to the NTSB, if necessary. 

b. If the PIC cannot immediately contact the Director of Operations, the PIC will immediately 

notify the NTSB. This notification may be through the FAA (ATC or FSDO), if possible; or 

may be direct to the NTSB, if necessary. 

c. If the Director of Operations has good reason to believe the PIC cannot contact him, and 

that one of the occurrences requiring notification has happened, he wil! immediately notify 

the NTSB. This notification may be through the FAA (ATC or FSDO), if possible; or may 

be direct to the NTSB, if necessary. 

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EMERGENCY NOTIFICATION 

Any Flying Media employee who, under emergency authority, deviates from any Federal Aviation 

Regulation while on duty will immediately write a complete report of the deviation from Federal Aviation 

Regulation .. The employee will include a description of the deviation taken and the reasons for it. This 

information will be sent to the following address no later than ten business days after the day of the 

deviation. 

PA Flight Standards District Office 

400 Airport Rd 

New Cumberland, PA 17070 

717-77 4-8271 

The employee will also provide a copy of this deviation report to the Director of Operations. 

REPORTING AND RECORDING OF MECHANICAL IRREGULARITIES 

[i35.23(f), and 135.65(d)] 

Whenever a PIC finds a material discrepancy with aircraft or support equipment, they will: 

1. Abort the mission. 

2. Coordinate with the Director of Maintenance to have the defective equipment repaired. 

PREVIOUSLY DEFERRED AND CORRECTED MECHANICAL IRREGULARITIES 

[135.23(g)] 

Not Applicable for sUAS. AI! material discrepancies will be repaired before flight. 

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EMERGENCY PROCEDURES 

[135.23(m )] 

The Pilot-in-Command (PIC) is the sole company employee assigned a!! flight emergency duties. 

Whenever a Observer is assigned to the flight, the emergency duties are assigned as follows: 

Pilot-in-Command 

• Aviate. If the aircraft can stil! maintain flight, keep flying and maneuver to a safe landing position 

on the ground. 

• Navigate. Maneuver to a safe position on the ground. 

• Communicate. Tel! Observer the prob!em(s) you are having. 

• Notify proper authorities and request aid. Call after flight termination if necessary. 

Observer 

• Assist the P!C with obvious or requested tasks until the aircraft is on the ground. 

• If the P!C is incapacitated, the Observer will assume all emergency duties. 

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MISSION QUALIFICATION PROCEDURES 

[! 35.23(n )] 

Pilot-in-command: Line checks: Routes and airports 

[135.299(c)] 

The P!C and Observer will, before beginning a flight: 

1. Study the area on !ow altitude VFR charts as appropriate, noting restricted areas, MEA's, 

MOCA's, helicopter landing pads, airport routing, and any other pertinent information. 

2. Study the area on Goog!e Earth or Bing maps, noting MEA's, routing, buildings, overhead cables, 

trees, and any other obstacles 

3. Study area airports using Airport Facility Directory, noting runway orientations, tower hours of 

operation, control frequencies and any other pertinent information. 

4. in rural areas, study the mission area for bearing and range from any large agricultural fields or 

crops. Call the local FSS for available aircraft f!ight information. 

5. Check current weather conditions and mission time forecast weather at 

https://www.avlatlonweather.gov/. 

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APPROVED AIRCARFT INSPECTION PROGRAM 

[135.23(0)] 

Not Applicable. Flying Media does not maintain any aircraft under the provisions of an Approved Aircraft 

Inspection Program 

FUNCTIONAL CHECK FLIGHTS {FSF} 

1. Place aircraft on open flat ground with indicator lights facing towards you 

2. Power on the controHer and then the aircraft and bind the controller to the aircraft 

3. Set the Home Point 

4. Push the throttle up slowly to take off 

5. Check roll, pitch, an yaw control response 

6. Check throttle response 

7. Fly outbound from PIC for 100 feet and hover 

8. Climb to altitude of 50' and set position and altitude hold 

9. Test Failsafe mode with controller switch to (OFF). When aircraft begins return, interrupt with 

controller switch to (ON) 

10. Test return to home (RTH) by pressing button on contro!!er 

1 i. Allow RTG to land aircraft. Throttle down aircraft until motors stop 

12. Turn off aircraft and controller 

GENERAL 

OTHER PROCEDURES AND POLICY INSTRUCTIONS 

[135.23(r)] 

AH company flight operations shaH be conducted in a professional and discipline manner. Safety is 

paramount 

All applicable rules, regulations, procedures and policies will be followed. When confronted with a matter 

of choice or interpretation In determining a course of action where the decisions are a matter of judgment, 

the safer alternative will always be chosen. 

