)i)j(o--3 3~ & 

Big Shot Aerial Imaging LLC 

3347 Mount Pleasant Road NE ·, 

Dalton, GA 30721 

January 10, 2016 

U.S. Dept. ofTransportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 ..J) 

Re: Exemption Request under Section 333 of the FAA Reform Act and Paw 

11 of the Federal Aviation Regulations o 

·Y"<,-

. .,...t 

Dear Sir or Madam: 

We are writing pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (the "Reform Act") and 14 C.P.R. Part 11, Big Shot Aerial Imaging LLC seeks an 

exemption from Federal Aviation Regulations ("PARs") detailed below for the following 

described Unmanned Aerial System or alike called in this application the UA V System, 

which includes an Unmanned Aircraft (UA) and ground station-based equipment and 

crew: 

THE UNMANNED AIRCRAFT (UA): 

• A lightweight (5.3 lb gross weight with all on-board equipment), battery 

operated 4-motor rotorcraft in the form of a Quadcopter that takes off and lands 

vertically, manufactured by DJI, Model Phantom 3 Professional, modified by the 

applicant to carry the following equipment in, flight; 

• An on-board flight computer with GPS navigation and location ability 

that receives signals for flight controls from a ground-based transmitter/controller; 

• An on-board 4K camera capable of capturing imagery in the form of full 

color, high definition Dstill photos and video; ~-

• An on-board telemetry system that delivers flight data from the on-board 

flight computer to the on-board radio transmitter including altitude AGL, 

horizontal and vertical speed, compass direction of flight and direction back to its 

launch site; 

• A 600mW, 5.8GHz on-board radio transmitter that transmits live video 

from the on-board camera plus all the flight data from the telemetry system 

described above; THE GROUND STATION-BASED PART OF THE SYSTEM: 

• A Pilot in Command (PIC) in operational control of a flight operation 

from beginning to end and who controls the UA while in the air; 
• A 1OOm W, 2.4GHz radio transmitter/controller operated by the PIC to 

control the UA while in flight; 

• A radio receiver receiving live video and flight data from the on-board 

camera and computer projects it all together onto a screen for the PIC to view 

during flight; 

• A Visual Observer (VO) is a person who provides a second pair of eyes 

to visually track the UA while in flight. 

The requested exemption would support an application for a commercial 

Certificate of Authorization to use the UAV System to support aerial photography 

and video primarily of Large Scale Construction Project, to conduct land survey, 

top side building progress and condition, and wide scale documentation of 

construction conditions and also used for agricultural surveys and real estate. 

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and diminish 

the likelihood of death or serious bodily injury. With a small payload and maximum 

flight time of only I 0 minutes, this offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than 

ground- based imagery for displaying the characteristics of large, complex properties 

with several buildings and large trees. The applicants in the past have chartered 2-seat 

full-sized helicopters for this purpose, which has proven more costly than many potential 

clients have been able to afford. The benefits of reduced cost, reduced noise interference 

and improved quality of presentation from the UA will be valuable to and benefit many 

construction professionals as well as community leaders, in the development of project 

site characteristics. 

The state constmction based photography occor in restricted or other areas where access 

to the public is strictly limited and controlled. Under virtually all circumstances, all of the 

only property or structures near the construction sites are owned and operated by the 

same entity. As a result, the operation has no substantial impact on any third persons not 

involved in the actual site project. 

Because Big Shot Aerial Imaging will operate in a sterile area, the UAS will be flown 

based on visual line-of-sight at altitudes below 400' AGL, and a NOT AM wi11 be issued 

prior to any flight, the requested exemption provides an equivalent level of safety to any 

requirement for a commercial pilot's certificate. 

Additionally, we request that we be allowed to use our system to benefit first responders 

nearby who might require assistance, including fire fighters, the police, the sheriff, et al., 

while remaining subject to all limitations cited in this application as we do so. 

The UA V System will be operated in the field with both a PIC and a VO in accordance 
with FAA Policy N 8900.227 Section ·14 "Operational Requirements for UAS" and with 

the following Restrictions: 

(a) No flight will be made with a UA Gross weight exceeding 55 pounds; 

(b) All operations must occur in .FAA Class G airspace at no more than 400 ft AGL, at 

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

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

to communicate by voice at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of 

the property owner; 

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

61.51 (b), a minimum oflOO flight cycles and 25 hours of total time as a UA 

rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; 

(f) All required permits will be obtained from state and local government prior to 

operation; 

(g) The UA V System will not be operated over densely populated areas; 

(h) The UAV System will not be operated at air shows; 

(i) The UA V System will not be operated over any open-air assembly of people; 

G) The UAV System will not be operated over heavily trafficked roads; 

(k) The UA V System will not be operated within 5 NM of an airport or heliport; 

(1) The UA V System will not be operated over properties without property owner 

representation in observance 

(m) Operations will be restricted to day only and weather conditions equivalent to 

VFR; 

(n) The PIC will brief the VO and property owner about the operation and risk before 

the first flight at each new location; 

(o) No flight may be made without a Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UA is in a condition safe for flight (see Appendix 

A). 

