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# ~61 Flying Media

May28, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAAReform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.P.R. 45.23(b);14 CFRPart 21;14 CFR61.113 (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 ofthe FAA Modernization and ReformAct of2012 (the ReformAct) and 14 C.P.R. Part 11, Flying Media, developer and operator ofSmall UnmannedAircraftSystems ("sUASs") equipped to conduct aerial photography for the motionpicture and television industryfor scripted closed set filming, hereby applies for an exemption from the listed Federal AviationRegulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conductedwithin and underthe conditions outlined herein or as maybe establishedbythe FAA as requiredbySection 333.! As described more fullybelow, the requested exemption wouldpermit the operation ofsmall, unmanned andrelatively inexpensive sUAS under controlled conditions in airspace thatis 1) lirnited2) predetem1ined 3) controlled as to access and 4) wouldprovide safety enhancements to the alreadysafe operations in the film and television industrypresentlyusing conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (theFAA Administrator's) responsibilities to "

...establishrequirements for the safe operation ofsuchaircraft systems in the national airspace system." Section 333(c) ofthe ReformAct. The name and address ofthe applicantis: Flying Media Attention: Craig Peck Phone: 717 475 2482 Email: cpeck@flyingmedia.net Address: 837 Willow Road, Lancaster PA 17601

1The conditionsproposed bythe applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of Waiver for Motion Picture and TelevisionFilming.

### Regulations from whichthe exemption isrequested: 14 CPRPart 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 CPR91.405 (a) 14 CFR407 (a) (1) 14 CPR409 (a) (2) 14 CPR417 (a) & 

### (b) This exemption application is expressly submittedto fulfill Congress' goal inpassingSection 333(a) through (c) ofthe ReformAct. This law directs the SecretaryofTransportationto consider whether certainunmanned aircraft systems may operate safely inthe national airspace system(NAS) before completion ofthe rulemaking required under Section 332 ofthe ReformAct. In makingthis determination, the Secretary is required to determine whichtypes ofUASs do not create a hazard tousers ofthe NAS orthe public orpose a threat to national security in light ofthefollowing:

• The 

### VAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximityto airports andpopulated areas; and • Operation ofthe UAS within visua1line ofsight ofthe operator. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that suchvehicles "mayoperate safely inthe national airspace system, the Secretary shall establishrequirements for the safe operation ofsuchaircraft in the national airspace system."

### !d. §333(c) (emphasis added)2.
The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authoritybyits terms includes exempting civil aircraft, as the term is defined under §40101 oftheAct, that includes sUASs, from the requirement that all civil aircraft musthave a currentairworthiness certificate.

2 Applicant interprets this provision to place the duty on the Administrator to not onlyprocess applications for exemptionsunder section 333, but for the Administrator to craft conditions for the safe operation oftheUAS, ifit should be determined that the conditions set forth herein do not fulfill the statutoryrequirements for approval.

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

### The Administratormay grant an exemption from a requirement ofa regulation prescribedunder subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator findsthe 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 ofno more than 50 knots and have the capabilityto hover, and move inthe vertical andhorizontal plane simultaneously. Theywill operate only in line ofsight and will operateonly withinthe sterile area described in the Aerial Camera Platforms OPERATIONS MANUAL, attachedas Exhibit 1 (hereinafter "the Manual")3. Such operations will insure that the sUAS will "notcreate ahazardto users ofthe national airspace system orthepublic."4 Given the small size ofthe sUASs involved and the restricted sterile environmentwithinwhich they will operate, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety)in which Congress envisionedthat the FAAmust, byexemption, allow commercial operations ofUASsto commence immediately. Also due to the size ofthe UASs andthe restricted areas in whichtherelevant sUASs will operate, approval ofthe applicationpresents no national security issue. Given theclear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal AviationAct, as amended; the strong equivalent level ofsafety surrounding the proposed operations, andthesignificant public benefit, including enhanced safety, reduction in environmental impacts, includingreduced emissions associated with allowing UASs for movie and television operations, the grant oftherequested exemptions is inthe public interest. Accordingly, the applicant respectfullyrequests thatthe FAAgrant the requested exemption without delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes thatthe exemption requested herein apply to civil aircraft that havethe characteristics and that operate with the limitations listedherein. These limitations provide for at leastan equivalent or even higher level ofsafetyto operations under the current regulatory structure becausethe proposed operations represent a safety enhancement to the already safe movie andtelevisionfilming operations conductedwith conventional aircraft.