The policies and procedures contained herein provide basic operational philosophies and Included 

general procedures and regulations applicable to a!l Company PIC/Observers. For more specific 

information on aircraft operating procedures, refer to the appropriate Aircraft Owners ManuaL 

FLIGHT TRAINING AND TESTING 

14 CFR § 91.9 

Flying Media's adaptable flight training system wi!! maintain and improve the safety and utility of sUAS 

flight operations. Flying Media's foundational training program will consistently test a set f!ight proficicies. 

All P!Cs for Flying Media will hold a FAA licensed airman certificate. This ensures the basic knowledge of 

FAA rules, terminology, airspace, aerodynamics and flight. 

Pilot logbooks 

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Flying Media PICs will maintain a sUAV logbook. Entries will include: 

• Date 

• Total Flight time or training time 

• Flight location 

• Type and identification of aircraft 

• Flight Simulator used (Heli-X or OJ! Inspire) 

Basic Training Course 

Flying Media flight qualification conducted with company trainer aircraft: 

initial upon probationary hire: 

1) 2 hours of observed simulator flight 

a) Controlled Hover at various altitudes 

b) Controlled night at constant altitude away from PIC 

c) Controlled flight at constant altitude back and forth in front of PiC 

d) Simulated emergency landing from altitude 

2) 5 hours of observed flight time in 'manual' mode, with designated training sUAS. (Manual 

mode means flying the sUAS without the use of any autopilot software functions such as; 

altitude hold, position hold or GPS flight modes.) 

Proficiency Tests 

1) Preflight and Battery knowledge 

a) Demonstrate a proper preflight and make ready for flight. 

b) Estimate total testing flight time and ensure enough charged batteries are on hand to carry out 

the test. 

c) Discuss: proper battery handling, temperature issues affecting charge and discharge, discharge 

rates at various throttle settings. 

2) Hover 

a) Bring the aircraft to a 3 foot hover, nose of the aircraft pointing away 180 degrees (tail on) 6 feet 

in front of the PIC and evaluator. Visualize a cube 6 foot on each side. Maintain a hover inside 

this cube for 5 minutes. 

b) Bring the aircraft to a 3 f foot hover, nose of the aircraft pointing toward the PIC (head on) 6 feet 

in front of the PIC and evaluator. Visualize a cube 6 foot on each side. Maintain a hover inside 

this cube for 5 minutes. 

c) Fly the aircraft out 100 foot from the P!C and evaluator, tail on. Bring the aircraft to a 3 foot hover. 

Visualize a cube 6 foot on each side. Maintain a hover inside this cube for 3 minutes. 

3) Vertical Obstacle Survey 30 foot 

a) Fly to a standoff distance of approximately 6 foot from the evaluator chosen vertical obstacle, tail 

on. Keeping the 6 foot standoff distance, climb, in 6 foot sections to the top of the obstacle, 

stopping for 10 seconds at each 6 foot increase of height. At the top of the obstacle, reverse the 

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sUAS to head on (to the PIC) and descend the sUAS In 1 0 foot sections, stopping for 30 seconds 

each 1 0 feet. 

4) Horizontal Obstacle Survey 50 foot 

a) Fly to a standoff distance of approximately 6 foot from the evaluator chosen horizontal obstacle, 

tail on. Keeping the 6 foot standoff distance, and maintaining constant altitude, fly the sUAS 

parallel down the length of the obstacle in no greater than 30 seconds. At the end of the 

obstacle, reverse the sUAS to head on (to the PIC) and fly the sUAS parallel down the length of 

the obstacle in no less than 90 seconds. 

5) Emergency Landing from altitude 

a) Climb the sUAS to approximately 100 foot and hold position. The evaluator will put down a 

visible marking about 10 feet in front of the PIC. When instructed, land the sUAS, as soon as 

possible (undamaged), within 2 feet of the landing marker. 