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

16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on 

the system and will complete a course of maintenance instruction as part of their initial 

training. 
We submit that the combination of the UA's light weight, flight performance and ability, 

fully qualified flight crew and strict operation under the guidelines established in 

8900.227, and under all of the Restrictions (a) through (o) listed above, the FAA can have 

full confidence that the operation will have an equivalent or greater level of safety than 

manned aircraft performing the same mission. 

The name and contact information of the applicant ar:e: 

Big Shot Aerial Imaging LLC, 3347 Mount Pleasant Road, Dalton, GA 3072I, (706) 

980-9287. 

Email: dan@bigshotaerialimages.com 

The regulations from which the exemption is requested are listed below. Beside each 

regulation number is the page of the attached Addendum upon which each may be found 

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

- I4 CFR Part 2I ........................................ Addendum Page I 

- 14 CFR 91.203 ......................................... Addendum Page I 

- 14 CFR 45.23, 45.29 ................................ Addendum Page 2 

- 14 CFR 91.9 ............................................. Addendum Page 2 

- I4 CFR 61.113, 61.13 3 ............................ Addendum Page 2 

- 14 CFR 91.109, 91.119, 91.12l.. ............. Addendum Page 3 

- 14 CFR 91.15 1.. ....................................... Addendum Page 4 

- 14 CFR Subpart E (91.401- 91.4I7) ...... Addendum Page 4 

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

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us at any time if you require additional 

information or clarification. We look forward to working with your office. 

Sincerely, 

Daniel M, Ursitti 

President, Big Shot Aerial Imaging LLC 
Addendum containing Exemption Requests and Equivalent Level of Safety 

Appendix A- Flight Manual 

Appendix B Owner's Manual for UA 

ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

14 CPR Part 21, Subpart H: Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develop airworthiness standards for Unmanned Aerial 

Systems, we request an experimental certificate be issued for the CAV System under 

either or both of the following provisions: 

21.191 Experimental certificates. 0 Experimental certificates are issued for the following 

purposes:O(a) Research and development. Testing new aircraft design concepts, new 

aircraft equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft. 0 (b) Showing compliance with regulations. Conducting flight tests and 

other operations to show compliance with the airworthiness regulations including flights 

to show compliance for issuance of type and supplemental type certificates, flights to 

substantiate major design changes, and flights to show compliance with the function and 

reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market 

surveys, sales demonstrations, and customer crew training, we would expect that an 

experimental certificate would permit our commercial purpose as well. 

The aircraft will not carry persons or property, will not carry fuel, and will only fly under 

strict operational requirements. Combined with the UA's light weight, being constructed 

primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if 

not safer, than a conventionally certificated aircraft performing the same mission. 

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CPR Part 21, Subpart H, and the requirement for an 

airworthiness certificate in general, citing the equivalent level of safety outlined in the 

previous paragraph. 

14 CPR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." 

At a maximum gross weight of 5.3 pounds, the UA is too small to carry documentation, 

does not have an entrance, and is not capable of carrying passengers or crew. To obtain 

an equivalent level of safety and meet the intent of 91.203, we propose that documents 
deemed appropriate for this aircraft by the FAA will be co-located with the crew at the 

ground control station and available for inspection upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and registration 

certificates be permanently affixed to the aircraft via placard containing the following 

information plus the word "EXPERIMENTAL" to 

Addendum Page 1 of 4 

satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed 

placard description below: 

EXPERIMENTAL Manufacturer: DJI Innovations, lnc.950 E Baseline Ave. Ste. 210 

Apache Junction AZ 85119 Model: Phantom 3 Professional, Serial Number: 

P76DCF17016857 

If found please contact: (706) 980-9287. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display 

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The UA does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and has a registration number assigned to it by the 

FAA: N-Number N715BS 

We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the 

PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be 

able to see the designation. Additionally, we feel that the permanent placard discussed in 

the previous paragraph will provide the aircraft's registration information at the ground 

station. Finally, we will display at the ground station a high contrast flag or banner that 

contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or 

greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate its point 

of origin. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. We 

request an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew during flight 

operations. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a 
current, approved UA Flight Manual (Appendix A) must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations. The regulation provides that no person that 

holds a private pilot certificate may act as pilot in command of an aircraft for 

compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command 

of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers 

or property for compensation or hire. 