3 Applicant submits this manual as a Confidential documentunder 14 CFR 11.35 (b) as the entire manual contains proprietary information that the applicanthas 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 theFreedomoflnformationAct 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 whichFlying Media agrees to be boundwhen conducting commercial operations under an FAAissued exemptioninclude: 1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/orobserver. 3. Maximumtotal flight time for each operational flight willbe 30 minutes. Flights will be terminated at 25% batterypowerreserve shouldthat occurpriorto the 30 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feet AGL or, notmore than200 feet above an elevatedplatform from which filming isplanned. 5. Minimum crew for each operation will consist ofthe sUAS Pilot, the Visual Observer,and the Camera Operator. 6. sUAS pilotwill be an FAA licensed airman with at least a private pilot's certificate and/or third class medical, orUS Driver's License. The observer will hold at least a third class medical. 7. sUAS Pilot will be Pilot in Command (PIC). Ifa pilot certificate holder otherthanthesUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. theAerial Coordinator), that person can also be designated as PIC. 8. The UAS will only operate within a confined "Sterile Area" as defined in theManual. The Manual requires the establishment ofa "SecurityPerimeter" forthe flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations prior to eachday's production activities. It

### will be mandatorythat all personnel who will beperforming duties within the boundaries ofthe safetyperimeterbe present for this briefing. 10. The operator will file a FAA Form7711-1, 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 ofall persons involved inthe filming and ensurethat only consenting persons will be allowed within 100 feet ofthe flight operation, andthis radius maybe reduced to 30 feet basedupon an equivalent level ofsafetydetermination, as requiredbythe Manual. With the advancedpermission ofthe relevantFSDO, operations at closerrange canbe approved. 12. The operatorwill submit a written Plan ofActivities to the FSDO three days before the proposed shoot as required bythe Exemption. 13. Pilot and observer will havebeentrained in operation ofUAS generally and receivedupto- date information on the particularUAS to be operated as requiredthe Manual. 14. Observer and pilot will at all times be able to communicateverbally. 15. Written and/or oral permission from the relevant propertyholders will beobtained. 16. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, orother appropriate governmental agencies. 17. Ifthe sUAS loses communications orloses its GPS signal, the UAS will have capability to return to a pre-determined location within the SecurityPerimeter andland. 18. The sUAS will have the capabilityto abort a flight in case ofunpredictedobstacles 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 forthe issuance ofairworthiness certificates as required byFAR §91.203 (a) 

### (1). Given the size andlimited operating area associated with the aircraft to beutilizedbythe Applicant, an exemption from Part21 Subpart H meets the requirements ofan equivalent level ofsafetyunder Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

### (f)) and Section 333 ofthe ReformActboth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate,upon consideration ofthe size, weight, speed, operational capability, andproximityto airports andpopulated areas ofthe particular UAS. In 

### all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposedwill be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating withan airworthiness certificate without the restrictions and conditionsproposed. The sUAS to be operatedhereunder is less than 55 lbs. fully loaded, carries neither a pilotnor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively withina secured area as set outin the Manual. Unlike other civil aircraft, operations underthis exemption willbe tightly controlled andmonitoredbyboththe operator, pursuant to the Manual'srequirements, andunder the requirements and in compliance with local public safetyrequirements, to provide security for thearea ofoperation as is now done with conventional filming. The FAAwill have advance notice ofall operations. These safety enhancements, which already applyto civil aircraft operated in connectionwith motion picture and televisionproduction, provide a greater degree ofsafetyto the public andproperty owners than conventional operations conducted with airworthiness certificates issuedunder 14C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no crediblethreat to national securityposedbythe UAS, due to its size, speed ofoperation, location ofoperation, lackof explosive materials orflammable liquid fuels, and inabilityto carry a substantial externalload. 

### 14 C.F

### .R. § 45.23 {b). Marking oftheAircraft The regulationrequires: Whenmarks include onlythe Roman capital letter "N" and the registrationnumberis displayed onlimited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operatormust also display onthat aircraft neareach entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches normore than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even thoughthe UAS will have no airworthiness certificate, an exemption maybe needed asthe UAS will have no entrance to the cabin, cockpit or pilot station on which theword "Experimental" can beplaced. Given the size ofthe sUAV, two-inch lettering will be impossible.The word "Experimental"will be placed onthe fuselage in compliance with §45.29 