STERILE OPERATING REQUIREMENT (FAR 135.100) 

PICs are prohibited from engaging in any activity during flight, except those required for safe opration of 

aircraft. Examples of duties and activities prohibited are: 

1. Mobile phone cals 

2. Eating, drinking 

3. Nonessential conversation (remarks not pertinent to safe aircraft operation). 

STANDARDIZATION OF FLIGHT PROCEDURES 

PICS and Observers will at all times adhere to published standardized procedures in the conduct of 

flights. This ensures company aircraft are operated according to procedures that the company deems to 

be safest 

Violaiton of Flying Media Flight operations manual procedures, is considered a breach of code of conduct. 

Infractions may result in termination of employment. 

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FLIGHT OPERATIONS 

6.1 MISSION PLANNING 

Mission planning is the responsibility of the PIC and will cover all matters pertinent to the mission to be 

flown. Proper planning prevents piss poor performance. 

6.1.1 Weather 

A complete weather briefing is a prerequisite. 

6.2 BRIEFING 

The success of a flight is a direct measure of the preflight preparations, planning, and briefing 

6.2.1 Flight Checklist 

1. Pick a Take Off Point; that is flat, dry and located inside the planned flight area. 

2. Estimate flight time and battery use for mission photography/survey points. 

3. Set recovery point; flat dry location 

4. Check wind speed and direction. 

5. Check complete horizon for low flying aircraft. 

6. Stay clear of structures that could block the Radio Frequency (RF) control or Global Positioning 

System (GPS) signal; tall buildings, many tal! trees 

7. Keep the aircraft away from obstacles, people, animals, overhead !ines, and trees. 

8. Turn off Wi-Fi on any mobile devices. sUAS operational control frequencies operate on 2.4Ghz and 

5.8Ghz bands. FCC WiFi bands are 2.4Ghz. 

9. Do not fly near areas with high electromagnetic fields (EMF); high voltage !ines, large scale power 

transmission stations, mobile base stations and broadcasting towers. 

10. Do not fly the aircraft within no-fly zones specified by local laws and regulations. 

6.2.4 Emergencies 

1. Aborts 

2. Radio failure; unresponsive to inputs (flyoff) or environmental jamming 

3. Loss of visual contact with sUAS 

4. Crash; ground, structures, persons 

6.2.4.1 Failsafe and Return to Home (RTH) 

1. Return to Horne will not work if the GPS signal is insufficient or GPS is not active. 

2. Press the RTH Button on the remote controller to bring the aircraft back to the Home Point instead of 

turning off the remote controller. · 

3. Tall buildings may adversely affect the Failsafe function. Please adjust the aircraft location, altitude 

and speed while returning home to avoid obstacles. 

4. Make sure to always fly the aircraft within the transmission range of the remote controller. 

5. When updating the Home Point, do not block the GPS signal of the remote controller Do not update 

the Home Point near tal! buildings, as the GPS may be blocked and lead to an incorrect location 

being stored. 

6. Only use the Failsafe and Return to Horne functions in case of emergency, as they may be 

7. affected by the weather, the environment, or any nearby magnetic fields. 

8. Set/check Failsafe altitude before each flight. 

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6.2.4.2 Low Battery RTH 

The low battery level failsafe is triggered when the battery is depleted to a point that may affect the safe 

return of the aircraft. P!C wi!! return home or land the aircraft immediately when these warnings are 

shown. Aircraft will automatically return to the Hopme Point if no action is taken after 10 seconds 

countdown. 

6.2.4.3 Failsafe RTH 

ai!safe RTH is activated automatically if remote controller signal is lost for more than 3 seconds provided 

that Home Point has been successfully recorded and compass is working normally. Return home 

process may be interrupted and the operator can regain control of the UAS if a remote controHer signa! is 

resumed. 

6.3 MISSION 

1. Primary 

2. Operating area 

3. Sequence of events 

4. Communications: voice or electroic comms with observer 

5. Landing 

6.4 DEBRIEFING 

Each flight shall be followed with a thorough debriefing by the PIC as soon as practical. All 

areas of flight should be covered, paying particular attention to those areas where any difficulty 

was encountered. 