Addendum Page 2 of 4 

Our proposed operations require that the PIC must either 

1. Hold a Commercial Pilot Certificate issued by the FAA, and have logged 25 hours of 

flight experience in this type ofUA, or 

2. Meet the requirements of 8900.227 para 16( c )(2)( c) "Operations without a pilot 

certificate" in which the PIC is required to complete "FAA private pilot ground 

instruction" and pass "the FAA Private Pilot written examination." Since there are 

currently no means available for the pilot of a UAS to gain the experience in an 

equivalent category and class in order to apply for a commercial pilot's license, 

we propose to generate an equivalent level of safety by requiring our pilots to 

complete, at a minimum, FAA commercial pilot ground instruction and pass the 

FAA Commercial Pilot written examination in addition to completing the private 

pilot requirements. Since the aircraft cannot carry passengers or property, we feel 

we meet the intent of 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls." 

The CA V System ground-based control station consists of a small hand-held radio 

transmitter and while it does not offer a second set of"controls", both the student and 

instructor can, and will, operate the single set of controls simultaneously. With both 

student and instructor having "hands-on" the controls during flight, we feel that this 

technique meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be 

operating at a maximum of 400 feet AGL, we cannot comply with this requirement. 
In order to provide an equivalent level of safety we will only fly over private property 

with a size of at least two acres with the permission of the owner of the property flown 

over. The aircraft will not be operated over congested areas or over any open air 

assembly of persons. The property owner will be briefed on the expected route of flight 

and the associated risks to persons and property on the ground. The aircraft will be 

operated at a low altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. Therefore we maintain that due to the 

small size of the UA, the hazard to persons, vehicles and structures is minimal compared 

to manned aircraft, which should be considered in granting the exemption. 

14 CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. 

The UA will always fly below 400 feet AGL and will not need to maintain cruising 

altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the UA onboard computer to the display screen held by the PIC, providing a constantly updated 

AGL readout. 

Addendum Page 3 of 4 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. 

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer 

for delays to landing. The U A is battery operated and the maximum duration of flight 

from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft will 

never fly more than 3/4 NM from the point of intended landing, a full battery charge at 

launch will ensure that we meet the reserve energy requirement of this paragraph. We 

request an exemption to the word "fuel" and ask for an equivalent interpretation with the 

word "energy". 

14 CFR Subpart E (91.401 - 91.417)- Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 

authorized under 43.7" after maintenance and inspection. 

It is our intention that the PIC perform maintenance and inspection of the aircraft and ''be 

authorized to approve the aircraft for return to service." As provided in the Pre-Flight 

Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition 

prior to every flight and in addition conduct detailed inspections after every two hours of 
flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a 

propeller, checking electrical connections and updating software and firmware for the onboard computer. All other maintenance will be performed by the manufacturer or their 

designated repair facility. The PIC will document work performed in accordance with 

91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC 

can ensure an equivalent level of safety. 

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(l) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class 

medical certificate issued under part 67 in order to perform as a pilot or observer. 

The UA maximum gross weight is 5.3 pounds, it is constructed of carbon fiber and 

plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. 

Given the unlikely event that both the PIC and VO become medically incapacitated while 

the aircraft is in flight, the UA will return autonomously to the site of launching and land 

without crew intervention. Therefore, requiring the PIC and VO to meet the same 

medical requirements as a commercial pilot carrying passengers in a large aircraft is an 

unnecessary burden. 

We propose that the minimum medical requirements for the PIC and VO be vision 

corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement 

will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is 

medically qualified to operate a much larger vehicle. 

Addendum Page 4 of 4 

APPENDIX A- FLIGHT MANUAL FLIGHT RESTRICTIONS 

(a) No flight will be made with a UA Gross weight exceeding 55 pounds; 

(b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at 

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

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

to communicate verbally at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of 

the property owner; 

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

61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA 

rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; 

(f) All required permits will be obtained from state and local government prior to 

operation; 

(g) The CAV System will not be operated over densely populated areas; 
' . 

(h) The CA V System will not be operated at air shows; 

(i) The CA V System will not be operated over any open-air assembly of people; 

G) The CA V System will not be operated over heavily trafficked roads; 

(k) The CA V System will not be operated within 5 NM of an airport or heliport; 

(1) The CA V System will not be operated over properties smaller than two acres in 

stze; 

(m)Operations will be restricted to day only and weather conditions equivalent to VFR; 

(n) The PIC will brief the VO and property owner about the operation and risk before 

the first flight at each new location; 

(o) No flight may be made without a successful Pre-Flight Inspection by the PIC 

before each operation to ascertain that the UA is in a condition safe for flight. 