### (f). The equivalent level ofsafety will be providedbyhaving the sUA V marked on its fuselage as requiredby §45.29 

### (f) where the pilot, observer and others working withthe sUAVwill seethe identification ofthe UAS as "Experimental." The FAA has issued the following exemptions tothis 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): PrivatePilot Privileges and Limitations: Pilot inCommand. Sections 61.113 (a) & (b) limitprivate pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafetyof current operations byrequiring the PIC operating the aircraft to have a private pilot's licenserather thana commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries thepilot and passengers, the sUAS is remotely controlled with no living thing onboard. The area ofoperationis controlled andrestricted, and all flights are planned and coordinated in advance as set forth in theManual. The level ofsafetyprovidedbythe requirements included in the Manual exceeds that providedby asingle individual holding a commercial pilot's certificate operating a conventional aircraft. The risksassociated with the operation ofthe sUAS are so diminished from the level ofrisk associated withcommercial operations contemplatedbyPart 61 when drafted, that allowing operations ofthe sUAS as requestedwith a private pilot as the PIC exceeds the present level ofsafety achievedby 14 C.P.R. §61.113 (a) &(b). 

### 14 C.F.R. §91.7(a): Civil aircraftairworthiness. The regulationrequires that no person may operate a civil aircraftunless it is inairworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemptionbe granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance anduse ofsafety checklistsprior to each flight, as set forth in Sections I and 

### J, an equivalent level ofsafetywill beprovided. 

### 14 C.F.R. § 91.9 (b) (2): Civil AircraftFlightManual in theAircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) Forwhich anAirplane or Rotorcraft FlightManual is notrequiredby §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or anycombination thereof. The sUAS, given its size and configurationhas no ability orplace to carry such a flightmanual on the aircraft, not onlybecause there is no pilot onboard, butbecause there is no room or capacityto carry such an item onthe aircraft. The equivalent level ofsafetywill be maintainedbykeeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAAhas issuedthe 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 regulationrequires eachpilot in commandto take certain actions before flight to insurethe safety offlight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraftan exemption will be needed. An equivalent level ofsafety will be provided as set forth in the Manual. The PIC will take all actions including reviewing weather, flight batteryrequirements, landing andtakeoff distances and aircraft performance databefore initiation offlight. 

### 14 C.F.R. §91.109: Flightinstruction: Section 91.103 provides that no person may operate a civil aircraft (except a mannedfree balloon) that is beingused for flight instructionunless that aircraft has fully functioning dualcontrols. 

### sVASs andremotelypiloted aircraft, bytheir design do nothave fully functional dualcontrols. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAAhas approved exemptions for flight training without fullyfunctional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. SeeExemption Nos.5778K 

### & 9862A. The equivalent level ofsafetyprovidedbythe fact thatneither a pilotnor passengers will be carried in the aircraft andbythe size and speed ofthe aircraft. 

### 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption is for a 

### sVAS that is a helicopter andthe exemption requests authority to operate at altitudes up to400 AGL, ornot more than 200 above an elevatedplatform from which filming is planned, an exemptionmay be neededto allow such operations. As set forth herein, except for the limited conditions stated inthe Manual, the 

### VAS will never operate at higher than 400 AGL. Itwill howeverbe operated in arestricted area with securityperimeter, where buildings and people will notbe exposedto operations withouttheir pre-obtainedconsent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe 

### VAS aswell as the location where it is operated. No flight will be taken without the permission ofthe propertyowner or local officials. Because ofthe advance notice to the property owner andparticipants inthefilming activity, all affected individuals will be aware ofthe planned flight operations as set forth in Section Hof the Manual. Comparedto flight operations with aircraft orrotorcraft weighting far more thanthe maximum 55lbs. proposedherein and the lackofflammable fuel, anyrisk associated withthese operations is far less than those presentlypresentedwith conventional aircraft operating at orbelow500 AGL inthe movie industry. In addition, the low-altitude operations ofthe 

### sVAS will ensure separation between these small-VAS operations and the operations ofconventional aircraft that must complywith 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 eachperson operating an aircraft to maintain cruising altitudeby reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriatealtimeter setting available before departure." As the sUAS maynot have a barometric altimeter, but instead aGPS altitude read out, an exemption maybe needed. An equivalent level ofsafety will be achievedbythe operator, pursuantto the Manual and Safety Checklist, confirmingthe altitude ofthe launch site shown on the GPS altitude indicatorbefore 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 underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly tothe first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes." The batterypowering the sUAS provides approximately40 minutes ofpowered flight. Tomeet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights wouldbe limitedtoapproximately 10 minutes in length. Given the limitations ontheUAS's proposed flight area andthe location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight ornightVFR conditions is reasonable. Applicantbelieves that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. 