7.2 PREFLIGHT INSPECTION 

1. Check that a!! parts are in good condition. Do not fly with aging or damaged parts. 

2. Remote controller, battery and ground station device are all fu!ly charged. 

3. Propellers are mounted correctly and securely. 

4. Camera lens clear. Survey equipment readied 

5. Memory cards inserted, if necessary. 

6. Gimbal is functioning as normal. 

7. Gimbal is correctly attached to the aircraft. 

8. Motors can start and are functioning as normal. 

9. AU firmware has been updated to the latest version. 

7.2.1 Compass 

1. Ensure the compass is calibrated before every flight. 

2. DO NOT calibrate your compass where there is a chance of strong magnetic interference from large 

metal objects, parking structures, steel reinforcements underground, or under bridges. 

3. DO NOT carry ferromagnetic materials with you during calibration, such as keys or mobile phones. 

4. The compass shou!d always be reca!ibrated when moving from indoor spaces to outdoor spaces. 

MAINTENANCE 

1. Check every part of the aircraft if it is violently impacted. 

2. Old, chipped, or broken propellers or motors should never be used. 

3. Regularly check the battery level and overall battery life. When the battery life reaches 0%, it can no 

longer be used. 

4. After every 10 hours of flight time perform a thorough inspection of parts and components to ensure 

the safe operations 

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USE OF CHECKLISTS 

The use of checklists to assist in the proper operation of the aircraft is mandatory for all flights. Only those 

checklists promulgated by R&M Aerial Imagery wi!l be acceptable, including the methodology and 

procedures developed for checklist use by Company PICs/Observers. 

The PIC completing the checklist (whether silently or by challenge) is responsible for visually checking 

each item on the checklist, and ascertaining that the correct action has been taken. 

Certain portions of the emergency checklist are required to be accomplished immediately, from memory, 

during an emergency. It is the responsibility of every PIC to commit these portions to memory and review 

the adequacy of their recall on a frequent basis. 

The checklist is not intended as a "work!ist" or a crutch to lead crewmembers through their routines of 

controlling aircraft systems. It is rather envisioned that PIC wil! maintain sufficient familiarity and 

proficiency with these routines or "flows" that the checklist can be used as a check to ensure the flows are 

properly accomplished. 

No PIC is expected to attempt to accomplish, without omission, every detail of a flow from memory. Such 

an expectation would negate the rationale and practicality of using a written checklist. The proper method 

is to accomplish the flow to the extent possible from memory and then to utilize the checklist to ensure 

that any overlooked items are then accomplished. 

Upon completion of each individual checklist, the PIC will announce, "(Checklist Name) CHECKLIST 

A checklist that cannot be completed when initiated because of an interruption or because an item on the 

checklist cannot yet be completed will be held untli the interruption is over or the item can be completed. 

It is not acceptable to skip a checklist item and then depend on memory to accomplish the item later 

COLLISION AVOIDANCE 

Each PIC and Observer is responsible for seeing and avoiding other traffic, terrain and obstacles. 

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I agree to comply with the following: 

DOCUMENT CUSTODY FORM 

OP-1 

1. ! am responsible for keeping this Manual number ___ in usable and current condition, 

inserting revisions when received and recording revision dates and insertion instructions on the 

Revision Control Page. 

2. ! will immediately return this manual to Fying Media if I resign my position, am terminated, or take an 

extended !eave of absence. 

(Date) (Signature) 

Position: ------.. --=---=-~"-"'"'''"""------·---·-.. ---- Typed or Printed Name: 

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REVISION NOTICE 

OP-2 

Revision Number __ , dated becomes effective issued to 

--------------for book number or Aircraft Number-·----· The 

person indicated above will complete the revision by removing the outdated pages and inserting the new 

or revised pages according to the instructions below. He will then sign and date the revision record 

sheet. 

Place the upper portion of this form in the manual behind the revision record sheet and return 

the lower portion to the Director of Operations. 

Remove: Insert 

Return to Director of Operations 

I hereby certify that I have received, read, and fully understand the contents of the General Operations 

Manual Revision Number __ . I further certify that I have revised the operations manual copy in my 

possession as per the revision instructions. 

Signature: ---------------- Date:----· 

Version 2015