PRE-FLIGHT CHECKLIST 

(1) Use voltmeter to determine that UA battery is fully charged in order to prevent 

unexpected premature descent; 

(2) Check all wiring connections are tight;(3) Check all propellers are undamaged and no 

cracks exist in any structural members ofthe UA; (5) Tum on radio controller, check for 

adequate voltage, set it to connect to the UA, move all 

control switches to forward or down position and throttle control stick full back position; 

(6) Connect UA main battery, check for radio contact with UA's radio receiver; (7) At a 

location different from previous flight, re-set GPS and compass to current location; (8) 

Tum on transmitter, gimbal and camera. 
January 10,2016 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Big Shot Aerial Imaging LLC 

3347 Mount Pleasant Road NE 

Dalton, GA 30721 

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

the Federal Aviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 

91.121; 91.151(a); 91.405(a); 91.407(a)(I); 91.409 (a)(1) and (2); 91.417(a) and (b). 

Dear Sir or Madam: 

We are writing pursuant to Section 3 33 of the FAA Modernization and Reform Act of 

2012 (the "Reform Act") and 14 C.F.R. Part 11, Big Shot Aerial Imaging LLC an 

operator of Unmanned Aircraft Systems ("UASs") for aerial photography in the 

Architectural Engineering and Construction industry as well as the motion picture and 

television industry, hereby applies for an exemption from the Federal Aviation 

Regulations ("F ARs") to allow commercial operation of its UASs. 

On or about September 25, 2014, the FAA granted exemptions to six UAS operators, 

including Astraeus Aerial (the "Astraeus Exemption"). As set forth in Big Shot Aerial 

Imaging LLC's Flight Operations and Procedures Manual (the "FOPM") submitted under 

14 CFR 11.35(b)), Big Shot Aerial Imaging LLC will adhere to the terms of the Astraeus 

Exemption. 

Low-level oblique photos and video from several angles are far more effective than 

ground- based imagery for displaying the characteristics oflarge, complex properties 

with several buildings and large trees. The applicants in the past have chartered 2-seat 

full-sized helicopters for this purpose, which has proven more costly than many potential 

clients have been able to afford. The benefits of reduced cost, reduced noise interference 

and improved quality of presentation from the UAS will be valuable to and benefit many 

construction professionals as well as community leaders, in the development of project 

site characteristics. The site construction based photography occurs in restricted or other 

areas where access to the public is strictly limited and controlled. Under virtually all 

circumstances, all of the only property or structures near the construction sites are owned 

and operated by the same entity. As a result, the operation has no substantial impact on 

any third persons not involved in the actual site project 

Big Shot Aerial Imaging LLC's requested exemption would permit the operation of small, 

unmanned UAS under controlled and "sterile" conditions in and on Construction Site 

Projects and in motion picture and television airspace that is: (i) limited, (ii) 

predetermined, (iii) subject to controlled access, and (iv) provide greater safety in 

connection with aircraft operations in the film and television industry and or Construction 

Site Projects. As established by the exemptions already granted by the FAA, approval of 

Big Shot Aerial Imaging LLC exemption would enhance safety and fulfill the Secretary 

ofTransportation's (the FAA Administrator's) responsibilities to " ... establish 
requirements for the safe operation of such aircraft systems in the national airspace 

system." Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

Big Shot Aerial Imaging LLC Attn: Daniel M. Ursitti.; Ph: 706-980-9287 Email: 

dan@bigshotaerialimaging.com 3347 Mount Pleasant Road NE, Dalton, GA 30721 

Regulations from which the exemption is requested: 

14 CPR 61.113(a) and (b) 

14 C.P.R. 91.103 14 C.P.R. 91.119 14 C.P.R. 91.12114 CPR 91.151(a) 14 CPR 

91.405(a) 14 CPR 407(a)(l) 14 CPR 409(a)(2) 14 CPR 417(a) and (b) 

UASs operated by Big Shot Aerial Imaging LLC weigh less than 55 pounds, including 

the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more than 50 

knots, can hover, and can simultaneously move vertically and horizontally. Big Shot 

Aerial Imaging LLC will only operate its UASs in line of sight and will operate only 

within the sterile area described in the POPM. Such operations will insure that the UAS 

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

Given the small size of Big Shot Aerial Imaging LLC's UASs and the restricted sterile 

environment within which they will operate, Big Shot Aerial Imaging LLC's UAS 

operations adhere to the Reform Act's safety requirements. Additionally, due to the size 

of the UASs and the limited areas in which they will operate, approval ofthis application 

presents no national security issues. Based on the substantial level of safety surrounding 

the proposed operations, and the significant public benefit (enhanced safety), reduction in 

environmental impacts (reduced emissions and noise), the grant of the requested 

exemption is in the public interest. Accordingly, Big Shot Aerial Imaging LLC's 

respectfully requests that the P AA grant the requested exemption without delay. 

PIC Qualifications 

Daniel M. Ursitti, ATP Helicopter/Rotorcraft Helicopter 

Commercial Privileges: SEL 

Ratings Type: 

B737, GN, CE500, N265, CL604, SK76, DA50 

Medical: 1st Class 

Restrictions: Must wear corrective lenses 

Experience: 

Commercial pilot since May 25, 1979 with total time of 18,700 hours (17,000 is PIC) 

UA V Systems: 25 years mostly recreational 

Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Big Shot Aerial Imaging LLC provide for at least 
an equivalent or higher level of safety because operations further enhance safety of movie 

and television filming using conventional aircraft. 