### See Exemption 10673 (allowing LockheedMartin Corporation to operate without compliance withFAR91.151 (a)). Operatingthe small UAS, in a tightly controlled area whereonly people andproperty owners or official representatives who have signedwaivers will be allowed, withless than 30 minutes ofreserve fuel, does not engender the type ofrisks that Section 91.151(a) was intendedto alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10minutes would greatlyreduce the utility for whichthe exemption will begranted. Applicantbelieves that an equivalent level ofsafety canbe achievedbylimiting flights to30 minutes or 25% ofbatterypower whichever happens first. This restriction wouldbemore than adequate to return the sUAS to its planned landing zone from anywhere in its limited operatingarea. 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 andRegistration Theregulationprovides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless ithas 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 requiredby paragraph (a) ofthis section or a special flight authorization issuedunder §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs no more than 55 lbs and is operated without an onboardpilot. As such, there is no ability or place to carry certification and registration documents orto display themonthe sUAS. An equivalent level ofsafety will be achievedbykeeping these documents at the groundcontrol point where the pilot flying the sUAS will have immediate access to them, to the extent theyare applicable to the sUAS. The PAAhas issued numerous exemptions to this regulation. Arepresentative sample ofother exceptions includes ExemptionNos. 9565, 9665, 9789, 9789A, 9797, 9797A, 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 orowner "shallhave that aircraft inspectedas prescribed in subpart E ofthis part and shall betweenrequired inspections, except as providedin paragraph (c) ofthis section, have discrepancies repaired as prescribed inpart 43 ofthis chapter

...,"and others shall inspect ormaintain the aircraft in compliance withPart43. Given that these section and Part43 apply onlyto aircraft with an airworthiness certificate,these sections will not applyto the applicant. Maintenance will be accomplishedbythe operatorpursuant tothe flight and operatinghandbook as referenced in the Manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payloadand operate onlyin restricted areas for limitedperiods oftime. Ifmechanical issues arise the UAS canland 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 orderprior to initiating flight, performrequiredmaintenance, andkeep a log of any maintenance performed. Moreover, the operator is the personmost familiar with the aircraft andbest suitedto maintainthe aircraft in an airworthy conditionto providethe equivalent level ofsafety. 

### ********* Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in theFederal Register, should itbe determined thatpublication is needed: Applicant seeks an exemption from the following rules: 14 C.P.R. §21, subpart H; 14 C.P.R45.23(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 smallunmanned vehicle (55lbs or less) inmotionpicture and televisionoperations. Approval ofexemptions allowing commercial operations ofsUASs inthe film industrywill enhance safetybyreducing risk. Conventional film operations, usingjetor pistonpower aircraft,operate at extremely low altitudesjustfeet from the subjectbeing filmed and in extreme proximityto people and structures; andpresent the risks associated with vehicles that weigh in the neighborhood of4,000lbs., carrying large amounts of jetA orother fuel (140 gallons forjethelicopters shownbelow). Suchaircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. andpoweredby batteries eliminates virtually all ofthatrisk given the reducedmass and lack ofcombustible fuel carried Q'\

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

### §ln C1l 0..

### onboard. The sUAS is carried to the film set and not flown. The sUAS will carryno passengers orcrew and, therefore, will not expose themto the risks associated with manned aircraftflights. The operation ofsmall UASs, weighting less than 55lbs., conducted inthe strictconditions outlined above, will provide an equivalent level ofsafety supporting the grant oftheexemptions requested herein, including exempting the applicant from the requirements ofPart21 andallowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and ina sterile environment and, as a result, are far saferthan conventional operations conducted withturbine helicopters operating in close proximityto the ground andpeople. 

### Privacy All flights will occur overprivate or controlled access propertywith the property owner'sprior consent and knowledge. Filming will be ofpeople who have also consentedto being filmed orotherwise have agreed to be in the area where filming will takeplace. Set forth below are pictures ofaerial filming conducted in both day andnight environment,as flown today inhighlypopulated and/or urban areas, with turbine powered helicopters. The grant ofthis exemption request will provide improved safety in both day and nightoperations.

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

### Night operations will also be conductedby sUASs and as shown in the photographs below, such operations are fully lighted so that visibility is as though filming was conducted during daylighthours.

Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012--size,weight, speed, operating capabilities, proximityto airports andpopulated areas and operation within visual lineof sight andnational security- provide more than adequatejustification for the grant oftherequested exemptions allowing commercial operation ofapplicant's UAS in the motionpicture andtelevision industrypursuant to the Manual appendedhereto.
Sincerely,



# C,:-/O;J

# ~ Craig Peck Flying Media

Flying Media· Craig Peck· 837 Willow Road, Lancaster PA 17601 · 717-475-2482 cpeck@flyingmedia.netGENERAL [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 ofthis manual will be maintained in current form at the principal operations base. A copy ofthis 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 ofthis manuaL Flying Media has furnished the Federal Aviation Administration with a current and complete copy ofthis 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 ofthis 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 

### 2015MANAGEMENT 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 necessaryto 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 offlight to the pHot-in-command, but always retains full responsibility. DUTiES AND RESPONSIBILITIES Each ofthese 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 bythe 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 

### 20157. 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 offlight operations personneL 4. Advises the Director ofOperations regarding the training offlight 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, dutytime 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 ofthis 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 ofthe aircraft and the forecast down times to facilitate maintenance scheduling and insure timely deferral or correction ofaircraft discrepancies. 8. Maintains a close liaison with manufacturer's representatives, parts supply houses, and repair facilities.

Version 1.1, 20159. Makes available to maintenance personnel the necessary overhaul manuals, service bulletins, service letters, airworthiness directives, applicable sections ofthis 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 ofthis 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 offlight. 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 offlight 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-offweight

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ACCIDENT NOTIFICATIONS REQUIREMENTS [135.23(d)] 1. The occurrence of any ofthe 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) ifthe cost of repair is estimated to exceed $25,000. Ifthe property is considered a total loss, then notification is required ifthe lesser ofthe estimated repair cost or its fair market value exceeds $25,000.

2. Flying Media personnel wli! notifythe NTSB in the most expeditious means available as follows a. The Pilot-in-Command (PIC) shall notifythe 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. Ifthe PIC cannot immediately contact the Director of Operations, the PIC will immediately notifythe NTSB. This notification may be through the FAA (ATC or FSDO), if possible; or may be direct to the NTSB, if necessary. c. Ifthe Director of Operations has good reason to believe the PIC cannot contact him, and that one ofthe 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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### 2015EMERGENCY NOTIFICATION Any Flying Media employee who, under emergency authority, deviates from any Federal Aviation Regulation while on dutywill immediately write a complete report ofthe deviation from Federal Aviation Regulation

.. The employee will include a description ofthe 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 ofthe deviation. PA Flight Standards District Office 400 Airport Rd New Cumberland, PA 17070 717-774-8271 The employee will also provide a copy ofthis 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. Ifthe aircraft can stil! maintain flight, keep flying and maneuverto a safe landing position on the ground. • Navigate. Maneuverto 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. • Ifthe P!C is incapacitated, the Observer will assume all emergency duties.

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### 2015MISSION 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, studythe 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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### 201SAPPROVED 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 of50' 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 ofjudgment, 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. Pilotlogbooks 

### 2015Flying Media PICs will maintain a sUAV logbook. Entries will include: • Date • Total Flight time ortraining 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 traineraircraft: initial upon probationary hire: 1) 2 hours of observed simulator flight a) Controlled Hover at various altitudes b) Controlled night at constant altitude awayfrom 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 ofthe 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 ofthe aircraft pointing toward the PIC (head on) 6 feet in front ofthe 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 ofthe obstacle, stopping for 10 seconds at each 6 foot increase of height. At the top ofthe obstacle, reverse the

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sUAS to head on (to the PIC) and descend the sUAS In 10 foot sections, stopping for 30 seconds each 10 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 ofthe obstacle in no greater than 30 seconds. At the end ofthe 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 ofthe PIC. When instructed, land the sUAS, as soon as possible (undamaged), within 2 feet ofthe 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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### 2015FLIGHT OPERATIONS 6.1 MISSION PLANNING Mission planning is the responsibility ofthe 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 ofthe 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 ofstructures 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 offWi-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 notfly 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 environmentaljamming 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 ifthe 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 offthe 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 ofthe remote controller. 5. When updating the Home Point, do not block the GPS signal ofthe remote controller Do not update the Home Point neartal! 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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### 20156.2.4.2 Low Battery RTH The low battery level failsafe is triggered when the battery is depleted to a point that may affect the safe return ofthe 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 ofthe 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 offlight 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 everyflight. 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 ofthe 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 offlight time perform a thorough inspection of parts and components to ensure the safe operations Version 

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USE OF CHECKLISTS The use of checklists to assist in the proper operation ofthe aircraft is mandatoryfor 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 ofthe 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 oftheir 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 memoryto 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, ortake an extended !eave of absence. (Date) (Signature)

Position:

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

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### May 201.5REVISION NOTICE OP-2 Revision Number

__ , dated becomes effective issued to --------------forbook 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 ofthis 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:----·

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