As set forth in the FOPM, the limitations and conditions include: D 

1. The UASs will weigh less than 55 pounds 

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

3. Maximum 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, and not 

more than 200 feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the UAS Pilot, the Visual 

Observer, and the Camera Operator. 

6. A UAS pilot will be an FAA licensed airman with at least a private pilot's 

certificate and third class medical. 

7. A VAS Pilot will be Pilot in Command (PIC): If a pilot certificate holder other 

than the UAS Pilot, who possesses 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 

FOPM. The FOPM requires the establishment of a "Security Perimeter" for the 

flight operations area. 

9. A briefing will be conducted for planned UAS operations prior to each day's 

flight. All personnel performing duties within the boundaries of the safety 

perimeter are required to attend. 

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 

("FSDO"). 

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

that only consenting persons will be allowed within 100 feet of the flight 

operation. This radius may be reduced to 30 feet based upon an equivalent level 

of safety determination, as required under the FOPM. With the advanced 

permission of the FSDO, 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 in the FOPM. 

13. The Pilot and observer must be trained in UAS operations and have received 

current information on the particular UAS to be operated as required by the 

FOPM. 

14. The Observer and pilot will at all times be able to communicate by voice and/or 

text. 

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 UAS loses communications or loses its GPS signal, the UAS will have the 

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

18. The UAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot 

Privileges and Limitations: 

Pilot in Command Sections 61.113 (a) and (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 than a commercial pilot's 

license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is 

remotely controlled by a ground-based operator. The operational area is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of safety 

exceeds that provided by a single individual holding a commercial pilot's certificate 

operating a conventional aircraft. The risks associated with the use of a UAS are so 

diminished from the level of risk associated with commercial operations contemplated by 

Part 61 allowing UAS use by a private pilot as the PIC exceeds the present level of safety 

sought by 14 C.F.R. §61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action Section 

91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. 

As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. 

However, an equivalent level of safety will be provided. The PIC will take all actions, 

including reviewing weather, flight battery requirements, landing and takeoff distances, 

and aircraft performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

provides, in pertinent part, that: "except when necessary for takeoff or landing, no person 

may operate an aircraft below the following altitudes: ..... 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure." 

Because Big Shot Aerial Imaging LLC requests authority to operate at altitudes only up 

to 400 AGL, and not more than 200 above an elevated platform from which filming is 

planned, an exemption is needed to allow such operations. Except for the limfted 

conditions stated in the FOPM, the UAS will never operate higher than 400 AGL. It will, 

however, be operated in a restricted area within a security perimeter, where buildings and 

people will not be exposed to operations without their pre- obtained consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of property owners or local officials. Because of the advance notice to the 

property owners and participants in the filming activity, all affected individuals will be 

informed of the planned flight operations. Compared to flight operations for manned 

aircraft and the lack of flammable fuel, any risk associated with the proposed UAS 
operations is far less than conventional aircraft operating at or below 500 AGL. In 

addition, the low-altitude operations of the UAS will ensure separation between a UAS 

and conventional aircraft. 

14 C.P.R. §91.121 Altimeter Settings 

Section 91.121 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 a UAS may not have a 

barometric altimeter, but instead a GPS altitude data, an exemption is needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the FOPM 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 VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed- (1) During the day, to fly after that for at least 30 minutes .... " 

The battery powering the Big Shot Aerial Imaging LLC UASs provides approximately 18 

minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR 

§91.151, UAS flights will be limited to approximately 10 minutes in length. Given the 

limitations on the VAS's proposed flight area and its proposed operations within a 

predetermined location, a longer time frame for flight in daylight VFR conditions is 

reasonable. Furthermore, operating the UASs in a tightly controlled area where only 

people, property owners, or official representatives who have signed waivers will be 

allowed, less than 30 minutes of reserve fuel does not engender the type of risk that 

§91.151(a) was intended to address. 

Big Shot Aerial Imaging LLC believes that safety can be achieved by limiting flights to 

10 minutes or 25% of battery power, whichever occurs first. This restriction would be 

more than adequate to return the UAS to its pre-determined landing zone from anywhere 

in its limited operating area. 

Big Shot Aerial Imaging LLC is not seeking an exemption for nighttime UAS operations. 

14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner shall "have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) ofthis section, have discrepancies repaired as 

prescribed in part 43 of this chapter ... ," and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Big Shot Aerial Imaging's operations. 

Maintenance will be accomplished by the operator. An equivalent level of safety will be 
achieved because the UASs are limited in size, will carry a small payload and operate 

only in restricted areas for limited periods of time. If mechanical issues arise, the U AS 

can land immediately and will be operating from no higher than 400 feet AGL. As 

provided in the FOPM, the operator will ensure that the UAS is in working order prior to 

flight, perform any :required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the UAS and best suited to 

maintain it in an airworthy condition. 

Summary for Publication 

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

Federal Register, should it be determined that publication is needed: 

Big Shot Aerial Imaging LLC seeks an exemption from the following rules: 

14 C.F.R. §§ 61.113(a) and(b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a small 

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

As established by the U AS exemptions already granted by the FAA, allowing 

commercial operations ofUASs in the film industry will enhance safety by reducing risk. 

Conventional film operations, using turbine aircraft, operate at low altitudes and present 

the risks associated with aircraft that weigh around 4,000 pounds, and which carry large 

amounts of Jet A fuel. Such aircraft must also fly to and from the film location. In 

contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates 

virtually all of that risk given the small size and lack of combustible fuel. The UAS is 

carried, and not flown, to a film set. In this regard, the UAS carries no passengers or crew 

and, therefore, will not expose them to the risks associated with manned fligh~s. 

The operation ofUASs conducted in the strict conditions outlined in the FOPM will 

provide an equivalent level of safety supporting the grant of the exemption requested 

herein. The UASs operate at slow speeds, close to the ground, and in a sterile 

environment. As a result, they are far safer than conventional operations conducted with 

turbine helicopters carrying fuel and flying near the ground and people. 

Privacy 

All flights \JVill occur over private or controlled access areas with the property owner's 

prior consent and knowledge. Filming will be only of people who have given their 

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

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012 (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 to grant Big Shot Aerial Imaging LLC's requested exemption, allowing for 

Big Shot Aerial Imaging LLC's UAS commercial operations for the construction industry, 

motion picture and television industry pursuant to the FOPM included herewith. 
Ifyou have any questions or need ahy additional infonnation, please contact the 

undersigned at 706-980-9287 or at dan@bigshotaerialimaging.com. 

Sincerely yours, 

Daniel M. Ursitti 

President, Big Shot Aerial Imaging LLC 
BIG SHOT 

AERIAL 

IMAGING 

Unmanned Aerial Systems 

Operations Manual 

January 2016 

Version 2.2 
Preface 

The following procedures are intended to promote safe, efficient and lawful operation 

of Big Shot Aerial Imaging's unmanned aerial system. The primary concern during 

any operation of Big Shot Aerial Imaging's UAS is safety. Any operations must 

comply with all safety and boundary limitations in order to proceed. 

Big Shot Aerial Imaging is dedicate to bringing safe and lawful operation of 

unmanned Aviation systems into the Architectural, Real Estate and Construction 

Agriculture Communities. With their use, Project managers are able to pre-program 

logistic matrixes to minimize impact on local communities, survey development 

location for information modeling, document progress and development in full 

perspective and inspect general scope and facilities for compliance. Additionally, 

project safety officers are able to get first hand perspectives in the event of out of 

reach incidents to make proper response decisions. 

While operating UAS Big Shot Aerial Imaging will abide by all FAA Regulation for 

flight and receive proper authorization for Flight. 

UAV operators and observers will ensure and will be held accountable for ensuring 

that operations of the UAS do not intrude on any individuals privacy and that 

operation will be strictly for the purpose of the Construction project site and its 

boundaries 

We will do this by: 

While in flight on board camera and capture device will only focus on and 

within the boundaries of that specific work site. 

All video of still images from such flight will pass post flight inspection to 

ensure and contain any images that might have inadvertently be capture. All 

non-sites related images will be destroyed. 

All flight operation will be documented and approved by site operations 

director and recorded within the site register. 

Flight operators will stay current on new technologies to ever increase·safety 

and standards. 

Administration 

Operations Manual 

The policies and procedures contained in this manual are issued by Big Shot 

Aerial Imaging and are compiled from a number of sources to best define and 

apply standards so to best ensure safe operation. 

This manual is not intended to be all-inclusive, but as a supplement to federal 

Aviation Administration regulations UAS manufactures approved flight manual 

and other regulatory material. 
This manual was intended to be as current and inclusive at of UAS operations 

at the time it was drafted. Material will be updated and released as amendments or 

versions upon delivery. 

Personnel and Responsibilities 

Operator 

Maintain all training, flight and maintenance records for the operations 

Team and airframe. 

Replace or repair all worn or broken parts only with manufacture approved and 

distributed parts. Such repairs or replacements will be conducted and logged in 

the aircrafts maintenance log by a certified technician of that manufacture. 

Operator must maintain a current class II flight Physical and have demonstrated 

proficiency on the U AS airframe. 

Operators will have sufficient expertise to perform the task of interacting with 

Air Traffic Control. 

Operators must have and understanding of, and comply to FAA and 

Military regulations applicable to the airspace where the UAS will operate. Safe 

and effective operation of the UAS is the operators' primary duty and to do so in 

accordance with FAA and manufactures approved flight manuals. 

Operators will be required to take periodic UAV flight training. 

Observer 

Observers must be able to communicate clearly and directly to the 

operator any turning or avoidance instructions required to stay clear of any 

obstructions. 

Observer's primary duty is to operate camera as well as maintain and 

monitor surrounding airspace and on ground occurrences. 

Observer will monitor flight information in regards to safe and compliant 

distances and altitudes and report such information to the operator. 

Observer will monitor onboard systems such as power consumption, flight 

time remaining and radio transmission strength. 

Observers will be required to take periodic flight operations training. 

Safety 

Big Shot Aerial Imaging will support safety training and awareness programs. 

Additionally, regular audits of safety policies, procedure and practices will be 

conducted. 

Monitoring of the UAS community to ensure best safety practices are 

incorporated into our standard operations. 

Operators and observers will never operate outside of manufacture 

recommendation, FAA regulations or weather constraints. 

Operation ofUAS will operate within the geofence and boundaries of such 

construction site. All ground personal will be alerted to flight path and 

operation of the UAS. 

Any and all occurrences will be reported to construction site manager 

immediately. All potential operational hazard or interference will be 
reported to construction site manager as well as Big Shot Aerial Imaging 

supervisors. 

No flight will be conducted until hazard has been removed or rectified. 

Communicate all reported safety related problems and the corrective action 

taken. 

Medical Factors 

Operators and Observers shall only deploy the UAS when rested and 

emotional prepared for the task at hand. 

Physical illness, exhaustion, emotional problems, etc., can seriously impair 

judgment, memory and alertness. The safest rule is not to act as an operator or 

observer when suffering from any of the above. Persons are expected to 

stand down and postpone flight when these problems could reasonably be 

expected to affect their ability to perform flight duties. 

All crew shall make a self-assessment of physical condition during pre-flight 

activities. 

Performance can be seriously hampered by prescription and over the counter 

drugs. If it is determined by crew or self-assessment that medication taken 

could hamper operation and observation that crew member will be prohibited to 

continue for that deployment. 

No crew person shall act as an operator or an observer within eight hours after 

consumption of any alcoholic beverage, while under the influence of 

alcohol. Or while having a concentration of0.04 (FAR 91.7) 

Training 

The key to continued safe operations is by maintaining a professional level 

of competency. The first step in this process is establishing minimum 

qualifications and then keeping up with continued flight training and 

regulations. 

Operators will enroll in appropriate training( fixed wing) in order to obtain 

their private pilot license/certificate. 

Observers will complete sufficient training to communicate to the pilot 

Operator and observer will have sufficient knowledge of air traffic and 

radio communications, including the use of approved A TC/pilot 

General Operating Procedures 

UAS flight will only be made when a request has been made and approved 

by the project site manager. 

UAS will only operate under VFR guidelines. 

UAS crew will only deploy if weather conditions that are within manufactures 

recommendations. 

Flight crew will only deploy UAS after completion of preflight checklist 

UAS will only be used within the boundaries of the given and documented 

project site and at a maximum altitude of 400 feet per the FAA COA. 

UAS operator will have in their possession a VFR Terminal Area Chart of 

the project areas to determine airspace designation and ATC 
'I~ ' I ,.,. 

interaction. Ariy requests from ATC or local towers will be made in 

advance of flight and flight plans will be filed as such. 

The Minimum personnel required on all flight with are an Operator and observer. 

The operator is directly responsible fro, and is the final authority over the actual 

operations of the UAS. 

Operators have the absolute authority to reject a flight based on personal safety or 

violation of FAA regulation. No mater the instructions from a project manager. 

Operators are responsible for compliance with this manual and FAA regulations. 

Operator shall see and avoid any obstacle that will lessen safety during flight. 

Operators shall be responsible for documentation for mission training and 

updating of flight books. 

Observer shall see and avoid any obstacle that will lessen the safety during flight. 

Observer shall operate any attachment to the UAS, allowing the operator to 

maintain complete focus on the operation of the UAS. 

Observers shall assist operators in the main objective of safe operation ofUAS. 

Personal Equipment 

Operators /Observers shall wear proper eye protection at all times while UAS is in 

Flight. Depending on conditions Operators /Observers will wear polarized 

sunglasses 
BIG SHOT AERIAL IMAGING LLC Flight Checklist and Procedures 

Pre-Operation Planning 

o Set flight time and duration with 

project manager Project. 

o Check Distance to nearest Airport 

and or controlled airspace using 

current FAA Sectional Aeronautical 

Chart. If within 5NM required 

procedures need to be followed. 

o Pre-Contact local A TC if required to 

inform ofUAS operation. Adjust 

flight as instructed. 

o Check Aircraft for any visible 

damage or loose part. 

o Gently shake to insure no internal 

parts are loose. 

o Check Props for cracks or damage 

(replace if needed) 

o Charge Aircraft and Camera 

Batteries. 

Pre-Operation Check 

1. Visually determine if flight area is 

clear of any obstruction or public 

spaces. 

2. Visually determine weather 

conditions are ideal for flight. IF 

RAIN, CLOUD COVER OR HIGH 

WIND EXSIST ABORT FLIGHT. 

3. If required, use VHF aviation 

Transceiver to contact tower if 

closer than 5NM. 

4. Inform tower/CTAF ofUAS ops, 

location and Max height of flight. 

Pre-Flight Check 

1. Place aircraft case on level surface. 

2. Remove Radio Controller 

3. Check for that all controls are free 

and operational. 

4. Check battery. 

5. Remove Aircraft 

6. Check for any damage, loose parts 

a. Landing Skids 

b. Props 

c. Prop Nuts 

d. Battery door 

7. Check Gimbal for free, clear and 

smooth operation. 

8. Check camera is secure and 

functioning 

9. Check Aircraft battery with voltage 

tester. (Do not use battery with 

percentages of charge lower than 

90%) 

10. Place UAS in clear and safe launch 

area. 

11. Place all Radio transmitter toggles 

to full up position. 

12. Center flight control 

13. Place throttle control in full down 

position (No throttle in) 

14. Turn Controller on 

15. Place battery into Aircraft 

16. Close and secure battery door 

17. Aircraft will make and AUDIBLE 

alert of powering up 

18. Indicator Light will run a diagnostic 

pattern to determine satellite 

connection and compass calibration. 

(If light indicate re calibrate 

compass using manufactures 

compass calibration procedure) 

19. Once aircraft cycle through 

diagnostics it will indicate as to 

flight readiness. 

20. Check area for any activity and 

announce CLEAR AREA. 

21. Raise throttle to 10% power to 

engage engines. 

22. Check and listen for smooth 

operation or no presence of grinding 

noise. 

23. Check operation of gimbal 

movement. 

24. Engage throttle to 52% power 

25. Lift off 

After lift off 

Hover aircraft at 1Oft 

Check operation of control 

Front 

Back 

Left 

Right 

Rotation (L/R) 

Proceed with Flight 
Landing check 

1. Clear landing area 

2. Return aircraft to above landing area 

3. Hover at 30ft 

4. Announce CLEAR FOR LANDING 

5. Slowly decrease power till Aircraft 

is descending. 

6. Hold throttle stick at descending 

position 

7. Once aircraft is down, Disconnect 

and remove battery from Aircraft 

8. Turn of power to controller 

9. Notify Tower of complete operation 

End of Operation 

o Return Aircraft and controller to 

case 

o Mark battery as used 
Phantom 2 Vision + 

Mission Checklists 

psflightorg 

Amvalictl~iflij 

·,_ If day and operating out of back of 

vehicle. point vehicfe into sun. 

2. Remove case and place on level surface. 

3_ Check distance to nearest airport and/or 

controlled airspace using smartphone or 

tablet app~ 

4. tf r~uired. use VHF aviation transceiver. 

to contact tower of field if closer than 5 

NM_ 

5.. Inform tower l CTAFof UAS ops) location. 

and max height of flight 

1_ . emove transmitter. 

2. Router ~ On 

3. Transmitter - On 

4_ Toggle Switches - FuiiiJp 

5, Video Monitor - On 

6< Remove UAS from case. 

7. Gimbal Lock & Lens Cap .. Removed 

8" M1cro.-SO card - Inserted. 

9. UAS Battery - Inserted 

10. Place UAS in clear and safe launch and 

recovery position if it returns to home. 

11_ UAS Battery- On 

12. Wdi Connection to Monitor - Verified 

13. OJI Application - Load 

14_ OJI application- Connect to Camera 

15. so Card ~· Format 

16. Camera- Full Up 

17. Satellite Connections ~ Verified 

18. Charge Levels= Safe for Fligh1 

19_ Video :Recording~ Start 

20. Takeoff 

1_ Hover approximately ten foot above the 

ground to confirm UAS is under control. 

2. All sticks operate correctly while in h.over 

-Verified 

amera Up 

Video Recorder .. Stop 

Landing Zone -Clear /Safe 

1. Battery .. Remove & Replace 

2; Wm Connection to Monitor~ Verified 

3~ DJt appltcation - Connect to Camera 

4. Takeoff 

'ena[o'f~ \eellfil' ' ' ·-_,.__. , ,,s "-' '"'M.o:~,.,,,_,~·~-Mi.:.. '.'""' 

1. Battery - Off 

2_ Transmitter - Off 

3 .. Router .. Off 

4. Notify Tower/CTAF- End of Ops